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.
(Attorney at Law) Texas Bar No.
24058299
Defendant
Joyce M. Guy
Edward McCray
Co-Defendant(s)
Amend Civil Complaint
Jury Demand
Comes
Now The Pro Se Plaintiff “Louis Charles Hamilton II” Pro Se Plaintiff files
“Amend Complaint” with the above Honorable U.S. District Court and for Just Cause,
Pro Se Plaintiff herein will show before the “Honorable U.S. Court” all facts,
circumstances, detailing “among other things”
“Past, present and
future (RICO) “Racketeer Influenced and Corrupt Organizations Acts and actions,
to include but not limited to actual Fraud of a 58 Judicial District Civil
Court in Jefferson County in Common Law,
And direct “Obstruction of Justice” in
connection thereof Civil Court Docket No. A-180805 being with criminal hostile
intent committed against among others the Pro Se Plaintiff “Louis Charles
Hamilton II” herein “Will”, “Civil Rights”, “Peace” “Personal Property” and
“Dignity”.
“United States
of America” Not a Party to this U.S. Civil Suit “However” at this present time frame “United States of America” being past,
present and future “time frame" being legally a unwilling connected party to all
subject matter to which includes “United States of America” suffrage in “actual
monetary losses” in excess of
$127,339.31
U.S. Dollars in connection with Hurricanes, “Rita”, “Humberto” and Ike” storm
damages in connection with the Pro Se Plaintiff Louis Charles Hamilton II herein
Profession
as an “Independent Construction Contractor” And the property(s) located at 5050
east 7th street in Port Arthur Texas and 448 DeQueen Blvd. in Port
Arthur Texas
1.
Parties.
Pro Se, Louis Charles
Hamilton II, African American Male, U.S. Navy Veteran,
Pro Se Plaintiff , Louis Charles Hamilton II, African American Male,
Permanently Disable Veteran protected under:
(ADA) American with Disability Act;
And also minorities persons cover under Title VII of the Civil Rights Act of 1964;
Domiciliary State of Texas, P.O. Box 17524 Sugar Land, Texas 77496
Pro Se Plaintiff , Louis Charles Hamilton II, African American Male,
Permanently Disable Veteran protected under:
(ADA) American with Disability Act;
And also minorities persons cover under Title VII of the Civil Rights Act of 1964;
Domiciliary State of Texas, P.O. Box 17524 Sugar Land, Texas 77496
2.
Defendant(s) Antoine L.
Freeman J. D. (Attorney at Law) (Active) in and for the State of Texas Bar No.
24058299
Has “Two Legal Law Offices” in Port Arthur Texas, 3627 Professional Dr.
Port Arthur Texas 77642 and 3723 Gulfway Dr. Port Arthur Texas 77642
3.
Co-Defendant(s) Joyce M.
Guy and Edward McCray (Legally Married) has (5) business E and J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur Texas
Information about E & J Collectibles is in the Used Merchandise Stores
business and this category has 2 companies in Port Arthur Texas.
J Can Company 1807 East
7th Street Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port
Arthur Texas 77640,
G and G Service Company
P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas (Office) located at 448
DeQueen Blvd. in Port Arthur Texas 77640 and “Cars and Pieces” Located in
Beaumont Texas (Office) also located at 448 DeQueen Blvd. in Port Arthur Texas
77640
And Paragon Business
Inc. (Lot 10 “block 18 Jef Chaison)
4.
Jurisdiction
Jurisdiction is proper
before the “Honorable U.S. Court” of The Eastern District of Texas in that (Pro
Plaintiff) is always a resident of Jefferson County Texas, residing in Fort
Bend County and all acts and actions described herein by all the Defendant and
Co-Defendant(s)
(RICO) enterprise endeavor(s) described herein fully occurred
within the Jurisdiction of Eastern District of Texas within the United States
which occurred in Port Arthur Jefferson County Texas.
Chief Defendant Antoine
L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 is a (Active)
“Attorney at Law” for the State of Texas as described above in paragraph (2)
Further said Defendant
Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein was
acting in his full capacities as an “License Attorney” on retainer for the
legal behalf of one
(Co)-Defendant(s) “Joyce M. Guy” and “Edward McCray” living
at 448 DeQueen blvd. in Port Arthur Texas 77640 in a Civil Action in The
District Court 58th Judicial District of Jefferson County, Texas,
Docket No. A-180805
When said Defendant
herein in his fiduciary capacities as an “Attorney of Law” Antoine L. Freeman
J. D. Texas Bar No. 24058299
Committed to “among
many other things” (RICO) “Racketeer Influenced and Corrupt Organizations Act”,
with this racket and Fraud on the 58th Judicial District Court of
Jefferson County Texas, while using also the legal skilled devices in almost 2
years of “Obstruction of Justice” in connection with
“Mail and Wire Fraud”, “Direct Fraud” on all official court
records derive thereof and “Constructive Fraud” in connection with Jefferson
County Texas 58th District Court Records, and
Direct Fraud acts, and actions and scheme of things involved
in Jefferson County Public Records in Connection with (2) “Texas Department of Housing and
Community affairs” for Loans in excess of
$127,339.31
U.S. Dollars in connection with Hurricanes, “Rita”, “Humberto” and Ike” storm
damages in connection with the Pro Se Plaintiff Louis Charles Hamilton II
herein.
5.
To include Defendant(s)
and Co-Defendant(s) collectively in concert, and collaboration in violations of
Title 18 U.S.C. § 1341, 1343 and 1349 “Mail and Wire Fraud”,
Violations of Chapter 96
of Title 18, United State Code: (RICO) Racketeering Influences Corruption
Organization, Chief Defendant Antoine L. Freeman J. D. Attorney at
Law Texas Bar No. 24058299 and Co-Defendant “Joyce M. Guy maintained such a
enterprise from the years of 2007-2010 to execute such a (RICO) enterprise “scheme
of things”, Notwithstanding
Aiding and abetting to
commit to A Criminal Enterprise racket and monetary retain endeavor in “Racketeer
Influenced and Corrupt Organizations Acts” in his Chief Defendant capacity as an
acting
Attorney of Law in and for the State of Texas, against
the rights, peace, dignity, and U.S. Code: Title 28:1343 Violations of Pro Se Plaintiff Civil
Rights herein in “among other
things”
“Equal Protection of the law” in a civil suit
in common law filed in Jefferson County Texas 58th Judicial District
Court within The United States of America docket No A-180805.
To include but not
limited to Chief 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 in
"Violations against the Computer
Fraud and Abuse Act (CFAA) 18 U.S.C. § 1030 in connection with all (RICO)
enterprise “criminal acts and actions”, as legally described fully herein.
6.
Chief 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
Being intertwine in a conspire complex mutable
corrupted “scheme of things” for several years starting from 2007-2010 to
include a rouge attorney engaging in a fraudulent obstruction of justice cover up
“scheme of thing” for all past, present and future (RICO)racketeering past
enterprises monetary gains
In a half bake (RICO) combine “greedy
racket enterprise” scheme of things that has accumulated gradually past acquisition
of hidden (RICO) monetary earnings cars, possessions and properties estimates
in excess of $980,000.00 U.S. dollars
From the time frame of 1997-2015 and to
include but not limited to the Grand (RICO) scheme of things involving the
Pro Plaintiff Louis Charles Hamilton II herein
alone in excess $127,339.31 monetary scam of (2) U.S. Federal Housing Grant.
In a half bake (RICO) combine “greedy
racket enterprise” scheme of things that has accumulated gradually past acquisition
of hidden (RICO) monetary earnings cars, possessions and properties estimates
in excess of $980,000.00 U.S. dollars net gain
From the exact time frame of 1997-2015 and to
include but not limited to the Grand (RICO) scheme of things involving the Pro
Plaintiff Louis Charles Hamilton II herein alone in excess $127,339.31 monetary
scam of (2) U.S. Federal Housing Grant.
Fully “greedy racket enterprise” scheme
of things complete by Co-Defendant “Joyce M. Guy and Edward McCray herein since
1997 Identified as follows:
(RICO)
“Scheme of things” is involved in concealing, obscuring, masking, cloak and
shielding corrupted fraudulent “mutable fraudulent business” enterprise endeavor
operations the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” herein concoct
and obtaining massive hidden income from over many years described as follows:
A. Assumed name business “G & G
Services” a fraudulent Medical services for obtain (13) years of hidden “monetary
payments” from “Senior Aging Handicap Citizens within Jefferson County Texas
which “G & G Services” was never even a litigable Licenses medical company with
the State of Texas from May 2nd 1997- 2010 as being order shut down
as described in Pro Se Plaintiff attached exhibit (F) on file with the U.S.
Clerk from the Texas Department of Aging and Disability Services. *to include
but not limited to “Tax Evasion” being directed at both the “State of Texas”
and “The United States of America” for a actual time period of (13) plus years
in this (RICO) illegal medical business operation fraudulent corrupted “scheme
of things”. To include but not limited to upon information and belief “G &
G Services” medical services is secretly still in business operation …….Omg
(wow) J
B. While “G & G Services” income not
listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and
Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing
Grant in excess of $72,500.00 U.S. dollars.
C. Assumed name business “E and J
Collectibles” 448 DeQueen Blvd. in Port Arthur Texas which is in the Used
Merchandise Stores business for a unknown amount of years having (2) companies
in Port Arthur Texas “However” these (2) companies is not registries with
“Jefferson County Texas, or upon information and belief registries with the “State
of Texas” fully engaging in among other things (RICO) enterprise in “Sales Tax
Evasion”, *Business is current in operation as identified on the “internet” for
a unknown accountability of time.
D. While “E and J Collectibles” income
not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and
Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing
Grant in excess of $72,500.00 U.S. dollars.
E. Assumed Name J Can Company in Port
Arthur Texas business operation from April 11th 2008 – 2015 this J
Can Company business operation is a “front company” for (RICO) enterprise
scheme of things in “among other things” besides hidden sells of “Crack cocaine
industry” actually further engaging at this present time frame April 11th
2008 in (RICO) enterprise in “money laundering” in scrap metal materials” in
connection scheme of things with assumed name business “Cars and Pieces”.
F. Another “front company” located in
Beaumont Texas. To include but not limited to J Can Company business operation
and “Cars and Pieces” business operation (RICO) enterprise engaging in State
and Federal Tax Evasion.
G. While J Can Company income not listed fully in
“Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray”
collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess
of $72,500.00 U.S. dollars.
H. Assumed Name “Car and Pieces” in
Beaumont Texas business operation from May 10th 1990 while actually
engaging in (RICO) enterprise in “money laundering” in scrap metal materials”
in connection with assumed name business J Can Company in Port Arthur Texas. As
described in paragraph (C) above.
I. While “Car and Pieces” income not
listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and
Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing
Grant in excess of $72,500.00 U.S. dollars.
J. Assumed Name Paragon Business Inc.
being a unknown company of sorts, current in business operation since May 17th
2001 while Paragon Business Inc. income not listed fully in “Financing
Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively
herein to (RICO) fraudulent obtain Federal Housing Grant in excess of
$72,500.00 U.S. dollars.
7.
To include Chief
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 fully being both “directly” and “indirectly “
Design
carefully with “conscious intent” to criminally conspire, plotting, scheme, and execute
(2) (RICO) racketing monetary endeavor(s)
against the
“United States Housing Grant(s)” being
Congress funded with the “State of Texas Housing” and “Community Affairs
Project” in direct violation against 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; in connection
In connection with fraudulent legal device,
tactic’s, instruments and documentations to fraudulent obtain in excess of $127,339.31
scam being knowingly and willfully conspire, collaborated as such against (2) United
States Federal Housing Grant.
“Namely” on May 28th 2010
7.
“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 Grant”
As
being described in Pro Se Plaintiff exhibit (P) on file with the U.S. Clerk of
Court namely a “Mechanic’s Lien Contract” with DSW Homes 805 S. Hwy. 69,
Memorial Fwy, Nederland, TX, 77267
To repair the home located at 5050 east 7th
street in Port Arthur Texas after (2) Private Insurances Monies for hurricane
damages to said property already being a part of a continue (RICO) “pattern and
practice” squander free “scheme of things” committed by Co-Defendant(s) “Joyce
M. Guy and Edward McCray” collectively
Involving
once again the Pro Se Plaintiff Louis Charles Hamilton II herein as the
Construction contractor providing damages estimates with Chief Defendant
Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 fully in
fraudulent (RICO) legal denial of ever being actually the physically acting
“Attorney of record” in this civil suit in common law A-180805 as a part of
this cover up scheme of things
While
all of this criminal half bake concoct (RICO) enterprise “scheme of things”
being formed and direct against not only the Pro Se Plaintiff, but to include private
insurances companies in connection with the Pro Se Plaintiff Construction
damages estimates at
(2)
Counts and among others parties namely “The United States of America” for a
monetary lost in excess of $54,839.31 U.S. Dollars. For the property located at
5050 east 7th street in Port Arthur Texas 77640
8.
To
add to Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collective
combine additional (RICO) enterprise “scheme of things” in a past further
fraudulent “scheme of things” in obtaining additionally another monetary (RICO)
enterprise shame in excess of $72,500.00 U.S Dollars from “Namely” on June 9th
2009
“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) Namely
“Mechanic’s Lien Contract” SWMJ Construction Inc., 525 N. Sam Houston Pkwy
East, Suite 600, Houston, Texas 77060
For
Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein
In
a total (RICO) combine pattern and practice “scheme of things” against the
“United States of America” alone for two properties in monetary ill gotten gain
in excess of $127,339.31 U.S. Dollars
9.
Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299
Fully Committed to among other things “Obstruction of Justice” in the capacity
as an “Officer of the Court” and “Attorney of Law” in and for the State of
Texas To commit and conspire to the same
(RICO) criminal enterprise causes in all
“acts and actions” in leadership, direct legal conspire devices, instruments
and documentations & fully in concert, collaboration with the
Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”
herein from to 2007-2015
Fully Described herein against the Pro Se
Plaintiff, While further willfully Omitting to and Destruction thereof
“Material Civil Evidences and Facts” before a ongoing “Civil Suit” in Common
Law in Jefferson County Texas 58th Judicial District
With “among other
things” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No.
24058299 and Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Actual Fraud upon
the
“Texas Department of Housing & Community
Affairs” Jefferson County Texas and Federal Grants derived thereof in
Connection with the Pro Se Plaintiff “Louis Charles Hamilton II” herein an “Independent
Construction Contractor”.
With “among other
things” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No.
24058299 and Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Actual Fraud
of Private Homeowner Insurance Companies”, for primary fraud during
“Hurricane
“Rita”, “Ike” and “Humberto” related to Construction storm damages, in
connection with the Pro Se Plaintiff “Louis Charles Hamilton II herein.
10.
Co-Defendant(s) “Joyce
M. Guy” and “Edward McCray” To commit to the same “Obstruction of Justice” fraud
and concealment of such (RICO) activities committed against the 58th
Judicial District Court, for primary fraud during “Hurricane “Rita”, “Ike” and
“Humberto” related Construction storm damages, with the leadership of
Chief Defendant(s)
Antoine L. Freeman J. D. (Attorney at Law) (Active) in and for the State of
Texas Bar No. 24058299 and in full collusion with Co-Defendant(s) “Joyce M.
Guy” and “Edward McCray et al”
Conspiracies collectively together to pursue the same Criminal (RICO) “Racketeer Influenced and Corrupt Organizations Act” monetary objectives,
In first and foremost Execute
Fraud on the 58th Judicial District Court of Jefferson County Texas and
the Honorable Bob Wortham with such acts, actions and events as “Mail and Wire
Fraud” in connection thereof, of the “Direct (RICO) Fraud “scheme of things” to
fraud the United States Disaster relief Homeowner program
and “Constructive
Fraud” of Jefferson County Texas 58th District Court Records, Fraud
of Jefferson County Public Records All “among other things”
being done criminally/civilly against the Pro Se Plaintiff civil rights, peace,
will, and dignity,
During an ongoing “Civil Suit” of Common Law
in Jefferson County Texas.
All being wrongfully and
fully committed to within the Jurisdiction the Eastern Division of
Texas United States District Honorable Court.
11.
Subject Matter Jurisdiction
Venue
Pro Se Plaintiff Louis
Charles Hamilton II herein States, Affirm, and Declare Before the “Honorable
Justice” Subject Matter Jurisdiction is fully proper before this U.S. District
Court primary exclusive with many “federal Questions”
involving “among other things”
Violations of Chapter 96
of Title 18, United State Code: (RICO) Racketeering Influences Corruption
Organization,
Section 1341 (relating
to mail fraud), section 1343 (relating to wire fraud), section 1028(relating to
fraud and related activity in connection with identification documents),
Section 1503(relating to obstruction of
justice),
Falsification,
obstruction and concealment of “Material facts”, subject matter before a civil
suit in common law proceeding with Conspiracies committed by all described “Defendant
and Co-Defendant(s)” herein collectively to pursue to the same Criminal Monetary
(RICO) enterprise monetary racket Objective(s) involving against the Pro Se
Plaintiff herein will, and personal property
With
mutable counts of constructive fraud activities “hiding behind” among other
things “attorney-client privilege” and all “work-product
doctrine” derive thereof, to include but not limited to all “communications”
between an “Attorney and his client”,
Namely Defendant
Antoine L. Freeman J. D. (Attorney at Law) (Active) in and for the State of
Texas Bar No. 24058299 in collusion and conspiracies with Co-Defendant(s)
“Joyce M. Guy” and “Edward McCray et al”
To Commit to each and
every Fraudulent acts in among other things all “prepared legal court
documents”, “affidavit(s)”, “interrogatories”, “request for admissions”, sign
statements and all other materials of Jefferson County Court records,
document(s) and materials facts in 58th Judicial District Court of
Jefferson County Texas Court Docket No. A-180805
“To include but not limited” absolute
obstruction of Justice to apply the same (RICO) scheme of things in a fraud attack
upon the Honorable Judge Bob Wortham, and His 58th Judicial Court and
all court officers, court transcripts involved thereof,
Including Fraud of the entire
“Clerk of Court office” records of Jefferson County Texas docket No. A-180805 to
execute the same (RICO) criminal monetary objectives described legally herein
this “Amend Complaint” of the Pro Se Plaintiff with
Fraud in all records at
the Jefferson County Clerk Office involving in financial records in connection
with “Insurance Companies”, and official “Financial
Statements” for primary monetary fraud and scheme
advantages during “Hurricane “Rita”, “Ike” and “Humberto ” scheme of things related
to Construction storm damages, derive thereof further involving the Pro Se
Plaintiff herein in his private profession as a “Independent Construction Contractor”.
12.
“To include but not
limited to” the ” Actual Fraud”, upon the “Texas Department of Housing & Community Affairs” of Jefferson
County Texas and “Federal Grants of $72,500 U.S. Dollars” derive thereof and Federal Grants of $54,839.31 in
connection with the Pro Se Plaintiff herein
In Violations
of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences
Corruption Organization, Section 1341 (relating to mail
fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud
and related activity in connection with identification documents),
Section 1503(relating to obstruction of
justice), violation of 18 U.S.C. § 1001: US Code -
Section 1001:
To include but not limited to the “Actual
Fraud(s)” the Co-Defendant(s) “Joyce M. Guy” and “Edward
McCray” committed and involved in monetary conspiracies
against mutable “Insurance Companies”, for primary fraud and monetary scheme advantages during “Hurricane
“Rita”, “Ike” and “Humberto ” related Construction storm damages, for (2)
properties as described herein
Involving further The
Pro Se Plaintiff herein as a “unwilling blind” party into this cold calculated complex
fraudulent acts and action(s), and complex scheme of things to further leading
to fraud of the “Texas Department of Housing” & “Community Affairs” of
Jefferson County Texas
And a “Federal Grants in excess of $72,500 U.S. Dollars”
derived thereof and Federal Grants of $54,839.31 derived thereof under the
direction, leadership, and skills of none other than the Chief Defendant Antoine
L. Freeman J. D. a (Attorney at Law) (Active) in and for the State of Texas Bar
No. 24058299
13.
“With Actual Fraud”,
upon the 58th Judicial Court of Jefferson County Texas and all
records derive thereof, in this “Grand (RICO) enterprise “scheme of things” in
connection with a fraudulent complex designed scheme of things against the
“Texas Department of Housing & Community
Affairs” of Jefferson County Texas and (2) “Federal U.S. Grants in excess of
$72,500 U.S. Dollars” derived thereof and Federal U.S. Grants of $54,839.31
derived thereof for a combine total of $127,339.31
14.
To include but not limited to Actual Fraud of mutable
Insurance Companies”, fraud of FEMA Repair Funds and
repair materials for primary additional monetary fraudulent
acts and actions gains during “Hurricane “Rita”, “Ike” and “Humberto” related
Construction storm damages, involving the Pro Se Plaintiff Louis Charles
Hamilton II herein
All this “Complex Mutable
Grand Scheme of Things” committed By the Name “Chief Defendant
Antoine L. Freeman J. D. a (Attorney at Law) (Active) in and for the State of
Texas Bar No. 24058299 in direct collusion, leadership, legal skilled directions
and conspiracies thereof with Co-Defendant(s)
“Joyce M. Guy” and
“Edward McCray et al” collectively corrupted activities,
dating back since the year 1997-2015
To include but not
limited to being a dated of unpaid “Principal and Interest” on (1) of the
Co-Defendant(s) collectively herein (RICO) monetary scheme of thing for $72,500
U.S. Dollars housing grant being mature on June 8th 2012 when it was
fraudulently executed on June 9th 2009 and To include but not
limited to being a dated of unpaid “Principal and Interest”
On the second
scheme of things designed of the Co-Defendant(s) collectively herein (RICO) monetary
scheme of thing for $54,839.31 U.S. Dollars housing grant being mature sometime
in the future year of 2015 when it was fraudulently executed on May 28th
2010
Fully executed in past,
present and future (RICO) enterprise endeavor full crafty complex designed, prepared
plans, legal court records, type mail and wire fraud “scheme of things”, with
an corrupted skilled evil eye towards the “realistic possibility” of impending “United
States Federal Court litigation” by the Pro Se Plaintiff herein
Against “Defendant and
Co-Defendant(s)” collective commitment to include but not limited to this Grand
direct (RICO) Fraudulent monetary shameful objects and obstruction of justice
“scheme of things” being direct against The will of the 58th
Judicial District Court of Jefferson County Texas and all Court records derive thereof
in this civil in common law Docket No A-180805.
And the realistic
object by all described Defendant and Co- Defendant(s) herein to further commit
to Fraud for “monetary value gain” in excess” of $336,000.00 U.S. Dollars in
(7) years of Pro Se Plaintiff “Lost wages” and “actual theft” thereof Pro Se Plaintiff”Louis
Charles Hamilton II” herein construction Company entire “Construction tools” in
excess of $3,800.00 U.S. dollars since date of injury
November 17th
2007 and counting well into 2015 in this (RICO) enterprise collective “scheme
of things” being still directly enforced, very much ongoing and very live
against the Pro Se Plaintiff Louis Charles Hamilton II herein fully against the
Pro Se Plaintiff “Civil Rights”, “Peace”, “Will” ,“Personal Property” and “Dignity”,
as of this undersigned date of this “Amend Complaint”.
15.
With further combine past,
present and future (RICO) enterprise conspiracy racket “scheme of things” in
mutable “fraudulent” acts, actions, events, and circumstances committed by “both”
the Defendant and Co-Defendant(s) collectively herein to plan a continue future
“scheme of things” in the also continue Theft of Pro Se Plaintiff
“Independent Construction Company “Personal Property” herein against the Pro Se Plaintiff Louis Charles Hamilton II
Being wrongfully added
in this (RICO) enterprise criminal conduct being executed and done within the
Jurisdiction of the “Honorable U.S. Justice” further causing the Pro Se Plaintiff
“Louis Charles Hamilton II” herein to suffer “among other things” actual
damages in excess of $336,000.00 U.S. Dollars to include to impose
Extreme real life
hardship, Extreme Intentional Infliction of
emotional distress and mental anguish from all of the combine Defendant and
Co-Defendant(s) among other things conspire in (RICO) “Racketeer Influenced and Corrupt Organizations Act”,
“Fraud on the Court”,
“Mail and Wire Fraud” in connection with Fraud upon the Court, “Obstruction of
Justice” “Direct Fraud” and “Constructive Fraud” of Jefferson County Texas 58th
Judicial District Court Records,
Fraud upon the
Jefferson County Public Records combine with all other extreme hostile
corrupted wicked cruel civil/criminal acts and actions being
fully described in this amend complaint herein.
16.
Pro Se Plaintiff herein
States, Affirm and Declare before the Honorable Justice” Chief Defendant Antoine
L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 with expert skilled
attorney at law powers, fiduciary responsibilities with “intent willful knowledge
of his actions knowingly and willfully engage to committed a combine conspiracy
with Co-Defendant(s) “Joyce M. Guy and Edward McCray collectively herein to act
in:
Violations of Chapter 96
of Title 18 United State Code:
In that Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No.
24058299 (RICO) Racketeering Influences Corruption
Organization Enterprise, engagement endeavor
To include commit (RICO)
under Section 1341 (relating to mail fraud), section 1343
(relating to wire fraud),
Section 1028(relating
to fraud and related activity in connection with identification documents),
Section 1503(relating to obstruction of
justice),
Fraud upon the 58th
Judicial District Court of Jefferson County Texas in connection with
Falsification and
concealment and direct destruction of “Material facts”, namely an entire Home
being destroyed while being material evidence during said civil suit in common
law
While adding numerous other Fraudulent
Activities in the Capacity of an “Attorney
at Law” to cause Pro Se Plaintiff “Louis Charles Hamilton II” herein to continue
suffers “actual damages” in excess of $336,000.00 U.S. Dollars
And this “actual
damages” is ongoing as of this undersigned date in the year of 2015 of this “Amend
Complaint” before the “Honorable Court U.S. Justice” since date of injury
November 17th 2007.
17.
To include mutable (RICO) enterprise in “Falsification
of “Material facts” Documents and Records, and Numerous Fraudulent Activities
in the Capacity of a “Attorney at Law” In direct connection with Pro Se Plaintiff
“Louis Charles Hamilton II” herein and direct fraud against the
“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 Grant”
As being described in Pro Se Plaintiff
attached exhibit already filed with the U.S. Clerk office in the records being
described as Pro Se Plaintiff exhibit (P)
And
Defendant and Co-Defendant(s) collectively once again obtaining additionally by
(RICO) enterprise “scheme of things” design, instrument and device and legal
court documents another monetary shame in excess of $72,500.00 U.S Dollars
“Namely”
on June 9th 2009 committed against 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 already filed with the
U.S. Clerk office in the records being described as exhibit (Q)
Namely “Mechanic’s Lien Contract” SWMJ
Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas
77060
For
Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein
In
a total (RICO) enterprise combine monetary “pattern and practice” “scheme of
things” against the “United States of America” tax payers in monetary
fraudulent acquisitions gain and earnings in excess of $127,339.31 U.S. Dollars
18.
Pro Se Plaintiff “Louis
Charles Hamilton II” herein seeks Actual, Accumulative, Compensatory, Consequential,
Continuing, Expectation Damages, Foreseeable, Future, Incidental, Indeterminate,
Reparable, Lawful, Proximate, Prospective, Special, Speculative, Substantial, Declaratory
Judgment, Punitive, Exemplary and Permanent Damages;
Pro Se Plaintiff seeks also
Actual Awards for “Intentional Infliction of Emotional Distress” and “Mental Anguish”.
Pro Se Plaintiff moves
the Cost of the Honorable Court, and for the Pro Se Plaintiff legal fees, any
Attorney Fee’s occupied herein
And such other further
relief as Pro Se Plaintiff “Louis Charles Hamilton II may be deem entitled to
in Law or in Equity.
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