Factual Background
19.
Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S.
Justice” Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) and
Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein having on
the
28th day of August 2009 in a “live” courtroom hearing setting
before
The
58th Judicial District Court of Jefferson County Texas appeared in
there persons and “legally defeated” Pro Se Plaintiff attempt to protect “Norma
Guy” legal Senior Citizen Rights” from her own fraudulent destructive daughter
pattern and practices in a continue long history of (RICO) enterprise scheme of
things since 1997. Starting with first and foremost” in that
Namely
Co-Defendant “Joyce M. Guy” (RICO) enterprise scheme had commenced early against
another said Hurricane damaged “property” located at 5050 east 7th street
in Port Arthur Texas.
Which
the Co-Defendant(s) “Joyce M. Guy” herein enjoying a “Power of Attorney”
relating to Real Property Transactions as Described in Pro Se Plaintiff
attached exhibit (O) herein already on file with the U.S. Clerk Office “Specific
Power of Attorney” executed on the 27th day of May 2010.
20.
Pro
Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S.
Justice” the Co-Defendant(s) “Joyce M. Guy” and Edward McCray herein collectively
having already “squander” all of the entire Hurricane repair funds for her own
mother home as a direct result of Hurricane “Rita” storm damages which
“Hurricane
“Rita” was the fourth-most intense Atlantic hurricane ever recorded and the
most intense tropical cyclone ever observed in the Gulf of Mexico, which on
September 24th 2005 the inner core and eye wall of “Hurricane Rita
slams into Port Arthur, Texas
Which
the Pro Se Plaintiff will show the Honorable Court” factual evidence during the
Trial of this matter of being the direct “construction contractor” whom was
contacted to fix,
And Pro Se Plaintiff “Louis Charles Hamilton
II” herein did in factual circumstances provide estimates of repair cost for
said damaged Home located at 5050 east 7th street in Port Arthur
Texas which Co-Defendant “Joyce M. Guy” submitted said estimates to a unknown
at this time “private home owner insurances company”,
And
received funding base upon Pro Se Plaintiff herein construction damages in
connection in needed cost estimates for said property located at 5050 east 7th
street in Port Arthur Texas 77640.
Thereafter
Pro Se Plaintiff herein returning to his home town of “Port Arthur Texas from
working “needed (ASAP) construction repairs” after massive storm damages in New
Orleans LA as a result of Hurricane “Katrina”.
21.
Pro
Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S.
Justice” was extremely concern for especially among other things fixing the
(asap) needed roofing repairs of 5050 east 7th street in Port Arthur
Texas which Co-Defendant(s) “Joyce M. Guy” refusal to comply with the terms and
conditions of said
“Insurances repair Funds” to actually fix such
Hurricane damages other then Co-Defendant(s) “Joyce M. Guy” (RICO) scheming
plans to obtain said “private Insurances repair Funds” for her own personal
private gains.
Pro
Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S.
Justice” the Co-Defendant(s) “Joyce M. Guy” herein after squandering all of the
said “private insurance” Hurricane repair funds designated for damaged
“property” located at 5050 east 7th street in Port Arthur Texas.
“Lot number (10) in block number (4) of
Lakeview “she” next contacting Federal
“FEMA” for needed roofing plastic covering to stop the rain water, and
never fixed the damaged roof at all ever.
And
just use the Pro Se Plaintiff Construction Contract as a device to execute this
Fraud upon the Private Insurance Company, as well as to execute the same scheme
of things against the Pro Se Plaintiff, in not having the Contract honored, for
Pro Se Plaintiff Construction Company profits derive thereof,
Which
all of the Co-Defendant “Joyce M. Guy”, device, instrument, events, and circumstances
was to achieve monetary fraud from the Private Insurance Company and making the
Pro Se Plaintiff “Louis Charles Hamilton II” herein an unwilling party, and
victim thereof at this first stage of this (RICO) enterprise involving Pro Se
Plaintiff.
22.
Pro
Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S.
Justice” Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar
No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively
secondly secretly make plans, scheme, precise calculations and plotted to carry
out a further
(RICO) scheme of things against “first and
foremost” the 58th Judicial District Court of Jefferson County Texas
in the scheme execution of covering up all of the Co-Defendant “Joyce M. Guy”
Monetary scheme already made against the
Hurricane repair “private insurance funds” designated for said damaged
“property” located at 5050 east 7th street in Port Arthur Texas.
“Lot number (10) in block number (4) of Lakeview
Which
this was “Fraud upon the 58th Judicial District Court of Jefferson
County Texas being executed on August 28th, 2009 before the
Honorable Bob Wortham, His Court, and all Court officers involved,
To
which at this time frame said Chief Defendant Antoine L. Freeman J. D.
(Attorney at Law) Texas Bar No. 24058299 herein being in quite factual legal denial
of even being the actual “attorney of record” or ever being a physical
representative party present at said “Court hearing” August 28th,
2009
To
which Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 herein actually in court documentations claiming “among other things”
in his legal services ended clearly there after filing a “General Denial” on
18th
day of December 2007 for the behalf of said Co-Defendant(s) “Joyce M. Guy and
Edward McCray” collectively herein as already legally described in Pro Se
Plaintiff exhibit (B) on file with the U.S. Clerk office namely
“Response
to Plaintiff’s Motion for Sanctions by: Attorney of record Antoine L. Freeman,
J. D. Texas Bar. No. 240582993723
23.
Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S.
Justice” Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) and
Co-Defendant(s)
“Joyce M. Guy” and Edward McCray” collectively herein having continue
advancement further to collectively secretly make plans, and plotted to “secondly”
carry out a further (RICO) fraudulent “scheme of things” 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”
24.
As
being described in Pro Se Plaintiff exhibit (P) already 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 Private Insurances Monies already being a
part of a continue (RICO) “pattern and practice squander scheme of things”
committed by Co-Defendant(s) “Joyce M. Guy and Edward McCray”
Involving
once again the Pro Se Plaintiff Louis Charles Hamilton II herein as the
Construction contractor 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 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) scheme of things at this stage being
formed against the Pro Se Plaintiff, private insurances companies, and among
others parties namely “The United States of America” for a monetary lost in
excess of $54,839.31 U.S. Dollars
While
Chief Defendant being still already acting “live” attorney of record in civil
suit A-180805 filed November 26th 2007 involvement with Pro Se
Plaintiff Louis Charles Hamilton II herein while engaging in this (RICO) scheme
of things secretly at the same time of a ongoing civil suit
Notwithstanding
executing this Monetary Fraud against the Pro Se Plaintiff, Private Insurances
company to include against The 58th Judicial District Court of
Jefferson County Texas,
And
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.
All
fraudulent (RICO) enterprise activities being wrongfully and secretly advance
throughout the “United States Mailing System, the Jefferson County Civil Court
records, and transcripts derive thereof for docket No. A-180805
25.
Pro
Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S.
Justice” Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar
No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively
secondly secretly make plans, scheme, precise calculations and plotted to carry
out a further
(RICO) scheme of things in obtaining in excess
of $72,500.00 U.S Dollars from namely
“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
In
connection with the property located at 448 DeQueen Blvd. in Port Arthur Texas
77640
As
being described in Pro Se Plaintiff exhibit (Q) already on file with the “U.S.
Clerk office
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” in monetary excess gain of $127,339.31 U.S. Dollars
Collectively
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;
And
collectively Being directly in violation of Title
18 U.S.C. § 1341, 1343 and 1349 “Mail and Wire Fraud”,
And section
1028(relating to fraud and related activity in connection with identification
documents),
And Section
1503(relating to obstruction of justice), Violations
of Chapter 96 of Title 18, United State Code:
26.
Pro
Se Plaintiff being further set forth Declares,
Affirm, and State further before the “Honorable U.S. Justice” Chief 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
“Knowingly
and willfully” engaged in skill (RICO) enterprise “pattern and practices” – to falsifies,
conceals, and used covered up tricks, scheme, and device against material facts;
with many materially false, fictitious, and fraudulent statement, concealment,
destruction of evidence, and representation in which
Under leadership of “Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299” herein and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein conspire, plot, engage and execute the uses of each and every false writing or documents knowing the same to contain materially false, fictitious, and fraudulent statement or entry;
All
of which “Knowingly and willfully” engaged and executed Against said unknown at
this time “Private Insurance Companies”, against the Pro Se Plaintiff “Louis
Charles Hamilton II herein civil suit in common law Docket No. A-180805 and all
records derive thereof and against all such damages derive thereof,
27.
To include “Chief Defendant Antoine L. Freeman
J. D. (Attorney at Law) Texas Bar No. 24058299” herein and Co-Defendant(s)
“Joyce M. Guy” and Edward McCray” collectively herein directly direct, conspire,
plot, engage and execute the uses of each
and every
“Knowingly
and willfully” skill (RICO) enterprise “pattern and practices” for monetary gain
– to falsifies, conceals, and used
covered up tricks, scheme, device, fictitious, and fraudulent statements,
concealment, destruction of evidence,
And
fraudulent instrument during the course of representation, false writing or
documents knowing the same to contain materially false, fictitious, and fraudulent
statement or entry;
Against
all Jefferson County Texas Public records, against all of the 58th
Judicial District Court of Jefferson County Texas,
Against
all of The United States Department of Housing and Urban Development records,
And against all of the “Texas Department of
Housing and Community affairs” records.
28.
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
further continue on forward in there
(RICO)
“Scheme of things” involved in “obstruction of justice inorder to further
engage collectively concealing, obscuring, masking, cloak and shielding corrupted
fraudulent “mutable fraudulent business” enterprise operations the Co-Defendant(s)
“Joyce M. Guy” and Edward McCray” herein concoct, share, execute and obtaining
massive hidden (RICO) enterprise income over many past years starting since
1997 described as follows:
A. Assumed name business “G & G
Services” a fraudulent Medical services for obtain “monetary payments” from “Senior
Aging Handicap Citizens within Jefferson County Texas which “G & G
Services” was never even a litigable Licenses with the State of Texas from May
2nd 1997- 2010 as being order shut down as described in Pro Se
Plaintiff exhibit (F) already on file with the U.S. Clerk office 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 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” while actually engaging in (RICO) enterprise in “money laundering” in
scrap metal materials” in connection 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 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.
29.
Which Pro Se Plaintiff being further
set forth Declares, Affirm, and State further
before the “Honorable U.S. Justice” Chief 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 continue to engage in among other things (RICO)
“obstruction of Justice” collaboration, racket, trick and
Plot in their collective (RICO)
“defense” in the direct refusal to produce among other things said 58th
Judicial District “Court Order” for discovery of the “property deeds”, of
448Dequeen Blvd. in Port Arthur Texas and all records involved in Hurricane
“Rita,
Humberto, and Ike, in connection with the
dwelling located at 448 DeQueen Blvd. in Port Arthur Texas as of this
undersigned date in 2015.
And ruse, dodge, concealing, withholding,
destroying, masking, obscuring all past, property deeds, banking records,
contractor(s) construction insurances estimates and contract(s) for (5)-(6)
hurricane storm damages claims, homeowner private insurance records, for
properties located at 5050 east 7th street in Port Arthur Texas
77640,
And for properties located at 448 DeQueen
Blvd. in Port Arthur Texas to include but not limited to from the exact time
frame of 1997-2015
Ruse, dodge, concealing, withholding,
destroying, masking, obscuring all past FEMA records, (4)-(6) mutable private
illegal business company records, personal banking records, business banking
records, Texas Department of Housing and Community Affairs housing records,
State Tax Records,
Sales Tax records, (IRS) Tax Records,
court records, and any and all documents relating to any discovery into the
corrupted (RICO) enterprise endeavor of the Chief 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.
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