Thursday, February 12, 2015

Amend U.S. Civil Complaint Louis Charles Hamilton II vs. Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 et al


                                           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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