33.
To
include but not limited to 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 herein fully conscious with intent
direct, leadership, conspire, collaborated with the
Co-Defendant(s)
collectively herein to fully violated Pro Se Plaintiff both Federal and State
citizenship “Civil Rights” of the 7th Amendment of the United States
and civil rights to due process derive thereof in said civil suit in common law
Namely
in among other things Due Process of the law and the 7th Amendment
Equal Protection within the State of Texas laws in equally title Pro Se
Plaintiff having fair, just secure protection of a civil suit before the 58th
Judicial District Court of Jefferson County Texas, appearing before the
Honorable Bob Wortham” in docket No. A-180805
Which Chief Defendant Antoine L. Freeman J. D.
(Attorney at Law) Texas Bar No. 24058299 herein fully conscious with full intent
direct his legal (RICO) enterprise fraudulent assault against said 58th
Honorable Judicial District Court of Texas to criminally derail, conceal,
contain, obstruct , and institute a denial due process of the law against
Pro
Se Plaintiff said civil suit in common law for a total (RICO) combine pattern
and practice “scheme of things” against the “United States of America” in
monetary excess gain of $127,339.31 fully tax free and being a (2) Housing
grant sham of American U.S. Dollars scheme, plotting, and conspiring in making
the Pro Se Plaintiff herein an unwilling party thereof, and victim thereof of actual
assault, for said scheme, sham in monetary excess of $127,339.31 in connection
with said assault at the Property located at 448 DeQueen Blvd in Port Arthur
Texas
With
actual damages wrongfully directed at the Pro Se Plaintiff suffrage in excess of
$336,000.00 U.S. Dollars loss earning and earnings capacity and loss in Pro Se
Plaintiff “personal property” in construction company tools, in excess of
$3,800.00 lost being a part of this complex, half bake, and (RICO) endeavor
From the time frame of December 17th
2007-date of injury throughout December of 2015 as this well complex real-estate
(RICO) scheme of things is ongoing and have financial maturity in 2015. With the Co-Defendant(s) “Joyce M. Guy and
Edward McCray” (RICO) racket assault” against the “United States of America”,
dating well back to the exact year of 1997 in the first business “G & G
Services” fraudulent scheme of things against elderly seniors for over a period
of 13 years throughout 2010. “Under radar, and uncheck…
Pro Se Plaintiff herein “States”, “Affirm”
and “Declare” further before the “Honorable Justice” at this time frame Chief
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 was
fully aware of the “Texas Department of Aging and Disability Services shutting
down said “Illegal medical business” and Pro Se Plaintiff instituted such a
State of Texas investigation into
“G and G Service Company” until a real
HCSSA license is obtains with the State of Texas which Chief Defendant Antoine
L. Freeman J. D. “Attorney at Law” understood directly Pro Se Plaintiff himself
being the direct cause for “Illegal medical business” G and G Service Company
being closed against Co-Defendant(s) while this civil suit was ongoing in the
58th Judicial District Court of Jefferson County Texas
34.
With
Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 herein fully conscious with further premeditated intent, plans,
direction, scheme and conspire herein his part in a (RICO) enterprise retain payments
to work as legally off the books to legally fraudulently in the capacity as a
Professional
attorney of law impose aid, hinder, conceal, obstruct, hide, destroy, ruse,
cover up, fake and fool innocent Justice and contain not only Pro Se Plaintiff
civil suit docket No. A-180805 but to include
The Chief Defendant Antoine L. Freeman J. D.
(Attorney at Law) Texas Bar No. 24058299 herein also handsomely fully paid,
retain, and directed to hinder, conceal, obstruct, hide, destroy, ruse, cover
up, fake and make a fool of all of Pro Se Plaintiff discovery, and search into
the truth in all such
Co-Defendant(s)
“Joyce M. Guy and Edward McCray” described mutable past, present and future (RICO)
enterprise “monetary racket assault” against, private insurances companies,
private construction contractors, the State of Texas and the “United States of
America”, dating back to the exact time frame firstly in the year of 1997
Starting in the business namely “G & G
Services” another fraudulent monetary massive medical business scheme of things
against elderly seniors for over (13) years in “hidden monetary assets gains” throughout
2010 committed to within Jefferson County Texas.
As already being legally described in Pro Se
Plaintiff exhibit (E) and (F) on file with the U.S. Clerk office in the file
before the Honorable U.S. Justice “Magistrate”.
35.
To
include but not limited to 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 herein fully conscious with willful intent
direction, leadership, conspire, collaborated with the Co-Defendant(s) “Joyce
M. Guy and Edward McCray collectively herein
And fully paid, retain, and directed to
hinder, conceal, obstruct, hide, destroy, ruse, cover up, fake and make a fool
of Pro Se Plaintiff civil rights to Constitution Laws of the State of Texas namely
Article
16: “General Provisions” Section 37 provides for constitutional protection of
the “mechanic’s lien” against Co-Defendant(s) “Joyce M. Guy and Edward McCray”
collectively herein
Which
Defendant and Co-Defendant(s) collectively in furtherance’s (RICO) enterprise execute
efforts, conspire, hinder, obstruct, and full derailment of Pro Se Plaintiff
civil rights to Constitution Laws of the
State of Texas namely
Article
16: “General Provisions” Section (50) provides for protection of homestead
against force sales to pay debts, except for foreclosure on debts related to
the homestead (mortgage, taxes, mechanic’s liens, and home equity loans).
In connection with the property located at 448
DeQueen Blvd. in Port Arthur Texas being a direct party to said civil suit in
common law for breach of construction contract and actual fraud derive thereof.
36.
Chief Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299
Fully Committed to among other things Conspiracies together to pursue the same
Criminal (RICO) “Racketeer Influenced and Corrupt Organizations Act”, of
said Co-Defendant(s) “Joyce M. Guy and Edward McCray” in the execution, and direct usage of
“Obstruction of Justice”
in the capacity as an “Officer of the Court” and “Attorney of Law” for the
State of Texas to commit and conspire to the same causes of all (RICO) enterprise
past, present and future “acts and actions” in concert with the Co-Defendant(s) “Joyce M.
Guy” and “Edward McCray” collectively herein
Fully described herein such acts and actions
being unjust against the Pro Se Plaintiff,
While Chief Defendant Antoine L. Freeman J. D. Attorney at
Law Texas Bar No. 24058299 herein further willfully Omitting,
concealment, containment, obstruction and Destruction thereof “Material Civil
Evidences and all Material Subject Matter Facts” on its way presented before a
ongoing “Civil Suit” in Common Law in Jefferson County Texas 58th
Judicial District
With “among other
things” Chief 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 private capacity as a
“Independent Construction Contractor”
With “among other
things” 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 conspire, cover up, of Actual events of Fraud
of Insurance Companies”, for primary fraud
during “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm
damages, in connection with the Pro Se Plaintiff Louis Charles Hamilton II
herein.
37.
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 cleverly crafty abusing his
“attorney/client privileges, all work doctrine documents derive thereof;
And all known communications between
“Attorney and Client”
Namely Chief Defendant Antoine L.
Freeman J. D. and Co-Defendant(s) “Joyce Guy and Edward McCray” herein to “Grand
style” deceive the “Honorable 58th Judicial District Court” from
having any “Legal Knowledge Via Pro Se Plaintiff herein “direct discovery
request” and all “Investigation” derive
thereof fully focus on among other things Co-Defendant(s) “Joyce Guy and Edward
McCray”
Collectively in the past did in fact submit
numerous Hurricane disaster relief damages claims being in the form of
construction contractor’s estimates with the Pro Se Plaintiff being a party to
(2) such estimates to their “Insurance Companies” and possibly FEMA for relief
of damages caused by Hurricanes Rita, Humberto, and Ike for the property
located at 448 DeQueen blvd. in Port Arthur, Texas.
To include also for Property located
at 5050 east 7th Street in Port Arthur Texas, and Property Located
at Blk 4 Lot. 10 Lake View in Jefferson County Texas all own and in the
possession, custody, and control of the Co-Defendant(s)
As Pro Se Plaintiff making claims before the
58th Judicial District Honorable Court of Co-Defendant(s) “Joyce Guy
and Edward McCray” past fraudulent “practice and patterns” thereof.
38.
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 herein also having “insider
information and communications” with Co-Defendant(s) “Joyce Guy and Edward
McCray” conspire further with “obstruction of Justice” to continue to commit to
conceal this
“Material evidence” that
Co-Defendant(s) “Joyce Guy and Edward McCray” was in fact in the legal process
of having the old Home torn down while the ongoing civil actions was still
pending before the 58th District Court of Jefferson County Texas to
include Co-Defendant(s) “Joyce Guy and Edward McCray”
Collectively having a “New Home” secretly being built at the cost of
$72,500.00 U.S. Dollars on a “Federal Grant” kept 100% secret from the Pro Se
Plaintiff Discovery and The State Court while this Civil Suit in common Law had
commence in 2007 as was well ongoing out of control at this point under
(RICO).
As Chief Defendant himself Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein confirm and
described in Pro Se Plaintiff First Set of “Interrogatories” the “Texas
Department of Housing & Community Affairs” issuance of a “Housing Grant” in
favor for the Co- Defendant(s) “Joyce Guy and Edward McCray” all of which in
fact fraudulently obtain being in fact a “Federal Housing Grant” on the behalf
of “Texas Department of Housing & Community Affairs”
39.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Co-Defendant(s)
collectively herein making further fraudulent claims before said “Texas
Department of Housing & Community Affairs” that Pro Se Plaintiff was the
primary cause of damages to the old home derive thereof for Co- Defendant(s)
“Joyce Guy and Edward McCray” needing a “New
Home” based upon poor, Unsatisfactory contractor “workmanships” and
“craftsmanship” being committed by Pro Se Plaintiff Louis Charles Hamilton II
herein for the $10,800.00 U.S. Dollars Contract already sub-mitted to previous
“Insurance Company” by Co-Defendant(s) in regards to Hurricane Humberto storm
related damages.
40.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Co-Defendant(s)
collectively herein usage of this same (RICO) enterprise fraudulent tactic,
scheme, sham, plot and plans premeditated being done to the Pro Se Plaintiff
against other innocent independent construction contractors and
Private homeowner insurances companies
to obtain other mutable fraudulent monetary assets after storm damages of
Hurricane Rita, Humberto and Ike to the said property(s) located at 448 DeQueen
Blvd. in Port Arthur Texas 77640 and 5050 east 7th street in Port
Arthur Texas 77640
41.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Co-Defendant “Joyce
Guy and Edward McCray” secretly filed on June 18th 2009 Fraudulent
“Financing Statement” at the Jefferson County Clerk Office File #2009022763
To obtain from “Texas Department of Housing
& Community Affairs” $72,500.00 on a “Federal Grant” as the secretly destruction
of the older home took place during this ongoing “Civil Suit”
42.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Chief Defendant Antoine
L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 having full knowledge
of all this transfer of the Home, and the destruction of the older one and all
circumstance involved thereof being secretly conspire further fraudulently in
the capacitates of a “Attorney at Law” with the Co-Defendant(s) “Joyce M. Guy
and Edward McCray” herein
To achieve the same fraudulently
(RICO) enterprise monetary objective(s) gain being $72,500.00 “New Home” on a “Federal
Grant” shamefully submitted Before the “Texas Department of Housing &
Community Affairs” by Co-Defendant(s) after already “Greedy Squandering” all of
the Numerous Insurance Funding” from each previously Hurricane “Rita”,
“Humberto”, and “IKE” related storm damages on the dwelling located at 448
DeQueen Blvd. in Port Arthur Texas.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Chief Defendant Antoine
L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein had a fiduciary
duty to disclose all material facts as described herein and regardless of his
“Attorney/Client defense of the Co-Defendant(s)
Chief Defendant Antoine L. Freeman J.
D. Attorney at Law Texas Bar No. 24058299 was obligated to conform with the
Texas Rules of Civil procedures in said Discovery phase of a Civil Suit in
common law within the State of Texas
Regardless of it criminal/civil fall
out affect being properly in placement upon the Co-Defendant “Joyce M. Guy and
Edward McCray numerous fraudulent acts and actions discovery of a shocking
further investigation involving “among other things” the actual designed “Fraud
of Contractors” related to “Insurance Company” Scams and scheme of things the
Co-Defendant(s) monetary calculated and concocted during Hurricane “Rita”,
“Ike” and “Humberto”.
43.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine
L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 at no time did the
Defendant file any notice with the court from the time frame of December 18th
of 2007 throughout December 11th 2009 request for “Motion For
Withdrawal of Counsel” exactly 7 days shy of two years
Defendant Antoine L. Freeman J. D. Attorney at
Law Texas Bar No. 24058299 was retain to commit to numerous fraudulent acts and
actions involving withholding all discovery material during this entire (2)
year time frame and shield all of Co-Defendant(s) mutable fraudulent indiscretions
of Corrupted Illegal (RICO) Business dealing within Jefferson County Texas
being instituted by the Co-Defendant(s) .
44.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Special Exclusive
in-depth Investigation into the Co- Defendant(s) “Joyce Guy and Edward McCray”
further reveal J Can Company 1807 East 7th Street Port Arthur Texas (Office)
located at 448 DeQueen Blvd. in Port Arthur Texas 77640 being owned by the
Defendant(s) “Joyce Guy and Edward McCray”, assumed name filed on April 11th
2008 Jefferson County Clerk records #72594
1807 East 7th street in
Port Arthur Texas is actually a “Vacant Lot” which has been raided by the PAPD
Dept. (Police) several times for engaging in “illegal Scrap Industry”
“Moreover” once all “Illegal Scrap
Metal” other then used Cans being recycle and obtain in the City of Port Arthur
Texas city limits by Co-Defendant “Edward McCray”, by the business J Can
Company being now introduced as “Scrap Metal” in connection with “Cars and
Pieces” business Located in Beaumont Texas (Office) also located at 448 DeQueen
Blvd. in Port Arthur Texas 77640
Making the final “Legal sales” of all
“illegal scrap” obtain in the City of Port Arthur Texas city limits by
Defendant “Edward McCray”,
“Moreover” Pro Se Plaintiff Louis Charles
Hamilton II herein (Fully) quite “elementary sure and certain” after prior raid
by the (PAPD) Police into “illegal scrap” of J Can Company that this “many
years of “baffling exchange” transfer rate of
“Illegal scrap” from Port Arthur Texas City Limits has been
confusing the (PAPD) Police in the exchange rate form now “legal scrap” derived
in “Beaumont Texas” from J Can Company “Namely”, “Cars and Pieces” business in
Beaumont Texas being now major illegal scrap metal “money laundering” “Earn
Income” system for Co-Defendant (Edward McCray) derived from this “criminal
endeavor.
To include but not limited to, upon
information, belief and personally witness Co-Defendant “Edward McCray” usage
of “Vacant Lot” being J Can Company to secretly continue engaging in the sales
of a “Crack Cocaine Industry”.
45.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Chief Defendants
Antoine L. Freeman, J.D. “Attorney at Law” herein at the very start clearly in
December 18th of 2007 was
engaging in Professional Skills of a Attorney at Law” in a “Legal” ongoing
court room obligations to defend this civil case A-180805 against Pro Se
Plaintiff
Chief Defendant (Attorney at Law)
herein committed to Fraud upon the 58th Judicial District Court
claiming in a documents filed by “Chief Defendant his only legal job was to
draft a (Simple) General denial on behalf of the Co- Defendants “Joyce M. Guy
and Edward McCray which was filed on December 18th 2007, as such to
avoid a default on behalf of Co-Defendant(s) collectively by filing his “Chief
Defendant (Attorney at Law)”
Original Answer and at that point his
“Fiduciary Duty” to his clients Co-Defendant(s) “Joyce M. Guy and Edward McCray
and before the 58th Judicial District Court ended on that date
December 18th 2007 thereafter and was legally completely over,
Which Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” this is
not the case at hand as chief Defendant (Attorney at Law) herein Fully scuttles,
hidden, obscured, and conspire in the
destruction all discovery materials and
material evidence received from Plaintiff in this civil matter from
December 18th 2007-
November 13th 2009 being the official day clients Co-Defendant(s)
“Joyce M. Guy and Edward McCray and Chief Defendant Antoine
L. Freeman J. D. (Attorney at Law) (Active) in and for the State of Texas Bar
No. 24058299 fully in possession, custody, control, and combine
knowledge thereof
Pro Plaintiff request for production of
Documents, Interrogatories, and request for admission and to disclose Pursuant
to Rule 194 during the entire year of 2008-2009 Chief Defendant Antoine L.
Freeman, J.D. “Attorney at Law” herein fail well above and beyond (30) days of
this request, for the discovery information or material described by a period
of over (2) years past the (30) days requirement to answer not only Pro Se
Plaintiff “Request to Disclose” Pursuant to Rule 194,
Chief Defendant (Attorney at Law) was
also served Pursuant to Rule 198 of the Texas Rules of Civil Procedure
Plaintiff Request for Admission(s) and Pursuant to Rule 197 of the Texas Rules
of Civil Procedure Pro Se Plaintiff Set of Interrogatories all of which
required a reply within (30) days of these request as Chief Defendant a skilled
(Attorney at Law)
Having such full knowledge that a discovery
phase process had commence in this civil legal matter and simply (RICO)
monetary retain to 100% refusal to submit any “response or reply” to all said
required discovery request for a period exceeding (1) year and (11) Months and
Pro Se Plaintiff Filed “Motion for sanctions” against said Chief Defendant
(Attorney at Law) in violation of Rule 193.1 of the Texas Rules of Civil
Procedure.
46.
Chief Defendant (Attorney at Law) in
his defense of Pro Se Plaintiff motion for Sanctions committed to the Following
further Fraudulent activities upon the 58th Judicial District Court
of Jefferson County Texas and all court records derive thereof.
a.
Engage in having Co-Defendant “Joyce M. Guy”
Subscribed and Sworn a fraudulent Affidavit in Support of Chief Defendant
(Attorney at Law) dated September 11, 2009
b.
File a Response to Plaintiff’s Motion For
Sanctions also committed to the same act of having this fraudulent document
“Subscribed and Sworn on the 11th day of September 2009
c.
Submitted all fact therein as being true
before a Court of Law knowing this to be 100% false and fraudulent describing
event of April 2nd, 2008 and April 11th, 2008 in
connection with Pro Se Plaintiff discovery request.
47.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Affidavit of
Co-Defendant “Joyce M. Guy” admit Chief Defendant (Attorney at Law) fraudulent informed
Co-Defendant(Guy) between April 2nd, 2008 and April 11th,
2008 about Pro Se Plaintiff “Discovery Request” providing proof that Chief Defendant
(Attorney at Law) was in fact in possession, custody, and control of said
discovery request while representing to the “Honorable Court” this was not the
case when said legal possession, custody, and control commenced March 14th
2008.
48.
Chief Defendant (Attorney at Law)
herein did not file any notice with the Pro Se Plaintiff or the District Court
of Jefferson County Texas that he was not representing the legal interest of
the Co-Defendant(s) “Joyce Guy and Edward McCray”, there after
filing “the original answer” with the
58th Judicial District
Court back in December 18th of 2007 when Chief Defendant (Attorney
at Law) herein in fact fraudulent stating having Pro Se Plaintiff Discovery in
Chief Defendant own Affidavit being in
his possession, custody and legal control as of April 2nd, 2008 and
April 11th, 2008.
49.
Pro Se Plaintiff herein “States”, “Affirm” and
“Declare” further before the “Honorable Justice” Chief Defendant (Attorney at
Law) herein stated to the Honorable 58th Judicial District Court
also, that his only duty was to file a original general denial (only) and this
was what his “Legal” services as a Attorney in this matter was only retain for
in his defense for Sanctions against him as described herein this complaint.,”
“However” Pro Se Plaintiff States”,
“Affirm” and “Declare” and further maintain that Chief Defendant Antoine L.
Freeman J. D. “Attorney at Law” Texas Bar No. 24058299 did in fact make a court
appearance in a hearing the Pro Se “set” before the Honorable 58th
District Court on the 28th day of August 2008
Pro Se Plaintiff also filed a (TRO)
“Temporary Restraining Order” in this same civil matter A-180805 against
Co-Defendant “Joyce M. Guy” to protect her own “Mother” Norma Guy, and the
resident living in that dwelling whom Co-Defendant (Guy) having “Power of
Attorney” Over her Mother Legal Affairs, filed in Jefferson County #2010042042
at which during this same time frame Co-Defendant (Guy) having process the same
(RICO) enterprise “scheme and scam” of
things regarding Private Insurance, Construction Contract estimates and
contracts of the Pro Se Plaintiff herein, FEMA roofing repair funds, and all fraudulent
scheme against the property located at 5050 East 7th street in Port
Arthur Texas being Norma Guy Home Mother of the Co-Defendant (Joyce M. Guy)
whom Norma Guy is dead now and Co-Defendant “Joyce M Guy and Edward McCray”
collectively in 2015 time frame having direct legal possession, custody and
control over (2) real-estate sham in excess of $127,339.31 involving the Pro Se
Plaintiff as a unwilling party and victim thereof.
50.
Chief Defendant (Attorney at Law) Antoine
L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein physically argued
this issue of a (TRO) alone before the Honorable Judge Bob Wortham, and the 58th
Judicial District Court of Jefferson County Texas on August 28th
2009
And Chief Defendant (Attorney at Law) Antoine
L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein also foolishly
claiming in Court document(s) filed with the U.S. Clerk office as exhibit (B) and
presently in the records and files before the U.S. Justice Magistrate that he said
Chief Defendant (Attorney at Law) herein was never even present there at said
hearing or physically being the acting Attorney of record on said hearing date
of August 28th 2009 before the 58th Judicial District
Court of Jefferson County Texas
While at this time frame of hearing
date August 28th 2009 at no time was Chief Defendant herein not
acting in the capacity as “Attorney of Record” at said August 28th
2009 hearing date to include but not limited to from the time of filing of his
notice of counsel and original answer on December 18th 2007 until Chief
Defendant (Attorney at Law) filed a Motion to withdraw as Attorney of Record in
November of 2009.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Chief Defendant
(Attorney at Law) herein sat on Pro Se Plaintiff entire Discovery Request in
excess of 16 Months and refuse to file a timely reply, or file any type motion
for withdrawal notice with the 58th Judicial District Court during
this 16 Months time period while Texas Rules of Civil Procedure require he so
do which all of this was to advance such (RICO) enterprise endeavor as
Chief Defendant a professional Attorney
at Law required to Adhere to local rules of the Texas Court System and reply
within (30) days later not on a time table of (16) months later after mailing service
of Said Discovery request by Pro Se Plaintiff Louis Charles Hamilton II on
March 14th 2008.
51.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Chief Defendant
(Attorney at Law) herein, further then took a even bolder set in “Obstruction
of Justice” in that after in excess of (16) months of scuttling Pro Se
Plaintiff Discovery request to further aid, obscure, conceal, and Hide all of
the corruption going on at present time frame engaged further in the direct
Destruction of the old home being
physical evidence in civil suit in common law and the new one being built,
secretly during this ongoing Civil Suit and all of the inquiries being made by
the Pro Se Plaintiff regarding Fraud relating to Insurance Companies, Former
Contractors, and Hurricane “Rita”, “Ike” and “Humberto”.
Chief Defendant (Attorney at Law)
herein conspire with Co-Defendant(s) “Joyce M. Guy” and Edward McCray to
provided further Fraud upon the 58th Judicial District Court in
Fraudulent Information in the Interrogatories claims against the Pro Se
Plaintiff construction tools and being in possession theft of personal thereof,
and Never Investigated the circumstances of the questions being raised
surrounding the “Theft” of The Pro Se Plaintiff Construction Tools by the
Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”,
Chief Defendant (Attorney at Law) completely
cover up the Co-Defendant(s) collective wrong doings from the Honorable Court
per Pro Se Plaintiff Discovery Request being scuttled for (16) months time
frame as being described in this Amend Complaint.
52.
Chief Defendant (Attorney at Law) made as if
no Construction tools where ever on the property of the Pro Se Plaintiff being
complain of
To include Defendant (Attorney at Law) supply
false answer(s) in the same Interrogatories that the Co-Defendant “Edward
McCray” never even meeting the Pro Se Plaintiff Step Father (Lewis Garza) whom
actually help delivery all of Pro Se Plaintiff said in excess of
$3000.00 U.S. Dollars in construction tools to
the dwelling in his Truck to the Home of The Co-Defendant(s) “Joyce M. Guy” and
“Edward McCray” on November 16th 2007. Defendant (Attorney at Law)
did not Investigate any of these facts nor was he ever even concern to attempt
to investigate into the issues of the were about of Pro Se Plaintiff
Construction tools.
53.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” after Chief Defendant
(Attorney at Law) was officially no longer “Attorney of record” of the Civil
action in Texas State Court from the time frame of December 18th
2007 – filing General Denial to November 13th 2009 when Chief Defendant
(Attorney at Law) herein filed with the Clerk of Court of Jefferson County
Texas a Motion for Withdrawal of Counsel
The Co-Defendant “Joyce M. Guy and
Edward McCray” continue to refuse to turn over said “Discovery Request” of the
Pro Se Plaintiff thereafter
To the point a Court Order of the 58th
Judicial District Court was obtain and enforced as Follows:
54.
Ordered that Co-Defendants “Joyce Guy
and Edward McCray” shall produce copies of deeds, property deeds or any other
such physical document in Defendants possession, custody or control that shows
actual ownership of the property of the dwelling located at 448 DeQueen Blvd.,
Port Arthur, Texas
55.
Ordered that Co-Defendants “Joyce Guy
and Edward McCray” shall produce copies of any and all construction estimates
for repairs in Defendants’ possession, custody or control in relationship to
the damages caused by Hurricanes Rita, Humberto and Ike to the Property located
at 448 DeQueen Blvd. in Port Arthur, Texas.
As so Ordered on the 10th
day of May 2010 by the 58th Judicial District Court of Jefferson
County Texas filed at 11:46 am.
56.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” that
Co-Defendants “Joyce Guy and Edward McCray” remain in Hostile abscond scuttle
refusal of the Honorable 58th Judicial District Court Order as of
the undersigned date in the Month of February 2015 of this Amend Complaint
being refilled in U.S. District Court.
57.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” because of
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299
acting in his skilled profession to fraud the court and belittle the Pro Se
Plaintiff and his discovery request for a period in excess of 16 months in
possession thereof
To include Chief Defendant (Attorney
at Law) herein unethical commitment to (RICO) enterprise conspires further
under the disguise of “Attorney/Client” privileges.
Work Product doctrine, and all Communications derive
thereof being secrete between the Chief Defendant (Attorney at Law) and the
Co-Defendant(s) “Joyce Guy and Edward McCray” collectively herein
To the point such Fraud committed by
the Chief Defendant (Attorney at Law) herein on the Jefferson County 58th
Judicial District Court in Texas completely forced the Pro Se Plaintiff to be
at an extreme “civil disadvantage” in the ongoing court proceeding in the time
frame of 2007-2009 and present in the time frame throughout 2015
Based solely upon Chief Defendant
(Attorney at Law) Rouge monetary retain (RICO) “obstruction of Justice” leadership,
direction among other things being fully a professional hire “Legal Gun”
knowledge thereof to scuttle, omit, delay, obstruct, destroy, concealment,
containment, and fraudulently mishandling required duties to supply a honest,
required respond to all of Pro Se Plaintiff discovery request in a timely
fashion, within the (16) months being in possession, custody and control of
said Pro Se Plaintiff Discovery request.
58.
Pro Se Plaintiff herein “States”, “Affirm” and
“Declare” further before the “Honorable Justice” Chief Defendant Antoine L.
Freeman J. D. Attorney at Law Texas Bar No. 24058299 retainer fees was solely
paid to keep the Co-Defendant(s) “Joyce M. Guy and Edward McCray” numerous
discover (RICO) enterprise fraud discovery by the Pro Se Plaintiff herein absolutely
100% top secret from the 58th Judicial Court”
While the other newer $72,500.00 U.S.
Dollars and the newer $54,839.31
“scheme of things” being in current
play and process to now a ongoing (RICO)
fraud monetary scheme of things the Co-Defendant(s) “Joyce M. Guy and Edward
McCray” concocted involving Fraud (Now) against The “Texas Department of
Housing & Community Affairs” issuance of a “Housing Grant” in favor for the
Co- Defendant(s) “Joyce Guy and Edward McCray”
All of which in fact being
fraudulently obtain from “Federal Housing Grant” on the behalf of “Texas
Department of Housing & Community Affairs” while the civil suit is “Live”
and pending” which Co-Defendant(s) collectively conspire to keep this under
wraps from any financial setback glitches being fully caused by The Pro Se
Plaintiff Louis Charles Hamilton II bring this additional Fraudulent activities
before The Honorable 58th Judicial District Court of Jefferson
County Texas well deserved attention.
59.
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” Chief Defendant Antoine
L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 in his History of being
a Skilled “Attorney at Law” in and for the State of Texas “Never” once scuttle,
hide and thereof flat out being in refusal in the filing of a “timely Discovery
request” for a period exceeding over (30) days against any Attorney, Law Firm
or other Pro Se (Litigant)
In comparison to the double dealing,
100% skilled rouge super late filing reply to Pro Se Plaintiff numerous
Discovery request being late in excess of (19) months and absolutely 100% in
full violation of Texas Rules of Civil Procedures 193.1
60.
All of which Pro Se Plaintiff herein
“States”, “Affirm” and “Declare” further before the “Honorable Justice” solely
done by Chief Defendant (Attorney at Law) (Only) to conspire in the illegal
(RICO) enterprise aid to hide, conceal, destroy, obstruct in concert of all of
the Co-Defendant(s) “Joy M. Guy” and “Edward McCray” many corrupted Business Enterprises
endeavors,
Mutable Counts of Fraudulent past,
present and future “pattern and practices” activities involving Hurricane
“Rita”, “Ike” and Humberto” with its Monetary rip off scams and schemes against
FEMA, Building Contractors estimate and invoices and Home Owner Insurances
Companies repair funds
Couple with the (Now) live ongoing new
2009 fraud activities of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray” concocted
directly involving “Federal Housing Grant” on the behalf of “Texas Department
of Housing & Community Affairs” in excess of $72,500.00 U.S. Dollars and
$54,839.31 U.S. Dollars for a combine total additional (RICO) enterprise sham
of in excess of $127,339.31 involving the Pro Se Plaintiff as a unwilling party
and victim thereof
Couple in providing with Pro Se
Plaintiff combines actual damages suffrage in excess of $336,000.00 U.S.
Dollars, lost earning and earning capacity, and $3,800 theft of personal
property (Construction tools) 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” ongoing (RICO) enterprise endeavor against the Pro Se Plaintiff Louis
Charles Hamilton II herein Civil Rights, Peace and dignity in excess of $467,139.31
U.S. Dollars
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