Sunday, February 15, 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


61.

Chief Defendant (Attorney at Law) herein known lying with a consciousness mind and disregard for the consequences for his actions in the “capacity as an Attorney of Law”, Antoine L. Freeman J. D. conspire to continue to use his legal lawyer skills” in the full “aid and abetting”, and commitment to “Obstruction of Justice” in the capacity of a

Attorney at Law forthwith in providing his own numerous Attorney fraud legal commitment documentations upon the 58th Judicial District of Court of Jefferson County Texas, the Court records thereof as being fully described in this U.S. District Court Amend Complaint of the Pro Se Plaintiff.

 And being in full criminal (RICO) enterprise concert, collusion, corruption and conspiracies thereof for all “monetary fraudulent assets gains” of the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” collectively herein being “ill-gotten pirate loot” from the “past” Hurricanes Seasons “Rita”, Ike” and “Humberto” and “present and future” pirate loot” of (2) “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs”

Awarding Federal Agency: “United States Department of Housing and Urban Development” in excess of $72,500.00 U.S. Dollars, and $54,839.31 of the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” (RICO) gradually acquisitions earning since past (RICO) enterprise endeavors as described since activated in such monetary corruption starting legally in 1997.

                                                62.

Fully affecting the Pro Se Plaintiff (Life) with “among other things” cause of action for “actual damages” being in excess of $336,000.00 U.S. Dollars in “lost wages” from 2007 – 2014 and lost profit in excess of $7000.00 of the $10,800 Breach of Construction contract, lost of profits in the sham & scheme against the property located at 448 Dequeen Blvd. in Port Arthur Texas


 With also “actual damages” in excess of “3093.00 U.S. Dollars causing lost wages and lost earning capacity in all of the Pro Se Plaintiff Construction tools: as described in “Original Complaint” filed in the 58th Judicial District Court of Jefferson County Texas Cause No. A-180805.

 
As showing the Construction Tools Listed as follows:

a.     Brand New Hitachi Air Compressor #2700009 $680.00

b.     Bosch Drill M# Brute S# NV $345.00

c.      “Portacable Skill saw $137.00

d.     Dewalt Sawall $97

e.     “Hitachi Nail Gun (Framing) $327.00

f.       “Hitachi Roofing Nailer $315.00

g.     Gas Power Generator $300.00

h.     Extension ladder $127.00

i.       100 ft. of air hose $95.

j.       50ft. of air hose $42.

k.     100ft. electric cord $70

l.       50ft. electric cord $38

m.  (4) Framing hammers $37. (each)

n.     “Pro Se Plaintiff “Personal Hammer” $48.

o.     “Leather tool belt” $50.

p.     Kobalt Razor Knife $17.

q.     Swanson pencil set & refills $22.

r.      “Black tool box & Respiratory $138.00

s.      “Extreme Safety Face Shield” $30

t.      Ear plugs (2) pack $16.

u.     (4) Normal face respirators with strap $12.

v.     Small assortment pliers set $35.

w.   (2) Tuck pointers $24.

x.     (1) Square mouth shovels $18.

y.     (1) set of blueprints $1200.00

z.      Gas container 15.

aa. Masonry trowel $18.

bb.            “Fatmax 35ft. tape measure $30.

cc.  Catspaw nail puller $12.

dd.            Speed square $8.

ee.             Contractor Calculator $34.

ff.    Crowbar $17.

gg. Utility knife (3) $9.  (Each)

hh.            Nail Punch $8.

ii.     Maxx Gloves $34.

jj.     Canvas Tarp 95ft. X 180ft. $100.00

kk. Roofing shovels (2) $48. (Each)

ll.     Saw blades with drill bits $24.

mm.       (2) Speed square (Plastic) $5.  (Each)

nn.            25ft. “Fatmaxx tape measure $19.00

oo.            3-way air hose fitting set $38.

pp.            Case of Gatorade $12.

qq.            Residential framing book $21.

rr.   (2) Paint brushes $14. (Each)

ss.  (1) Paint scraper $14.

tt.   (1) Paint scraper wire handle $10.

63.

Notwithstanding causing the Pro Se Plaintiff undue unwanted extreme hardship, infliction of emotional distress and anguish in the “Theft of Pro Se  Construction Profession” for a ongoing time frame over (7) years and still counting well into 2015

The Texas State Civil Suit is “Live” and ongoing due in large part to Chief Defendant (Attorney at Law) herein

Numerous (RICO) enterprise “acts and activities” to commit “among other things” a complete assault of “Obstruction of Justice” and “Fraud upon a Court” in the 58th Judicial District Court District of Jefferson County Texas

In a Suit in “Common Law” for the rouge disgrace benefit of his skilled profession as a “Attorney of Law” to skillfully cover up a Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” clients herein “Long Bogus Quite Profitable Crooked Road of “Fraudulent History” being described fully herein and direct against The civil rights, peace and dignity of the Pro Se Plaintiff herein. 

                                                64.

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 herein “facilitate” all of his own “Fraudulent Activities” upon the Pro Se Plaintiff civil suit and fraud of the 58th Judicial District Court of Jefferson County Texas for the full benefit of hiding the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”

 To include “among other things” numerous corruption activities with the usage of the fraudulent scheme of things in usage of the “United States Mailing System” to further long this fraudulent (RICO) enterprise “scheme of things” before a “Honorable 58th Judicial District Court of Law” within the State of Texas and further long this fraudulent (RICO) enterprise “scheme of things” against the State of Texas and The United States of America Housing grant program while all also being direct against the Pro Se Plaintiff Louis Charles Hamilton II as being described herein this amend complaint.

                                                65.

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 “facilitate” all of the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” described (RICO) enterprise past, present and future corruption(s) and fraudulent activities with the usage of among other things the “United States Mailing System” to further long this

 (RICO) enterprise fraudulent “scheme of things” before a “Honorable 58th Judicial District Court of Law” within the State of Texas and further long this “civil scheme” conspire 100% against the Pro Se Plaintiff “seventh” Amendment right of the Constitution of The United States of America and the State of Texas Constitutional rights as being fully described herein this amend complaint.

                                                66.

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 herein “facilitate” all of his own “Fraudulent Activities” and that he further conspire to and did in all facts and circumstances

 “Facilitate” provide concealment in court documentations, and evade Justice from the time frame of 2007-2015 for all of the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” described corruption(s) and “fraudulent activities” with the usage of the Jefferson County “Clerk of Court” Office Computer System, electronic records, and filing system thereof to further long this fraudulent “scheme of things”

 Before an “Honorable Court of Law” within the State of Texas and further long this “civil scheme” against the Pro Se Plaintiff civil rights in a suit in common law as being described herein this amend complaint.

                                                67.

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 fully “facilitate” and engage further in the usage of Extrinsic Fraud and tactics in the position as opposition counsel for the legal interest of Co-Defendant(s)
“Edward McCray and Joyce M. Guy” to stop, conceal and hinder, providing representation and presentation as acting attorney of record to cause Pro Se Plaintiff from rightfully not being involved in said discovery request, so Pro Se Plaintiff not being able to obtaining favorable evidence to use as a advantage to prosecute civilly against the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” in the civil suit in State Court docket No. A-180805.

                                                68.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” committed to defamation of the Pro Se Plaintiff as being a dishonest, unskilled, substandard Construction Contractor and Pro Se Plaintiff is the reasoning for the older home located at 448 DeQueen Blvd. in Port Arthur Texas being demolished for providing faulty contractor structural work and repairs being unskillfully provided by Pro Se Plaintiff herein in connection with the $10,800.00 U.S. Dollars “Breach of Construction Contract” issues still ongoing in 2015.

                                                69.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” used the defamation of the Pro Se Plaintiff substandard construction performance tactics with their previously Home Owner Insurance Company to satisfied any suspicion concerning the $10,800.00 dollars already wrongfully (RICO) enterprise squander by said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein.

To include Co –Defendant(s) “Joyce M. Guy and Edward McCray” herein used the same defamation of the Pro Se Plaintiff character against the “Texas Department of Housing & Community Affairs” claiming further Pro Se Plaintiff being a substandard contractor in construction performance by providing faulty contractor structural work and repairs skills to the dwelling of 448 DeQueen and Pro se Plaintiff being directly responsible for the need of destruction of the old dwelling thereof in Port Arthur Texas

 In order through this same wrongful scheme of defamation against the Pro Se Plaintiff contractor skills to obtain further a New Home with this (RICO) enterprise “scheme of things” being done directly against

“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 obtaining the already total of $72,500.00 U.S Dollars

 
As being described in Pro Se Plaintiff exhibit (Q) 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


                                                70.

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 “facilitate” to conspire in concert in the same defamation against the Pro Se Plaintiff reputation as being a dishonest, unskilled, substandard Construction Contractor and Pro Se Plaintiff is the direct reasoning for the older home located at 448 DeQueen Blvd. in Port Arthur Texas being torn down and a new one being built.       

                                                71.                 

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” on or about the dates of April 2nd 2008 and or April 11th 2008 Co-Defendant(s) admitted collectively of their involvement to “Entice”, “Induce”, “Allure”, and “Ensnare” Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein in his “Legal Capacities” as a “Attorney at Law”

 To commit to “Actual Fraud” of the 58th Judicial Court” of Jefferson County Texas  for the (RICO) enterprise purpose of “delays”, “concealment”, obstruction, “omitting” and “hindering” all material facts, accounts, material circumstances, events, both being now past, present, and future monetary gain of the Co-Defendant(s) collective “corrupted enterprise activates”

 The Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” of making numerous complaints thereof in Court filing records “Docket No. A-180805 and Before the State of Texas Investigation Services into the elderly

As well as all “secrete Pro Se Plaintiff discovery investigations” Pro Se Plaintiff was pursuing presently during said State Court Civil Complaint involving Co –Defendant(s) “Joyce M. Guy and Edward McCray” herein

In which further on or about April 2nd 2008 and or April 11th 2008 Co –Defendant(s) “Joyce M. Guy and Edward McCray” herein Fully Conspire, maneuver, pilot, manipulated, scheme and monetary paid and financially secure Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein in his “Legal Capacities” as a “Attorney at Law” throughout the dates of November 13th 2009 of his “paid in full legal services” for a total of (19) months to absolutely Violate Rule 193.1 Texas Civil Procedure in replying to the Pro Se Plaintiff Discovery request

 In order to fully engage in the covering up (RICO) collective scheme of things of Co-Defendant(s) “Joyce M. Guy and Edward McCray” having committed against The Pro Se Plaintiff, and the monetary scheme of things against said Federal and State Community Housing Grant

(RICO) collective scheme of things 58th Judicial District Court of Jefferson County Texas, Private Insurances Companies, State of Texas, and The United States of America’, in a long criminal corrupted enterprise of “Fraud for Monetary Gain” of said Co-Defendant(s) collectively “rip off” activities being described herein now Before The above entitled “Honorable” United State Federal Court having subject jurisdiction matter over the” Defendant and Co-Defendant(s)” collectively.

                                                72.

Pro Se Plaintiff, Declare, Affirm, and State before the “Honorable Justice” Chief Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein were “monetary retain” to file a General Denial on December 18th 2007 and then Chief Defendant Antoine L. Freeman J. D. herein

 
Claims that he was “not legally retained” at some point as acting Attorney of Record (Attorney at Law) Texas Bar. No. 24058299 to prepare and be ready to attended (2) court hearing before the 58th Judicial District Court in Jefferson County Texas for the legal behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on the dates of “August 28th 2009 and September 11th 2009 but was physically present in the capacity as “acting attorney of record”

While Chief Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein having full possession, custody and legal control over discovery request of Interrogatories, Request for Admission, and Request for Disclosure Pro Se Plaintiff mailed to him on the dates of March 14th 2008

And Chief Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein did not respond to any of said discovery request until on or about October 14th 2009.

Some (1) year and (6) months plus days later as Chief Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein was requested to complying with Texas rules of Civil Procedures, 194.2., 197, and 198. Request of Interrogatories, Request of Admission, and Request for Disclosure for civil cause No. A-180805

“However” at some point Chief Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein did in all Facts and Circumstances file a “Motion for Withdrawal” as Attorney of record for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein on

 November 13th 2009 @ 10:22 AM in the Judicial District “Clerk of Court Office” of Jefferson County Texas. Being already on file with the U.S. Clerk as Pro Se Plaintiff Exhibit (F)

                                                73.

Pro Se Plaintiff, Declares, Affirm, and State further before the “Honorable Justice” Chief Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein legally was acting as (RICO) enterprise “Attorney of Record” on or about the dates of August 28th 2009 and September 11th 2009 “Live” court hearing dates


 “However fully Legally Underhanded” during the same “time frame” of Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) claiming of not being the actual legal counsel of representation/presentation of said civil suit No. A-180805 on or about the same said dates of August 28th 2009 and September 11th 2009 “Live” court hearing dates

 
                                                74.

 
 Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively by and throughout their “Attorney of Record” being Chief Defendant (Attorney at Law) herein himself complex conspire together with the additional ongoing fraudulent activities of pirate loot” of (2) “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs”

Awarding Federal Agency: “United States Department of Housing and Urban Development” in excess of $72,500.00 U.S. Dollars, and $54,839.31 of the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” (RICO) gradually acquisitions earning since past (RICO) enterprise endeavors as described since activated in such monetary corruption starting legally in 1997

 
Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein whom now had conspire, executed and commence further (RICO) Fraud Activities and engage in the actual concealment of the “identifying property deeds” being a party to a Breach of Construction Contract with the
 

Pro Se Plaintiff Louis Charles Hamilton II herein being filed in Texas State Court Complaint docket No. A180805 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” during their ongoing Legal Retain Hire Top Gun Representation with Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299


Transfer of said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 to “Texas Department of Housing & Community Affairs” as Filed in Jefferson County Clerk Records # 2009022762, for a $72,500.00 Federal Housing Grant, as being described in “Jefferson County Texas Property Search Index” and Pro Se Plaintiff exhibit (Q) already on file with the U. S. Clerk
 
                                                75.

Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein further on June 18th 2009 while involved in this (RICO) activities filed a “fraudulent financing statement” in Jefferson County Clerk Records instrument # 2009022763

 
 In the connection thereof for fraud activities engagement of the “Texas Department of Housing & Community Affairs” for a monetary gain of in excess of said $72,500.00 U.S. Dollars Federal Housing Grant

 

After the Co-Defendant(s)“Joyce M. Guy and Edward McCray” herein already squandering all of the Home Owner Insurances funds, FEMA Funds designated for “actual building repairs” of said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2

 
Being as a result of Hurricanes damages from Hurricanes “Rita”, Humberto, and “Ike” as the 58th Judicial District Court of Jefferson County Texas “Court Order” to for Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein to produce among other such “Honorable 58th Judicial District Court” of Jefferson County Texas orders such
 

“Property Deeds” to said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 well into 2015 being (RICO) enterprise obstruction of justice, concealment, hidden and hinder in this scheme of things still in no compliance from first and foremost Defendant from March 14th 2008- November 2009 and Co-Defendant(s) collectively throughout the present time frame in this undersigned date in 2015

 
When this Pro Se Plaintiff Louis Charles Hamilton II required discover subject matter into property deeds was legally request and required to be produced on exact date of March 14th 2008.

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