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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