30.
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 continue corrupted
(RICO) enterprise endeavor after he filed a “General Denial” for the
Co-Defendant(s) Joyce M. Guy and Edward McCray (herein) behalf to complaint
Cause No. A-180805 in Jefferson County Texas
Between the dates of December 18th 2007 engaged in several pattern
and practices in the capacity as a “Attorney of Law” in full obstruction of
justice, concealing, obscuring, masking, cloak and shielding while (RICO)
scheme corrupted being 100% fraudulent throughout the dates of March 14th
2008 and continue on
a. April of 2008
b. May of 2008
c. June of 2008
d. July of 2008
e. August of 2008
f. September of 2008
g. October of 2008
h. November of 2008
i. December of 2008
j. January of 2009
k. February of 2009
l. March of 2009
m. April of 2009
n. May of 2009
o. June of 2009
p. July of 2009
q. August of 2009
r. September of 2009
s. October of 2009
Fully obstructed the 58th
Judicial District Court discovery process, scuttles, concealed, mask, and
contained all “discovery materials” received from Pro Se Plaintiff herein this
civil matter from the exact time frame of March 14th 2008- November
13th 2009 being legally in possession, custody and control over Pro
Se Plaintiff request to disclose Pursuant to Rule 194 during the entire year of
2008-2009 and refusal to reply or response thereof
While at the same time being legally
in possession of Pro Se Plaintiff Request for admission and Interrogatories
being sent throughout the “United States Mailing system
Chief Defendant Antoine L. Freeman,
J.D. “Attorney at Law” herein fail well beyond (30) days of this requested
discovery to response or reply thereof, for the information or material
described in Rule 194.2: 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) herein 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
31.
All of which required a reply within (30) days
of these request discovery materials as Chief Defendant a skilled (Attorney at
Law) having full knowledge that a discovery phase process had commence in this
civil legal in common law docket No. A-180805
There
after submitting a “retain” counsel of law defense reply on behalf of the
Co-Defendant(s) Joyce M. Guy and Edward McCray collectively herein on December
18th 2007 but this (RICO) enterprise endure and grew snowball affect
downhill in design, instrument, documents,
Obstruction of justice, fraud upon the 58th
Judicial District Court system, absolutely engaging in concealment to scuttle/hidden
all required discovery document records and property deeds, all insurance records,
hurricane events records, construction Contractor estimates
And
contracts involved thereof from ever being discovery or brought before the
Honorable 58th Judicial District subject matter Jurisdiction
100%
gross unwanted stall tactics and circumstances against all material facts and
required discovery described against the original State Court Complaint A-180805
To
the point actual physical evidence was completely destroyed during the ongoing
civil suit in common law action A-180805 to further long advancement of this complex
secrete (RICO) enterprise scheme of things for a secured monetary value in
excess of $73,500.00 U.S. Dollars in
connection with
Namely
the home located at 448 DeQueen Blvd. in Port Arthur Texas which is involved
already in a disputed breach of Construction Contract, Fraud Claim made in
connection with this complex violations of Title 18
U.S.C. § 1341, 1343 and 1349 “Mail and Wire Fraud”,
With Chief
Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
direct further violations relating to section
1028(relating to fraud and related activity in connection with identification
documents), Section 1503(relating to obstruction
of justice),
Violations of Chapter 96 of Title 18, United State Code: (RICO)
Racketeering Influences Corruption Organization to advance such a monetary enterprise
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 fully tax free and being a Housing
grant of American U.S. Dollars
32.
"Computer Fraud and Abuse Act (CFAA) 18 U.S.C. § 1030 in
connection with all criminal acts and actions described legally herein this
Amend Complaint,
Furtherance’s
being directly in violation of 18 U.S.C. § 1001: US Code - Section 1001:
As
Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 100% direct leadership refusal to submit any “response or reply” to
all said discovery request as indicated in paragraph (30) in a timely fashion
Or
as generally required by Texas Rules of Civil Procedure “attorney of record institute
a “withdrawal immediately” thereafter in the month of December 2007 when Chief
Defendant Antoine L. Freeman, J.D. “Attorney at Law” herein claiming in court
documents his legal services officially ended directly Cause Pro Se Plaintiff
“Louis Charles Hamilton II” herein to suffer “actual damages” in excess of $336,000.00
U.S. Dollars
And this “actual damages” is ongoing as of
this undersigned date of this Amend Complaint before the Honorable U.S. Court Justice
since date of injury November 17th 2007.
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