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


                                                            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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