89.
Further being described once before
the same U.S. District Court of Eastern District of Texas when (Pro Se
Plaintiff) filed his first original (RICO) complaint being legally made thereof
and now no question beyond any doubt ever being so “crystal clear” in 2015
Amend Complaint of the Pro Se Plaintiff
confident in being precise, and having a “well understanding” into this well
twisted, calculated, future plotted, manipulated,
(RICO) mutable Fraudulent count enterprising
“scheming activities” derive thereof and its involvement with Chief Defendant
Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein for
“Actual Damages” exceeding (7) years conspire
collectively with Co-Defendant(s) “Joyce M. Guy and Edward McCray herein to
depriving the Pro Se Plaintiff of his “personal property” namely “Construction
tools” in excess of $3800.00 U.S. Dollars and “lost wages” and earning capacity
at a minimums of $48,000.00 U.S. Dollars per year.
90.
Pro Se Plaintiff herein once being an
“Independent Construction Contractor” suffrage such brutal destruction of his
profession per (7) year since date of injury of November 2007 in the “Actual
Theft of property” of Said Entire Construction Company tools.
To include loss in construction
company profit earning derive against another (RICO) enterprise conspire sham
against said property of 5050 east 7th street in Port Arthur Texas
and connections to Hurricane “Rita”.
To include loss of earning derive
against another (RICO) enterprise conspire sham against said property of 448
DeQueen Blvd. in Port Arthur Texas
With 6% interest incurred since date
of Pro Se Plaintiff injury incurred being November 17th 2007 into
the future of 2015 as this Amend Complaint being “examine and entertain” before
the “Honorable Justice” of such “Actual Damages”.
91.
Pro Se Plaintiff being further set
forth Declares, Affirm, and
State further before the “Honorable U.S. Justice” herein mutable complex “Federal
Questions” subject matter being raised before the
“Honorable Justice” as to the Chief Defendant
(Attorney at Law) and Co-Defendant(s) collective (RICO) enterprise
criminal/civil corrupted scheming uncivil behavior being committed
Against the Pro Se Plaintiff civil
rights, peace, will, personal property and dignity in a Civil Suit in common
Law in connection with the Chief Defendant Antoine L. Freeman J. D. Attorney at
Law Texas Bar No. 24058299 defense thereof.
Which this “United States Eastern District
Court of Texas” having full expert “Honorable Justice” Subject Matter” over
such among other things (RICO) activities described herein full in this Amend
Complaint with supporting laundry list of “ prime meat and potatoes being
namely evidence/exhibit already on file with the U.S. Clerk office
And the further full knowledge
Defendant (Attorney at Law) executed in full wrongful conspire involvement
being of a “Legal expert” to commit to among other things “obstruction of
justice”, corrupted, misleading, manipulation” and fraud commitment upon the 58th
Judicial District Court of Jefferson County Texas in the public professional
trade “among all things”
The
“fiduciary capacity” of a legal “Attorney at Law” and “Officer of the Court” in
and For the State of Texas.
92.
The
Pro Se Plaintiff States, Affirm and Declares Chief Defendant (Attorney at Law)
herein willfully engaged in conduct criminaly fraudulent and knowingly assist
his client/co-defendant(s) in such (RICO) monetary grand enterprise activities
while the
Chief
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299
herein having fully skilled legal knowledge that
A lawyer shall not counsel a client to engage in conduct that
the lawyer knows is criminal or fraudulent, nor knowingly assist a client in
such conduct, but a lawyer may discuss the legal
consequences of any proposed course of conduct with a client and may counsel or assist a client to make a good faith effort to determine the validity, scope, meaning or application of the law.
• shall not counsel to engage in conduct that the lawyer knows is criminal or fraudulent.
• shall not knowingly assist a client in such conduct.
• When an attorney allows his client to give false sworn testimony or file false sworn affidavits, he is sanctioning the crimes of perjury and obstruction of justice by his client, and this violates the Rules.
• When an attorney allows his client to destroy or withhold documents that the client is obligated to produce, he is sanctioning the crimes of tampering with evidence and obstruction of justice.
• When an attorney allows his client to falsify documents or file bogus documents, he is sanctioning the crimes of tampering with evidence, obstruction of justice, and perhaps forgery.
• When an attorney knows his client is lying, concealing evidence, obstructing justice, violating any criminal statute, or committing fraud in any way, the attorney has an ethical obligation to
tell the client that this cannot be allowed.
consequences of any proposed course of conduct with a client and may counsel or assist a client to make a good faith effort to determine the validity, scope, meaning or application of the law.
• shall not counsel to engage in conduct that the lawyer knows is criminal or fraudulent.
• shall not knowingly assist a client in such conduct.
• When an attorney allows his client to give false sworn testimony or file false sworn affidavits, he is sanctioning the crimes of perjury and obstruction of justice by his client, and this violates the Rules.
• When an attorney allows his client to destroy or withhold documents that the client is obligated to produce, he is sanctioning the crimes of tampering with evidence and obstruction of justice.
• When an attorney allows his client to falsify documents or file bogus documents, he is sanctioning the crimes of tampering with evidence, obstruction of justice, and perhaps forgery.
• When an attorney knows his client is lying, concealing evidence, obstructing justice, violating any criminal statute, or committing fraud in any way, the attorney has an ethical obligation to
tell the client that this cannot be allowed.
In the representation of a client, a lawyer shall not: (a) file
a suit, assert a position, conduct a defense, delay a trial, or take other
action on behalf of the client when the lawyer knows or when it is
obvious that such action would serve merely to harass or maliciously injure another;
(b) knowingly advance a claim or defense that is unwarranted under existing law, except that the lawyer may advance such claim or defense if it can be supported by good faith argument for an extension, modification or reversal of existing law.
Disclosure to prevent a crime, tort, or fraud
obvious that such action would serve merely to harass or maliciously injure another;
(b) knowingly advance a claim or defense that is unwarranted under existing law, except that the lawyer may advance such claim or defense if it can be supported by good faith argument for an extension, modification or reversal of existing law.
Disclosure to prevent a crime, tort, or fraud
The crime-fraud exception can render the privilege moot when
communications between an attorney and client are themselves used to further a
crime, tort, or fraud. In Clark v. United States, the
US Supreme Court writes that "A client who consults an
attorney for advice that will serve him in the commission of a fraud will have
no help from the law. He must let the truth be told."
The crime-fraud exception also does require that the crime or
fraud discussed between client and attorney be carried out to be triggered
93.
Which Pro Se Plaintiff “Louis Charles Hamilton II” herein States, Affirm and Declares such “crime-fraud”
so richly (RICO) enterprise endeavor having been plotted, committed, and
achieved by Chief Defendant and
Co-Defendant(s) collectively being directly in violation of
18 U.S.C. § 1001 : US Code - Section 1001:
Statements or entries generally
(a) Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States,
Knowingly and willfully - (1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact;
(2) Makes any materially false, fictitious, or fraudulent statement or representation; or
(3) Makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;
94.
Cause of
Actions
Pro
Se Plaintiff herein “States”, “Affirm” and “Declare” further before the
“Honorable Justice” a Cause of Actions exist for U.S.
Code: Title 28:1343 Violations of Pro Se Plaintiff Civil Rights herein
95.
Cause of
Actions
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” a Cause of
Actions exist for "Violations against the
Computer Fraud and Abuse Act (CFAA) 18 U.S.C. § 1030 in connection with all
(RICO) enterprise “criminal acts and actions”, as legally described fully
herein.
96.
Cause of
Actions
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” a Cause of
Actions exist for Violations of Chapter 96 of Title
18, United State Code: (RICO) Racketeering Influences Corruption Organization,
Title 18 U.S.C. § 1341, 1343
And 1349 “Mail and Wire Fraud”, section
1028(relating to fraud and related activity in connection with identification
documents),
Section 1503(relating to obstruction
of justice) in connection with the Pro Se Plaintiff
and all records, affidavits, court records, transcripts, files and
documents, described legally fully
herein.
97.
Cause of
Actions
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” a Cause of
Actions exist for" Violations against the
Computer Fraud and Abuse Act (CFAA) 18 U.S.C. § 1030 in connection with all
(RICO) enterprise “criminal acts and actions”
In connection with the
Pro Se Plaintiff and all transcripts records,
“State and Federal” Computer records, Jefferson County Texas Public
records described legally fully herein.
98.
Cause of
Actions
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” a Cause of
Actions exist for Amendment VII Violation against
the Pro Se Plaintiff In Suits at common law, where the value in controversy
shall exceed twenty dollars, the right of trial by jury shall be preserved,
which the Chief Defendant and Co-Defendant(s) “Joyce M. Guy and Edward McCray”
(RICO) enterprise was
Obstruction of Justice not to preserved, and total destruction thereof Pro Se
Plaintiff right of o due process in said suit in common law,
99.
Cause of
Actions
Pro
Se Plaintiff herein “States”, “Affirm” and “Declare” further before the
“Honorable Justice” a Cause of Actions exist for Violation
against Pro Se Plaintiff entitlements under The Constitution of the State of
Texas,
In civil suit within the State of Texas, Article 16:
"General Provisions" Section 37 provides for the constitutional
protection of the mechanic's lien.
Section 50 provides for protection of a homestead against forced
sale to pay debts, except for foreclosure on debts related to the homestead
(mortgage, taxes, mechanic's liens, and home equity loans).
100.
Cause of
Actions
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” a Cause of
Actions exist for Violations of Chapter 96 of Title
18 United State Code:
In that Chief
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” collective
engaged in mutable monetary counts of (RICO) Racketeering Influences Corruption
Organization Enterprise,
Fraudulent engagement monetary endeavor from the
exact time frame of March 14th 2007 throughout 2015 as described
herein this Amend Complaint.
101.
Cause of
Actions
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” a Cause of
Actions exist for Chief Defendant(s) and Co-Defendant(s) collective conspire
Defamation of the Pro Se Plaintiff Construction reputation in connection with
the execution of such fraudulent (RICO) enterprise objectives as described
legally herein this Amend Complaint.
101.
Cause of
Actions
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” a Cause of
Actions exist for Chief Defendant(s) and Co-Defendant(s)collective Fraudulent
Corruption of The 58th Judicial District Court of Jefferson County
Texas System to induce,
And perpetrate such Fraud upon the 58th
Judicial District Court in a suit in common law for a period in excess of (19)
Months as all subject matter statements, “events” and “circumstances” described
fully legally herein this Amend Complaint of the Pro Se Plaintiff.
102.
Cause of
Actions
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” a Cause of
Actions exist for “Intentional Infliction of Emotional Distress” against
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and
Co-Defendant(s) “Joyce M. Guy and Edward McCray”.
Pro Se Plaintiff herein Incorporated
and state all Defendant (Attorney at Law) and Co-Defendant(s) herein enjoyed
collectively their “Intent” scheming fraudulent manufactory purpose in wanting
the
Pro Se Plaintiff herein to suffer,
extreme agony, heartache, distrait, Accompany substantially massive monetary
loss of “tools and independent services” in the Construction profession thereof,
Humiliation, Defamation, and crushing
legal defeat to inflict “excessive mental anguish” as a result of their combine
craft complex ongoing conspire (RICO) elements, and fraud on the court to
execute the same (RICO) objective
All of which being past, present, and
further derive thereof Pro Se Plaintiff suffrage such future (7) years of
ongoing “mental anguish” of the Chief Defendant and Co-Defendant(s) enforced
legal corrupted (RICO) enterprise strong hold over the civil suit in “common
law” rights of the Pro Se Plaintiff herein
Chief Defendant Antoine L. Freeman J.
D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and
Edward McCray”.
Civilly accomplish with strong corrupted concealment
motive not to be “confused or construed” with a simple attorney mistake by Chief
Defendant (Attorney at Law) in a combine collective “cause of action” before
the “Honorable Justice” for continual past, present, and future “Intentional
Infliction of Emotional Distress” upon the Pro Se Plaintiff herein.
102.
Cause of
Actions
Actual Damages Pro Se Plaintiff
wrongfully civilly suffer as follows: $336,000.00 U.S. Dollars in “loss wages”
and Loss Earning capacity from date of injury December 17th 2007 –
2014 and “actual damages” in excess of $3800.00 U.S. dollars for theft of
Pro Se Plaintiff personal property namely
construction tools, Actual Damages in the conspire $10,800.00 U.S. Dollars
Breach of Construction profits derive thereof, Actual damages in the Conspire
Construction Contract for the property located at 5050 east 7th
street in Port Arthur Texas 77640
103.
Cause of
Actions
Pro Se Plaintiff herein “States”,
“Affirm” and “Declare” further before the “Honorable Justice” a Cause of
Actions exist for “Declaratory Judgment” of the Honorable Court against Chief
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299
herein
And against Co-Defendant(s) “Joyce M.
Guy and Edward McCray” collectively as to all of the “material subject matter”
fully declared past, present and future Before the Honorable Justice herein
Of the Defendant and Co-Defendant(s)
Collective conclusive, conspire, concert, agreements, engagement, and
execution, pilot, maneuver, manipulated, scheme upon (RICO) enterprise
endeavors, objectives, actions and dealing, from the time frame of March 14th
2007 throughout 2015
103.
Cause of
Actions
Pro
Se Plaintiff herein “States”, “Affirm” and “Declare” further before the
“Honorable Justice” a Cause of Actions exist for “Actual Fraud”, Simultaneously
with a (RICO) enterprise, mail and wire fraud, breach of Contract, Obstruction
of Justice,
Fraud
is using deceit and dishonest means for the purpose of depriving of money/profits,
personal property and a legal civil right in a suit in common law docket No.
A-180805 against the Pro Se Plaintiff herein.
104.
Cause of
Actions
“Treble Exemplary Damages” Statue of the
“Honorable Court Justice” against Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 against
Co-Defendant “Joyce M. Guy” and Edward McCray” Collectively herein in favor of
the Pro Se Plaintiff.
105.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for accumulative, compensatory, consequential, continuing,
expectation damages, foreseeable, Future, incidental, indeterminate, reparable,
lawful, proximate, prospective, special, speculative, substantial, Awards in
Excess of the Jurisdictional amount of
$75,000.00 U.S. Dollars against Co-Defendant(s) “Joyce M. Guy” and “Edward
McCray” collectively in favor of the Pro Se Plaintiff for (RICO) enterprise
against the Pro Se Plaintiff civil rights, peace, personal property and
dignity.
106.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for “ Intentional
Infliction of Emotional Distress” against Chief Defendant Antoine L. Freeman J.
D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and
Edward McCray” collectively herein Awards in
Excess of the Jurisdictional amount of
$75,000.00 U.S. Dollars against Co-Defendant(s) “Joyce M. Guy” and “Edward
McCray” collectively in favor of the Pro Se Plaintiff for (RICO) enterprise
against the Pro Se Plaintiff civil rights, peace, personal property and
dignity.
107.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for Chief
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299
herein to pay “Actual Damages” to the Pro Se Plaintiff “Louis Charles Hamilton
II” wrongfully civilly suffer as follows: $336,000.00 U.S. Dollars in “loss
wages” and Loss Earning capacity from date of injury December 17th
2007 – 2014
And “actual damages” in excess of $3800.00
U.S. dollars for theft of Pro Se Plaintiff personal property namely
construction tools,
Actual Damages in the conspire
$10,800.00 U.S. Dollars Breach of Construction profits derive thereof, Actual
damages in the Conspire Construction Contract for the property located at
5050 east 7th street in
Port Arthur Texas 77640 all of which said Chief Defendant Antoine L. Freeman J.
D. Attorney at Law Texas Bar No. 24058299 herein
Directly provided (RICO) enterprise
skilled attorney at law racket, scheme, plot, conspire, concert, leadership and
obstruction of Justice thereof among other devise, instruments, trick, shams to
deprive the Pro Se Plaintiff herein thereof said
“Actual Damages” with 6% interest
incurred since date of Injury December 17th 2007.
108.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II herein Respectfully Moves the “Honorable Court Justice” for
“Declaratory Judgment” of the Honorable Court against Chief Defendant Antoine
L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein
And against Co-Defendant(s) “Joyce M.
Guy and Edward McCray” collectively as to all of the “material subject matter”
fully declared, described fully past, present and future Before the Honorable
Justice herein.
109.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II herein Respectfully Moves the “Honorable Court Justice” for
“Treble Exemplary Damages” Statue of the “Honorable Court Justice”
Against Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 against
Co-Defendant “Joyce M. Guy” and Edward McCray” Collectively herein in favor of
the Pro Se Plaintiff.
110.
Wherefore Pro Se Plaintiff Louis
Charles Hamilton II herein Respectfully Moves the “Honorable Court Justice” for
the Chief Defendant and Co-Defendant(s) collectively pay all court cost of this
U.S. Civil Court Action,
And all legal cost the Pro Se
Plaintiff incurred, and all Pro Se Plaintiff Attorney cost incurred herein.
111.
Wherefore Pro Se
Plaintiff Louis Charles Hamilton II Respectfully Moves and Request the “Honorable Court Justice” for any further,
Just, proper, Damages, Orders, and Awards
The “Honorable Court Justice” Deems
favorable for the behalf of Pro Se Plaintiff “Louis Charles Hamilton II” herein
in "Law and equity".
On this ______ Day of ________________ 2015
By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
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