Friday, June 19, 2015

United States District Court, Houston Division, Pro Se Plaintiff "Louis Charles Hamilton II" Civil Complaint for Defendants, "Raeis Construction Services Ltd. Co.," and "Porter International Construction, L.L.C. CEO Vernon Smith" et al


In The United States District Court

For The Southern District of Texas

Houston Division

Louis Charles Hamilton II

         Pro Se Plaintiff

            Vs.     

Raeis Construction Services Ltd. Co.

David Randin

 5747 Avonley Creek Dr. Sugar Hill, GA 30518

2000 Dairy Ashford, Houston TX. 77007

(Defendant)

            Vs.

Porter International Construction, L.L.C.

Vernon Smith CEO

20165 Old Houston Rd. Porter, Texas, 77365

(Co-Defendants)

            Vs.

Russell Mills

9535 Tower Street Houston Texas, 77088

  All American Concrete and Construction


                                                            Civil Complaint

                                                               Jury Demand

            Comes Now The Pro Se Plaintiff “Louis Charles Hamilton II” herein files “Civil Complaint” with the above Honorable U.S. District Court and for Just Cause, Pro Se Plaintiff herein will show before the “Honorable U.S. District Court” all facts, circumstances, detailing “among other things” Civil Cause of Actions

Specifically, Porter International Construction, L.L.C. CEO “Vernon Smith” committed as follows:

                                                            (1)

Tortious Interference with existing contract between Mr. Louis Charles Hamilton II, and Raeis Construction Services Ltd. Co., over a signed $120,000.00 agreed contract dated April 23rd 2015 to preformed concrete work at 797 Honea Egypt Road, Magnolia, TX

                                                      (2)

Tortious Interference with prospective relations, over a signed $120,000.00 agreed contract dated April 23rd 2015 to preformed concrete work at 797 Honea Egypt Road, Magnolia, TX

                                                            (3)

Civil Conspirers with acting agent David Randin of Raeis Construction Services Ltd. Co. and Russell Mills of “All American Concrete and Construction”

Whom was in partnership with (Pro Se Plaintiff) in this agreed contract dated April 23rd 2015 to preformed concrete work at 797 Honea Egypt Road, Magnolia, TX in excess of said $120,000.00 agreed contract.

To now “Russell Mills” herein having “Vernon Smith” (CEO) of “Porter International Construction, L.L.C” 20165 Old Houston Rd. Porter, Texas, 77365 to performed the said same $120,000.00 agreed contract dated April 23rd 2015 of the Pro Se Plaintiff “Louis Charles Hamilton II”

 Namely to preformed concrete work at 797 Honea Egypt Road, Magnolia, TX with pictures on file of “Porter International Construction, L.L.C” physically performing said same $120,000.00 agreed contract dated April 23rd 2015 o0f the Pro Se Plaintiff

                                                            (4)

Specifically, Porter International Construction, L.L.C. CEO “Vernon Smith” engaged with acting agent David Randin of Raeis Construction Services Ltd. Co. to a hostile Defamation of “Louis Charles Hamilton II” Specifically, “Vernon Smith” of “Porter International Construction, L.L.C” stating of “Louis Charles Hamilton II” concrete skills and abilities being substandard as a concrete contractor to preformed

Any building phase at all in concrete construction, at 797 Honea Egypt Road, Magnolia, TX and further Defame the Plaintiff  as “Worthless, uneducated, unskilled Construction worker trash”…

Specifically, Porter International Construction, L.L.C. CEO “Vernon Smith” never even met Pro Se Plaintiff “Louis Charles Hamilton II”, herein in his person or work with or for past or present with Pro Se Plaintiff during the time frame of said $120,000.00 agreed contract between Pro Se Plaintiff and for Raeis Construction Services Ltd. Co. “David Randin” dated April 23rd 2015 was introduced and signed

                                                            (5)

  Specifically, Porter International Construction, L.L.C. CEO “Vernon Smith” simply hostile, greedy, corrupted in fashion commence to defame, derail, 100% Interference with prospective relations, between the Pro Se Plaintiff and Raeis Construction Services Ltd. Co.

 Specifically, there after all was done as described above Porter International Construction, L.L.C. CEO “Vernon Smith” obtain physically the same said $120,000.00 Concrete Contract to preformed concrete construction, at 797 Honea Egypt Road, Magnolia, TX for Raeis Construction Services Ltd. Co. “David Randin” 5747 Avonley Creek Dr. Sugar Hill, GA 30518

With Raeis Construction Services Ltd.  Having office at 2000 Dairy Ashford, Houston TX. 77007

                                                            (6)

And this simply hostile, greedy, croupted in fashion commence to defame, derail, 100% Interference with prospective relations, between the Pro Se Plaintiff and Raeis Construction Services Ltd. Co. was done after Specifically, by Porter International Construction, L.L.C. CEO

 “Vernon Smith” was physically on said property @797 Honea Egypt Road, Magnolia, TX on April 23rd 2015 while “Louis Charles Hamilton II” already having a business meeting with Raeis Construction Services Ltd. Co. “David Randin” and already secured said $120,000.00 agreed contract dated April 23rd 2015,

                                                            (7)

“However” the Pro Se Plaintiff will show the Honorable Court facts that agent David Randin and  Raeis Construction Services Ltd. Co. and Russell Mills 9535 Tower Street Houston Texas of “All American Concrete and Construction”

Civilly conspire together against the (Plaintiff) with Porter International Construction, L.L.C. CEO “Vernon Smith” in which Porter International Construction, L.L.C. CEO “Vernon Smith” now having possession, custody, and control over the same said $120,000.00 concrete construction contract to performed work at the same job location of 797 Honea Egypt Road, Magnolia, TX and physically did so while

 “Louis Charles Hamilton II” (Pro Se Plaintiff) herein already having a secured concrete contract, blueprints for said $120,000.00 agreed contract signed by “Louis Charles Hamilton II, “David Randi” of “Raeis Construction Services Ltd. Co.” and Russell Mills 9535 Tower Street Houston Texas of “All American Concrete and Construction” dated April 23rd 2015, to performed said agreed Concrete construction at 797 Honea Egypt Road, Magnolia, TX

                                                                        (8)

Specifically, Pro Se Plaintiff will show the Honorable U.S. District Court, fact and circumstances that Porter International Construction, L.L.C. CEO “Vernon Smith” and “Russell Mills” of “All American Concrete and Construction”

Having engage in being partners on many Concrete Construction project over a 25 years past history, with one concrete partnership project done together between “Vernon Smith” and Russell Mills completed recent in 2015 long before Pro Se Plaintiff “Louis Charles Hamilton II” and “Russell Mills” of “All American Concrete and Construction” enter into partnership for contract with “Raeis Construction Services Ltd. Co.”

                                                            (8)

 To include but not limited to  (Hamilton) and (Mills) having a secured concrete contract, blueprints for said $120,000.00 agreed contract signed by “Louis Charles Hamilton II, “David Randi” of “Raeis Construction Services Ltd. Co.” And Russell Mills 9535 Tower Street Houston Texas of “All American Concrete and Construction” dated April 23rd 2015,

To the extent of several additional counts of “Civil Fraud”, with “Breach of Construction Contract”, “Detrimental Reliance”

Among other cause of actions being filed and levy well within the statute of limitation deadline” with the above Honorable U.S. District Court and for Just Cause,

With Principal place of business located for (Defendant) Raeis Construction Services Ltd. Co.  At 5747 Avonley Creek Dr. Sugar Hill, GA 30518 located well in a “Diversity of Jurisdiction” before the Honorable Justice.

                                                            (9)

                   Parties.

Pro Se Plaintiff, Louis Charles Hamilton II, and African American Male, U.S. Navy Veteran, Permanently Disable Veteran protected under: (ADA) American with Disability Act;

 And also minorities persons cover under Title VII of the Civil Rights Act of 1964; Domiciliary State of Texas, P.O. Box 17524 Sugar Land, Texas 77496

                                                                        (10)

Raeis Construction Services Ltd. Co., and their agent David Randin

 5747 Avonley Creek Dr. Sugar Hill, GA 30518 2000 Dairy Ashford, Houston TX. 77007 (Defendant)

                                                                        (11)

Porter International Construction, L.L.C. Vernon Smith CEO

20165 Old Houston Rd. Porter, Texas, 77365 (Co-Defendant)

                                                                        (12)

Russell Mills 9535 Tower Street Houston Texas, 77088, of All American Concrete and Construction (Co-Defendant)

                                                                        (13)

“United States of America” Not a Party to this U.S. Civil Suit

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