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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