(51)
Pro Se Plaintiff further Assert,
declare and affirm before the “Honorable Justice” Chief Defendant “Doctor
Dinesh Chandra Khare”, and Co-Defendant(s), GEETA Group LLC., and
Co-Defendant(s) Vipul Khare, first
engage in the Common Law Fraud acts and actions within the State of Texas
Jurisdiction described as follows:
1.
Fraud by Non-Disclosure all
material factual circumstances that Co-Defendant(s) Geeta International et al
was “directly” handing all “legal Contractual Details of the Construction
Contract involved with the Pro Se Plaintiff “Louis Charles Hamilton II” herein
and Chief Defendant “Doctor Dinesh Chandra Khare”, and the property Lot 110
Block 4 of the “Walden on Lake Conroe Subdivision 3429 “Nottingham Ln,
Montgomery Texas 77356 herein and Chief Defendant “Doctor Dinesh Chandra
Khare”, herein was just simply their Co-Defendant(s) Geeta International et al acting
(United States of America) agent by design
2.
Fraud by Non-Disclosure of all material
factual circumstances that Co-Defendant(s) Geeta International et al would be
directly overseeing and handling all legal documents, payment plans, making the
approval over all actual monetary payments to Pro Se Plaintiff “Louis Charles
Hamilton II” for all “labor and materials services” received for the property
Lot 110 Block 4 of the “Walden on Lake Conroe Subdivision” 3429 “Nottingham Ln,
Montgomery Texas 77356 herein
3.
Fraud by Non-Disclosure of all material
factual circumstances that Geeta International et al in every aspect of “New
Home Construction dealings with the Pro Se Plaintiff would be the primary controlling
Principle Agent/Landowner in any and all said “written and verbal contractual agreement
with Pro Se Plaintiff “Louis Charles Hamilton II” for all “labor and materials
services” recivied for the property Lot 110 Block 4 of the “Walden on Lake
Conroe Subdivision” 3429 “Nottingham Ln, Montgomery Texas 77356 herein
4.
Fraud by Non-Disclosure of all
material factual circumstances that Pro Se Plaintiff “Louis Charles Hamilton II”
herein having a direct legal contractual
responsibility and obligation on July 8th, 9th, 12th, 17th, 26th, and August
7th and 23rd in the year 2015 as described in paragraph (42) above to
Co-Defendant(s) Geeta International et al in every aspect of construction
dealing with the Pro Se Plaintiff and the Property located in Montgomery County
Texas at 3429 Nottingham Ln in Montgomery, Texas 77356
5.
Fraud by Non-Disclosure of all
material factual circumstances that there never was (5) Properties in the “Walden
on the Lake Conroe Subdivision” ready for New Construction in the direct
ownership of Chief Defendant “Doctor Dinesh Chandra Khare”, herein.
6.
Fraud by Non-Disclosure of all
material factual circumstances that Co-Defendant(s) Greg Miller, Trillionaire
Realty et al”, and “Trillionaire Assets et al”, would be acting agent for Chief
Defendant “Doctor Dinesh Chandra Khare”, , Geeta International et al, , GEETA Group
LLC., property Lot 110 Block 4 of the “Walden on Lake Conroe Subdivision” 3429
“Nottingham Ln, Montgomery Texas 77356 herein
7.
Fraud by Non-Disclosure of all material
factual circumstances that Pro Se Plaintiff “Louis Charles Hamilton II” herein
having a direct legal contractual
responsibility and obligation to Co-Defendant(s) Greg Miller, Trillionaire
Realty et al”, and “Trillionaire Assets et al”,
8.
Fraud by Non-Disclosure of all
material factual circumstances that Pro Se Plaintiff “Louis Charles Hamilton
II” herein having a direct legal
contractual responsibility and obligation to Geeta International et al, and
Geeta International “Legal Department” et al, located at being 94/10 Phet Kasem 3 Soi 2, Bang Khae Nuea,
Bang Khae, Bangkok 10160, Thailand
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