(66)
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein
Fully “Declare”, State, and Affirm
before the “Honorable U.S. Justice” that Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd.
Co-Defendant(s) “Geeta International” et al and Geeta International” Legal
Division” et al, Co-Defendant(s) “Geeta International
Co. Ltd.”
Co-Defendant(s) GEETA Group LLC. And Co-Defendant(s)
Vipul Khare collectively from “January 1993 to
date (22) years and (9) months and counting specifically,
Being a “International
RICO Racket Cartel” design to Defraud “United States of America” as a Whole” in
Violation of 18 U.S.C. § 371 §371 with all Defendant(s) and Co-Defendant(s) collectively
committed to
“Conspiracy to commit
offense or to defraud United States” and Chief Defendant “Doctor Dinesh Chandra
Khare”, “Managing Director of (Geeta) International Co Ltd.
Co-Defendant(s) “Geeta International” et al and Geeta International” Legal
Division” et al, Co-Defendant(s) “Geeta International
Co. Ltd.”
Co-Defendant(s) GEETA Group LLC. And Co-Defendant(s)
Vipul Khare did in fact from “January 1993 to
date September 24th 2015 in the year 2015 (22) years and (9) months
and still counting specifically “did usage of
United States “Mail and
Wire services” to commit to Specifically violations of Title III of the of Co-Plaintiff(s) "USA Patriot Act" In connection with a
International (RICO) Cartel scheme of things engaging furtherance’s violations of “18 USC § 1343 RICO Wire Fraud”, and specifically,
violations of RICO statute (18 U.S.C. § 1961(1) “Money laundering”
And specifically,
violations of RICO statue “18 USC § 1341 “Mail Fraud”, among other Federal and
State criminal conducts.
(67)
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein Fully “Declare”, State, and Affirm before the
“Honorable U.S. Justice” that Co-Defendant “Greg Miller” of
“Trillionaire Realty”, and
Co-Defendant(s) “Trillionaire
Assets” conspire to in Violation of 18 U.S.C. § 371 §371 with all Defendant(s)
and Co-Defendant(s) collectively committed to “Conspiracy to commit offense or
to defraud United States” in concert with Chief Defendant “Doctor Dinesh
Chandra Khare”, “Managing Director of (Geeta) International Co Ltd.
Co-Defendant(s) “Geeta International” et al and Geeta International” Legal
Division” et al, Co-Defendant(s) “Geeta International
Co. Ltd.”
Co-Defendant(s) GEETA Group LLC. And Co-Defendant(s)
Vipul Khare collectively
(67)
Cause of Action
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) “United States of America” et al and Co-Plaintiff
“State of Texas” et al herein reincorporate and fully set all described in this
complaint in paragraph (1) - (67) as set forth this Honorable U.S. Court Justice”
for a entry of each 1-26 “cause of actions” as described above in paragraph (1)-(67)
above and seeks collectively against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd.
Co-Defendant(s) “Geeta International” et al and Geeta International” Legal
Division” et al, Co-Defendant(s) “Geeta International
Co. Ltd.”
Co-Defendant(s) GEETA Group LLC. And Co-Defendant(s)
Vipul Khare collectively
Count 1
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd.
Co-Defendant(s) “Geeta International” et al and Geeta International” Legal
Division” et al, Co-Defendant(s) “Geeta International
Co. Ltd.” In whole and or in parts
Specifically, a “International
RICO Racket” design to Defraud “United States of America” as a Whole” in
Violation of 18 U.S.C. § 371 §371 with Co-Defendant(s) “Greg Miller” of
“Trillionaire Realty”, and “Trillionaire Assets” committed to “Conspiracy to
commit same offense or to defraud United States” in whole or in parts as
described in this complaint.
Count
2
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein seeks collectively cause of Federal Civil Actions
against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd., Co-Defendant(s)
GEETA Group LLC.,
And Co-Defendant(s)
Vipul Khare in whole and or in parts collectively a “International RICO Racket” design to Defraud “United States of
America” as a Whole” Specifically cause of action in violation of Title III of the "USA Patriot Act"
With Co-Defendant(s) “Greg
Miller” of “Trillionaire Realty”, and “Trillionaire Assets” committed to same “Conspiracy
to commit same offense or to defraud United States” in whole or in parts as
described in this complaint.
Count
3
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein seeks collectively cause of Federal Civil Actions
against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd.,
Co-Defendant(s)
GEETA Group LLC. And Co-Defendant(s) Vipul Khare
in whole and or in parts collectively a “International RICO
Racket” design to Defraud “United States of America” as a Whole” Specifically cause
of action Specifically, violations of “18 USC § 1343 RICO Wire Fraud”,
With Co-Defendant(s) “Greg
Miller” of “Trillionaire Realty”, and “Trillionaire Assets” committed to same “Conspiracy
to commit same offense in whole or in parts as described in this complaint.
Count
4
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein seeks collectively cause of Federal Civil Actions
against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd.,
Co-Defendant(s)
GEETA Group LLC. And Co-Defendant(s) Vipul Khare
in whole and or in parts collectively a “International RICO
Racket” design to Defraud “United States of America” as a Whole” Specifically cause
of action for violations of RICO statute (18 U.S.C. § 1961(1) “Money
laundering”
With Co-Defendant(s) “Greg
Miller” of “Trillionaire Realty”, and “Trillionaire Assets” committed to same “Conspiracy
to commit same offense in whole or in parts as described in this complaint.
Count
5
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein seeks collectively cause of Federal Civil Actions
against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd.,
Co-Defendant(s)
GEETA Group LLC. And Co-Defendant(s) Vipul Khare
in whole and or in parts collectively a “International RICO
Racket” design to Defraud “United States of America” as a Whole” Specifically cause
of action for violations of RICO statue “18 USC § 1341 “Mail Fraud”,
With Co-Defendant(s) “Greg Miller” of
“Trillionaire Realty”, and “Trillionaire Assets” committed to same “Conspiracy
to commit same offense in whole or in parts as described in this complaint.
Count
6
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein seeks collectively cause of Federal Civil Actions
against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd., Co-Defendant(s)
GEETA Group LLC.
And Co-Defendant(s) Vipul Khare
in whole and or in parts collectively a “International RICO
Racket” design to Defraud “United States of America” as a Whole” Specifically cause
of action for violations of 18
U.S. Code § 1028A
With Co-Defendant(s) “Greg
Miller” of “Trillionaire Realty”, and “Trillionaire Assets” committed to same “Conspiracy
to commit same offense in whole or in parts as described in this complaint.
Count
7
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein seeks collectively cause of Federal Civil Actions
against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd.,
Co-Defendant(s)
GEETA Group LLC. And Co-Defendant(s) Vipul Khare
in whole and or in parts collectively a “International RICO
Racket” design to Defraud “United States of America” as a Whole” Specifically cause
of action for violations of 18
U.S. Code § 1001
With Co-Defendant(s) “Greg
Miller” of “Trillionaire Realty”, and “Trillionaire Assets” committed to same “Conspiracy
to commit same offense in whole or in parts as described in this complaint.
Count
6
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein seeks collectively cause of Federal Civil Actions
against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd.,
Co-Defendant(s)
GEETA Group LLC. And Co-Defendant(s) Vipul Khare
in whole and or in parts collectively a “International RICO
Racket” design to Defraud “United States of America” as a Whole” Specifically cause
of action for violations of 18
U.S. Code § 1028A
With Co-Defendant(s) “Greg
Miller” of “Trillionaire Realty”, and “Trillionaire Assets” committed to same “Conspiracy
to commit same offense in whole or in parts as described in this complaint.
Count
8
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein seeks collectively cause of Federal Civil Actions
against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd.,
Co-Defendant(s)
GEETA Group LLC. And Co-Defendant(s) Vipul Khare
in whole and or in parts collectively a “International RICO
Racket” design to Defraud “United States of America” as a Whole” Specifically cause
of action for violations of“18 USC § 1956 (A) (1)
With Co-Defendant(s) “Greg
Miller” of “Trillionaire Realty”, and “Trillionaire Assets” committed to same “Conspiracy
to commit same offense in whole or in parts as described in this complaint.
Count
9
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein seeks collectively cause of Federal Civil Actions
against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd.,
Co-Defendant(s)
GEETA Group LLC. And Co-Defendant(s) Vipul Khare
in whole and or in parts collectively a “International RICO
Racket” design to Defraud “United States of America” as a Whole” Specifically cause
of action for violations of 18 U.S.C. 1028A - Aggravated identity theft
With Co-Defendant(s) “Greg
Miller” of “Trillionaire Realty”, and “Trillionaire Assets” committed to same “Conspiracy
to commit same offense in whole or in parts as described in this complaint.
Count
10
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein seeks collectively cause of Federal Civil Actions
against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd.,
Co-Defendant(s)
GEETA Group LLC. And Co-Defendant(s) Vipul Khare
in whole and or in parts collectively a “International RICO
Racket” design to Defraud “United States of America” as a Whole” Specifically cause
of action for Computer Fraud and Abuse Act
(CFAA) 18 U.S.C. § 1030
With Co-Defendant(s) “Greg
Miller” of “Trillionaire Realty”, and “Trillionaire Assets” committed to same “Conspiracy
to commit same offense in whole or in parts as described in this complaint.
Count
11
Pro Se Plaintiff, “Louis Charles
Hamilton II”, Co-Plaintiff(s) United States of America” et al and Co-Plaintiff
“State of Texas” et al herein seeks collectively cause of Federal Civil Actions
against
Chief Defendant “Doctor
Dinesh Chandra Khare”, “Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd., Co-Defendant(s)
GEETA Group LLC.
And Co-Defendant(s) Vipul Khare
in whole and or in parts collectively a “International RICO
Racket” design to Defraud “United States of America” as a Whole” With Co-Defendant(s)
“Greg Miller” of “Trillionaire Realty”, and “Trillionaire Assets” committed to same
“Conspiracy to commit same offense in whole or in parts as described in this
complaint.
Count
12
Specifically cause of
action for violations of Deceptive Trade Practices Acts,
Brought in conjunction
with “Common law”
Count
13
Cause of action for Fraud,
Count
14
Cause of action for “Breach
of Construction Contract” committed against namely Pro Se Plaintiff “Louis
Charles Hamilton II” herein
Count
15
With specifically Cause
of action for “Obstruction of Justice”,
Count
16
Cause of action for “Medical
Battery”,
Count
17
Cause of action for Battery,
Count
18
Cause of action for “Harassment”,
Count
19
Cause of action for “Public
Nuisance”,
Count
20
Cause of action for “Civil
Conspirer”,
Count
21
Cause of action for “Intent
Gross Negligence”,
Count
22
Cause of action for “Slander”,
Count
23
Cause of action for “Breach
of Fiduciary Duty”,
Count
24
Cause of action for “False
Promise of Future Performance,
Count
25
Cause of action for Detrimental
reliance’s” and
Count
26
Cause of action for “Intentional infliction of
emotional distress
With Co-Defendant(s) “Greg
Miller” of “Trillionaire Realty”, and “Trillionaire Assets” committed to same “Conspiracy
to commit same offense in whole or in parts in Cause of actions Count(s) 1-26 as
described in this complaint in connection with a International
(RICO) Cartel scheme of things.
Count
27
To include Pro Se
Plaintiff, “Louis Charles Hamilton II”, Co-Plaintiff(s) United States of
America” et al and Co-Plaintiff “State of Texas” et al herein seeks
collectively “Declaratory Judgment” against
Chief Defendant “Doctor Dinesh Chandra Khare”,
“Managing Director of (Geeta) International Co Ltd, Co-Defendant(s) “Geeta International” et al and Geeta
International” Legal Division” et al, Co-Defendant(s) “Geeta
International Co. Ltd., Co-Defendant(s)
GEETA Group LLC. And Co-Defendant(s) Vipul Khare and Co-Defendant(s) “Greg Miller” of “Trillionaire Realty”, and
“Trillionaire Assets” committed to same.
Count 28
To include Pro Se
Plaintiff, “Louis Charles Hamilton II”, Co-Plaintiff(s) United States of
America” et al and Co-Plaintiff “State of Texas” et al herein seeks
collectively in whole or in parts violations of
U.S. Code: Title 28:1343 namely
Violations of Pro Se Plaintiff Civil Rights
herein With Co-Defendant(s) “Greg Miller” of “Trillionaire
Realty”, and “Trillionaire Assets” committed to same “Conspiracy to commit same
offense in whole or in parts in Cause of actions Count(s) 1-29 as described in
this complaint in connection with a International (RICO)
Cartel scheme of things.
Count 29
To include Pro Se
Plaintiff, “Louis Charles Hamilton II”, Co-Plaintiff(s) United States of
America” et al and Co-Plaintiff “State of Texas” et al herein seeks “cause of
actions” against Chief Defendant “Doctor Dinesh
Chandra Khare”, “Managing Director of (Geeta) International Co Ltd,
Co-Defendant(s) “Geeta International” et al and Geeta International” Legal
Division” et al, Co-Defendant(s) “Geeta International
Co. Ltd., Co-Defendant(s)
GEETA Group LLC. And Co-Defendant(s) Vipul Khare for
violations of
Co-Plaintiff(s) “United States of
America” et al and the “State of Texas” et al prospective (American) Constitution
provisions of “equal protection of the law” and “due process” thereof on the
Constitution of “United States of America and Constitution of the “State of
Texas” direct at the Pro Se Plaintiff Louis Charles Hamilton II herein and
others similarly the same having same business dealing Chief Defendant “Doctor Dinesh Chandra Khare”, “Managing Director of
(Geeta) International Co Ltd,
Co-Defendant(s) “Geeta International” et al and Geeta International” Legal
Division” et al, Co-Defendant(s) “Geeta International
Co. Ltd., Co-Defendant(s)
GEETA Group LLC. And Co-Defendant(s) Vipul Khare collectively.
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