The standard for reviewing a traditional summary judgment is well established. See Nixon v. Mr. Prop.
Mgmt. Co., 690 S.W.2d 546, 548 (Tex. 1985); McAfee, Inc. v. Agilysys, Inc., 316 S.W.3d 820, 825 (Tex.
App.-Dallas 2010, no pet.).
The movant has the burden of showing that no genuine issue of material fact
exists and that it is entitled to judgment as a matter of law. Tex. R. Civ. P. 166a(c).
In deciding whether a disputed material fact issue exists precluding summary judgment, evidence favorable to the nonmovant will
be taken as true. Nixon, 690 S.W.2d at 548-49; In re Estate of Berry, 280 S.W.3d 478, 480 (Tex. App.-
Dallas 2009, no pet.).
Every reasonable inference must be indulged in favor of the nonmovant and any
doubts resolved in its favor. City of Keller v. Wilson, 168 S.W.3d 802, 824 (Tex. 2005). We review a
summary judgment de novo to determine whether a party's right to prevail is established as a matter of
law. Dickey v. Club Corp. of Am., 12 S.W.3d 172, 175 (Tex. App.-Dallas 2000, pet. denied).
Summary judgment is proper only when a movant establishes that there is no genuine issue of material
fact and that the movant is entitled to judgment as a matter of law. TEX. R. CIV. P. 166a(c).
A matter-of-law summary judgment is proper only when the movant establishes that there is no genuine
issue of material fact and that the movant is entitled to judgment as a matter of law. TEX. R. CIV. P. 166a
(c). The motion must state the specific grounds relied upon for summary judgment. Id.
The standard of review for a traditional summary judgment is well established: (1) the movant for summary
judgment has the burden of showing that no genuine issue of material fact exists and that it is therefore
entitled to summary judgment as a matter of law;
(2) in deciding whether there is a disputed material fact
issue precluding summary judgment, evidence favorable to the nonmovant will be taken as true;
and (3)
every reasonable inference must be indulged in favor of the nonmovant and any doubts resolved in the
nonmovant’s favor. See, e.g., Nixon v. Mr. Prop. Mgmt. Co., 690 S.W.2d 546, 548–49 (Tex. 1985).
In a traditional motion for summary judgment, the movant has the burden to show there is no genuine
issue of material fact and it is entitled to judgment as a matter of law. Nixon v. Mr. Prop. Mgmt. Co., 690 S.
W.2d 546, 548 (Tex. 1985).
In determining whether there is a genuine fact issue precluding summary
judgment, evidence favorable to the non-movant is taken as true and the reviewing court makes all
reasonable inferences and resolves all doubts in the non-movant’s favor. Id. at 548–49. If there is no
genuine issue of material fact, summary judgment should issue as a matter of law. Haase v. Glazner, 62 S.
W.3d 795, 797 (Tex. 2001).
A defendant who conclusively negates at least one of the essential elements
of a plaintiff’s cause of action is entitled to a summary judgment on that claim. IHS Cedars Treatment Ctr.
of DeSoto, Tex., Inc. v. Mason, 143 S.W.3d 794, 798 (Tex. 2004).
Once a defendant establishes its right
to summary judgment, the burden then shifts to the plaintiff to come forward with competent controverting
summary judgment evidence raising a genuine issue of material fact. Centeq Realty, Inc. v. Siegler, 899 S.
W.2d 195, 197 (Tex. 1995).
To prevail on a traditional summary judgment motion, the movant has the burden of proving that it is
entitled to judgment as a matter of law and that there are no genuine issues of material fact. Tex. R. Civ.
P. 166a(c); Cathey v. Booth, 900 S.W.2d 339, 341 (Tex. 1995). Res judicata is an affirmative defense.
Tex. R. Civ. P. 94; W. Dow Hamm III Corp. v. Millennium Income Fund, L.L.C., 237 S.W.3d 745, 755 (Tex.
App.—Houston [1st Dist.] 2007, no pet.).
A defendant is entitled to summary judgment based upon an
affirmative defense when the defendant proves all elements of the affirmative defense. Henry v. Masson,
No. 01-07-00522-CV, 2010 WL 5395640, at *16 (Tex. App.—Houston [1st Dist.] Dec. 31, 2010, no pet.)
(citing Havlen v. McDougall, 22 S.W.3d 343, 345 (Tex. 2000)).
To prevail on a traditional summary judgment motion, a movant must prove that there is no genuine issue
regarding any material fact and that it is entitled to judgment as a matter of law. See TEX. R. CIV. P. 166a
(c); Little v. Tex. Dep’t of Criminal Justice, 148 S.W.3d 374, 381 (Tex. 2004).
A party moving for summary judgment on one of its own claims must conclusively prove all essential elements of the claim. See Rhone-
Poulenc, Inc. v. Steel, 997 S.W.2d 217, 223 (Tex. 1999).
A defendant may also prevail by traditional summary judgment if it conclusively negates at least one essential element of a plaintiff’s claim or
conclusively proves an affirmative defense. See IHS Cedars Treatment Ctr. of DeSoto, Tex., Inc. v.
Mason, 143 S.W.3d 794, 798 (Tex. 2004).
A movant seeking traditional summary judgment on an
affirmative defense has the initial burden of establishing its entitlement to judgment as a matter of law by
conclusively establishing each element of its affirmative defense.
See Chau v. Riddle, 254 S.W.3d 453,
455 (Tex. 2008) (per curiam); see also TEX. R. CIV. P. 166a(b)–(c). A matter is conclusively established if
reasonable people could not differ as to the conclusion to be drawn from the evidence. See City of Keller
v. Wilson, 168 S.W.3d 802, 816 (Tex. 2005).
If the movant meets its burden, the burden then shifts to the nonmovant to raise a genuine issue of
material fact precluding summary judgment. See Centeq Realty, Inc. v. Siegler, 899 S.W.2d 195, 197
(Tex. 1995).
The evidence raises a genuine issue of fact if reasonable and fair-minded jurors could differ
in their conclusions in light of all of the summary-judgment evidence. See Goodyear Tire & Rubber Co. v.
Mayes, 236 S.W.3d 754, 755 (Tex. 2007) (per curiam).
NO-EVIDENCE MOTION FOR SUMMARY JUDGMENT - TRCP 166a(i)
After adequate time for discovery, a party without the burden of proof at trial may move for summary
judgment on the ground that there is no evidence of one or more essential elements of a claim or
defense. See Tex. R. Civ. P. 166a(i).
We review the granting of a motion for no-evidence summary judgment under the same legal sufficiency standard used to review a directed verdict. King Ranch, Inc.
v. Chapman, 118 S.W.3d 742, 750-51 (Tex. 2003); Ogg v. Dillard's, Inc., 239 S.W.3d 409, 416 (Tex.
App.-Dallas 2007, pet. denied).
Our inquiry focuses on whether the nonmovant produced more than a scintilla of probative evidence to raise a fact issue on the challenged elements. King Ranch, Inc., 118 S.
W.3d at 751.
Evidence is no more than a scintilla if it is "so weak as to do no more than create a mere surmise or suspicion" of a fact. Id.
Where, as here, the trial court's order granting summary judgment does not specify the grounds upon which it was granted, we will affirm the judgment if any of the theories
advanced are meritorious. See Provident Life & Acc. Ins. Co. v. Knott, 128 S.W.3d 211, 216 (Tex. 2003);
Kastner v. Jenkens & Gilchrist, P.C., 231 S.W.3d 571, 577 (Tex. App.-Dallas 2007, no pet.).
A no-evidence summary judgment motion under Rule 166a(i) is essentially a motion for a
pretrial directed verdict; it requires the nonmoving party to present evidence raising a genuine
issue of material fact supporting each element contested in the motion. Tex. R. Civ. P. 166a(i);
Mack Trucks, Inc. v. Tamez, 206 S.W.3d 572, 581-82 (Tex. 2006).
STANDARD OF REVIEW ON APPEAL. When reviewing a no-evidence summary judgment,
we “review the evidence presented by the motion and response in the light most favorable to the
party against whom the summary judgment was rendered,
crediting evidence favorable to that party if reasonable jurors could, and disregarding contrary evidence unless reasonable jurors
could not.” Mack Trucks, 206 S.W.3d at 582 (citing City of Keller v. Wilson, 168 S.W.3d 802,
827 (Tex. 2005); Johnson v. Brewer & Pritchard, P.C., 73 S.W.3d 193, 208 (Tex. 2002)).
MUST STATE ON WHICH ELEMENT THERE IS NO EVIDENCE. It is well settled that a trial
court cannot grant a summary judgment motion on grounds not presented in the motion. Brewer
& Pritchard, P.C., 73 S.W.3d at 204; Science Spectrum, Inc. v. Martinez, 941 S.W.2d 910, 912
(Tex. 1997). Our no-evidence summary judgment rule similarly requires that the moving party
identify the grounds for the motion:
After adequate time for discovery, a party without presenting summary judgment evidence may
move for summary judgment on the ground that there is no evidence of one or more essential
elements of a claim or defense on which an adverse party would have the burden of proof at trial
Friday, November 7, 2014
Louis Charles Hamilton II PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT No. A-180805
Plaintiff Personal Lost in tool(s) $3093.00 dollars, to include Plaintiff brand New “Hitachi Air Compressor” $680.00 #2700009 purchased @ Lowell’s in “New Orleans, L.A.”
Plaintiff was working during the aftermath of Hurricane (Katrina) and can prove such a massive collection of tools
The Defendants (Told) the Port Arthur Texas (Police) Dept. that the Plaintiff has no receipts for his tools and all of his tools are staying on their property of the Defendant(s), “Joyce Guy and Edward McCray”
“However” the Plaintiff was only allowed to have back his own “Construction Lab top Computer” that was on the Property of the Defendant(s).
Plaintiff Further state before the Honorable Court the Affidavit of the Defendant (Joyce Guy) dated September 11, 2009 support a entry of Summary Judgment in Favor of the Plaintiff (Alone) by the
Defendant (Joyce Guy) very own Sworn statement being Plaintiff exhibit (A)
As Follows: The Defendant (Joyce Guy) Fully aware of a civil action pending against (Her) and from the date of December 18, 2007 throughout the undersigned date of said exhibit (A) Affidavit of
Defendant (Joyce Guy) September 11, 2009 being approximately “One Year and Nine Months” Defendant having full knowledge of Civil suit is in progress as she quite refusal to comply with discovery” regardless of her hired Gun “Attorney”
Defendant work to not comply with any discovery at this time frame as well as a all out refusal of a “Honorable Court order” being Plaintiff exhibit (L) dated 10th of May 2010.
Thus bring the Defendant(s) well document actions in refusal to comply with the local rules of This Honorable District Court to a total time of Defendant refusal from the issuance of said Court Order to now a new time frame of “Two Years and Eight Months” Defendant(s) total disregards for this “Live” Civil action,
and their combine conduct fully dictates and logical, legal, Conclusion that a
Summary Judgment is warrant, Just and Proper”.
Any further litigation of this civil action is a pure disgrace of the Honorable 58th District Court times in dealing with such “Hostile” described Defendant(s) collectively as their combine continue disregard actions for “Court Authority before the “Honorable Court”
also support the Plaintiff Claims made against the Doggeries Acts of Defendant(s) “Joyce Guy and Edward McCray”
Notwithstanding the only way any discover will be obtain from these Defendant(s) is through a Strong Arm
“Court Order”
That the Defendant(s) collectively being placed in Jefferson County Jail
until all such required discover is fully provided to the Plaintiff and the Honorable Court Records 
Plaintiff was working during the aftermath of Hurricane (Katrina) and can prove such a massive collection of tools
The Defendants (Told) the Port Arthur Texas (Police) Dept. that the Plaintiff has no receipts for his tools and all of his tools are staying on their property of the Defendant(s), “Joyce Guy and Edward McCray”
“However” the Plaintiff was only allowed to have back his own “Construction Lab top Computer” that was on the Property of the Defendant(s).
Plaintiff Further state before the Honorable Court the Affidavit of the Defendant (Joyce Guy) dated September 11, 2009 support a entry of Summary Judgment in Favor of the Plaintiff (Alone) by the
Defendant (Joyce Guy) very own Sworn statement being Plaintiff exhibit (A)
As Follows: The Defendant (Joyce Guy) Fully aware of a civil action pending against (Her) and from the date of December 18, 2007 throughout the undersigned date of said exhibit (A) Affidavit of
Defendant (Joyce Guy) September 11, 2009 being approximately “One Year and Nine Months” Defendant having full knowledge of Civil suit is in progress as she quite refusal to comply with discovery” regardless of her hired Gun “Attorney”
Defendant work to not comply with any discovery at this time frame as well as a all out refusal of a “Honorable Court order” being Plaintiff exhibit (L) dated 10th of May 2010.
Thus bring the Defendant(s) well document actions in refusal to comply with the local rules of This Honorable District Court to a total time of Defendant refusal from the issuance of said Court Order to now a new time frame of “Two Years and Eight Months” Defendant(s) total disregards for this “Live” Civil action,
and their combine conduct fully dictates and logical, legal, Conclusion that a
Summary Judgment is warrant, Just and Proper”.
Any further litigation of this civil action is a pure disgrace of the Honorable 58th District Court times in dealing with such “Hostile” described Defendant(s) collectively as their combine continue disregard actions for “Court Authority before the “Honorable Court”
also support the Plaintiff Claims made against the Doggeries Acts of Defendant(s) “Joyce Guy and Edward McCray”
Notwithstanding the only way any discover will be obtain from these Defendant(s) is through a Strong Arm
“Court Order”
That the Defendant(s) collectively being placed in Jefferson County Jail
until all such required discover is fully provided to the Plaintiff and the Honorable Court Records
Thursday, November 6, 2014
Louis Charles Hamilton II PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT No. A-180805
The Plaintiff Further State before “The Honorable Court”,
A hearing was held before The 58th District Court on Plaintiff Motion to Compel Production of Documents and the Court “Ordered that Defendants Joyce Guy and Edward McCray shall produce copies of deeds, property deeds or any other such physical document in Defendants’ possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas
To include the Court “Ordered further that the Defendants Joyce Guy and Edward McCray shall produce copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to damages caused by Hurricanes Rita, Humberto, and Ike to the property located at 448 Dequeen Blvd. in Port Arthur, Texas
This Order of the 58th District Court was executed on May 10, 2010 and from that time frame to this very undersigned date the Defendant(s) refuse to comply with said “Court Orders” and produce said discovery Production of document request while Defendant(s) having the authority to comply with said Court Orders,
Defendant(s) Joyce Guy and Edward McCray will never ever comply with any Judicial District Court Orders within the State of Texas, and this 58th District Court of Jefferson County Texas has been proven to be quite beneath the Defendants Authority, Reach, and quite simply powerless thus far against said Defendants Joyce Guy and Edward McCray, and their Attorney of the Past Antoine L. Freeman, J. D. Texas Bar No. 24058299. And made to look quite foolish in being an “Honorable Court”
Even while Defendant(s) were with a Attorney of record it was His paid duties to mislead the 58th District Court and provide nothing being real Judicial Evidence in Favor of the Plaintiff that is actual in rendering a real physical documented response from “Joyce Guy and Edward McCray” and showing their numerous Fraud activities as described by the Pro Se Plaintiff in the Records herein of this civil complaint
Plaintiff files 58th Judicial Court Orders as Plaintiff exhibit (L) herein and state respectfully before the Honorable 58th District Court”.
That all required Court orders of this Honorable 58th District Court is very material in this particular case, and well within the means of the Defendants abilities to Honor such a Judicial Court Order as they flat out refusing to do so
Defendant(s) collectively in the past did submit Hurricane damages construction contractor’s estimates to their Insurance Companies for Hurricanes Rita, Humberto, and Ike for the property located at 448 DeQueen blvd. in Port Arthur, Texas. Just as they did Plaintiff Construction Contract and as admitted in Plaintiff “Request for Admission” exhibit (K)
As this being a standard practice for any home owner to submit to their home owner insurance companies construction contractors estimates for Hurricanes related damages to receive funding based upon contractors estimates and the Defendants refuse to retrieve any Public Records in this regards, especially with their “Insurance Companies” Banking records “notwithstanding giving up
the actual Identity of said “Insurance Companies”
Defendant(s) Joyce Guy and Edward McCray collectively are even definite in not providing any proof of actual ownership of the property in question at 448 DeQueen Blvd. in Port Arthur Texas as the Honorable 58th District Court so Order said Defendant(s) in doing so in this simple regards.
Contempt of court generally refers to conduct that defies disrespects or insults the authority or dignity of a court. Often, contempt takes the form of actions that are seen as detrimental to the court's ability to administer justice.
In this case the Defendant(s) Joyce Guy and Edward McCray rely on their defines of the Honorable Court Orders to reply on the 58th District Court of Jefferson County Texas assumed inability to administer justice in favor of the Plaintiff,
Notwithstanding Defendants Joyce Guy and Edward McCray do not even began to adhere to this Honorable Court authority/actions, even while being with their Attorney of Record of the past Antoine L. Freeman, J. D. Texas Bar No. 24058299 now creating one big messy miscarriage of Justice as of this undersigned date.
Civil contempt sanctions typically end when the party in contempt complies with the Court order, or when the underlying case is resolved. And this case has not been resolved, the actions of the Defendant(s) to defend their acts provides that a summary judgment is in favor of the Plaintiff and is warrant with all of the Plaintiff exhibit(s) in support thereof,
Defendant(s) took the extra civil/criminal steps in hiring a Attorney of Law to disguise their civil case, mislead the Honorable Court and at all cost bury the physical evidence, while misused the Rules of Texas Civil procedure to aid in the inability of this 58th District Court to administer justice in favor of the Plaintiff.
A hearing was held before The 58th District Court on Plaintiff Motion to Compel Production of Documents and the Court “Ordered that Defendants Joyce Guy and Edward McCray shall produce copies of deeds, property deeds or any other such physical document in Defendants’ possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas
To include the Court “Ordered further that the Defendants Joyce Guy and Edward McCray shall produce copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to damages caused by Hurricanes Rita, Humberto, and Ike to the property located at 448 Dequeen Blvd. in Port Arthur, Texas
This Order of the 58th District Court was executed on May 10, 2010 and from that time frame to this very undersigned date the Defendant(s) refuse to comply with said “Court Orders” and produce said discovery Production of document request while Defendant(s) having the authority to comply with said Court Orders,
Defendant(s) Joyce Guy and Edward McCray will never ever comply with any Judicial District Court Orders within the State of Texas, and this 58th District Court of Jefferson County Texas has been proven to be quite beneath the Defendants Authority, Reach, and quite simply powerless thus far against said Defendants Joyce Guy and Edward McCray, and their Attorney of the Past Antoine L. Freeman, J. D. Texas Bar No. 24058299. And made to look quite foolish in being an “Honorable Court”
Even while Defendant(s) were with a Attorney of record it was His paid duties to mislead the 58th District Court and provide nothing being real Judicial Evidence in Favor of the Plaintiff that is actual in rendering a real physical documented response from “Joyce Guy and Edward McCray” and showing their numerous Fraud activities as described by the Pro Se Plaintiff in the Records herein of this civil complaint
Plaintiff files 58th Judicial Court Orders as Plaintiff exhibit (L) herein and state respectfully before the Honorable 58th District Court”.
That all required Court orders of this Honorable 58th District Court is very material in this particular case, and well within the means of the Defendants abilities to Honor such a Judicial Court Order as they flat out refusing to do so
Defendant(s) collectively in the past did submit Hurricane damages construction contractor’s estimates to their Insurance Companies for Hurricanes Rita, Humberto, and Ike for the property located at 448 DeQueen blvd. in Port Arthur, Texas. Just as they did Plaintiff Construction Contract and as admitted in Plaintiff “Request for Admission” exhibit (K)
As this being a standard practice for any home owner to submit to their home owner insurance companies construction contractors estimates for Hurricanes related damages to receive funding based upon contractors estimates and the Defendants refuse to retrieve any Public Records in this regards, especially with their “Insurance Companies” Banking records “notwithstanding giving up
the actual Identity of said “Insurance Companies”
Defendant(s) Joyce Guy and Edward McCray collectively are even definite in not providing any proof of actual ownership of the property in question at 448 DeQueen Blvd. in Port Arthur Texas as the Honorable 58th District Court so Order said Defendant(s) in doing so in this simple regards.
Contempt of court generally refers to conduct that defies disrespects or insults the authority or dignity of a court. Often, contempt takes the form of actions that are seen as detrimental to the court's ability to administer justice.
In this case the Defendant(s) Joyce Guy and Edward McCray rely on their defines of the Honorable Court Orders to reply on the 58th District Court of Jefferson County Texas assumed inability to administer justice in favor of the Plaintiff,
Notwithstanding Defendants Joyce Guy and Edward McCray do not even began to adhere to this Honorable Court authority/actions, even while being with their Attorney of Record of the past Antoine L. Freeman, J. D. Texas Bar No. 24058299 now creating one big messy miscarriage of Justice as of this undersigned date.
Civil contempt sanctions typically end when the party in contempt complies with the Court order, or when the underlying case is resolved. And this case has not been resolved, the actions of the Defendant(s) to defend their acts provides that a summary judgment is in favor of the Plaintiff and is warrant with all of the Plaintiff exhibit(s) in support thereof,
Defendant(s) took the extra civil/criminal steps in hiring a Attorney of Law to disguise their civil case, mislead the Honorable Court and at all cost bury the physical evidence, while misused the Rules of Texas Civil procedure to aid in the inability of this 58th District Court to administer justice in favor of the Plaintiff.
Louis Charles Hamilton II PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT No. A-180805
The Plaintiff Further State before “The Honorable Court”,
The defendant(s) as described in Plaintiff exhibit (K) Request for Admission dated October 14, 2009 supply their collective response in regards to “Request for Admission question No. 5 and question
No. 6 as follows:
Admit the Defendants herein received $7000 from their home owner insurance company.
RESPONSE: ADMITTED
Admit the Defendant herein forward construction Contract of 10,800 to their home owner insurance company/mortgages company to receive an additional amount to cover construction difference amount.
RESPONSE: ADMITTED
The Defendants admitted this was the case involving the Plaintiff and his construction contract for $10,800, while at the same time during discovery hiding this unknown Insurance Company Identity completely from being brought into question in this civil matter,
As a precise witness in favor of all of The Plaintiff claims that the defendant squanders $7000.00 from the Hurricane claim of (Rita) long before the $10,800 Contract of Plaintiff was even introduced to said insurance company
While the Defendant(s) making the actual presentation to said Insurance Company that more repairs funds was needed, to include that physical construction repairs had did in fact commence on the home at 448 DeQueen blvd. in Port Arthur Texas after $7000.00 of repair funds being already forward to said Defendant(s) for such storm related repairs
Plaintiff states before the Honorable 58th District Court of Jefferson County Texas Defendants continue to hide all Insurance and banking records in regards to exact amount the Defendants received in repairs funds, exact dates, and what was spent with the $7000.00 first installment of said Insurance Companies repair funds for very need construction repairs in the year of 2007.
Plaintiff Exhibit (K) is material proof before the “Honorable Court” of the Plaintiff involvement in this civil matter by the defendants own admission to exhibit (K), request for Admission question 5 and 6
Providing additional fact before “The Honorable Court examination” of said Request for Admission that the Defendant(s) collectively knowingly executed and hatched a plan to conspire, scheme, and deliberation of a intent to commit fraud Against The Unknown Insurance Company”
While making the Plaintiff the primary tool /mark to achieved additional monetary fund’s there after defendants already having their squandering ways with the first $7000.00 funds of Construction Repair funds.
The defendant(s) as described in Plaintiff exhibit (K) Request for Admission dated October 14, 2009 supply their collective response in regards to “Request for Admission question No. 5 and question
No. 6 as follows:
Admit the Defendants herein received $7000 from their home owner insurance company.
RESPONSE: ADMITTED
Admit the Defendant herein forward construction Contract of 10,800 to their home owner insurance company/mortgages company to receive an additional amount to cover construction difference amount.
RESPONSE: ADMITTED
The Defendants admitted this was the case involving the Plaintiff and his construction contract for $10,800, while at the same time during discovery hiding this unknown Insurance Company Identity completely from being brought into question in this civil matter,
As a precise witness in favor of all of The Plaintiff claims that the defendant squanders $7000.00 from the Hurricane claim of (Rita) long before the $10,800 Contract of Plaintiff was even introduced to said insurance company
While the Defendant(s) making the actual presentation to said Insurance Company that more repairs funds was needed, to include that physical construction repairs had did in fact commence on the home at 448 DeQueen blvd. in Port Arthur Texas after $7000.00 of repair funds being already forward to said Defendant(s) for such storm related repairs
Plaintiff states before the Honorable 58th District Court of Jefferson County Texas Defendants continue to hide all Insurance and banking records in regards to exact amount the Defendants received in repairs funds, exact dates, and what was spent with the $7000.00 first installment of said Insurance Companies repair funds for very need construction repairs in the year of 2007.
Plaintiff Exhibit (K) is material proof before the “Honorable Court” of the Plaintiff involvement in this civil matter by the defendants own admission to exhibit (K), request for Admission question 5 and 6
Providing additional fact before “The Honorable Court examination” of said Request for Admission that the Defendant(s) collectively knowingly executed and hatched a plan to conspire, scheme, and deliberation of a intent to commit fraud Against The Unknown Insurance Company”
While making the Plaintiff the primary tool /mark to achieved additional monetary fund’s there after defendants already having their squandering ways with the first $7000.00 funds of Construction Repair funds.
Louis Charles Hamilton II PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT No. A-180805
The Plaintiff Further State before “The Honorable Court”,
“The Defendant(s) By and through their Attorney of record Antoine L. Freeman, J.D. Texas Bar No. 24058299 was in fact served Plaintiff Request for Admissions propounded by Louis Charles Hamilton II Pro Se Plaintiff herein pursuant to rule 198 of the Texas Rules of Civil Procedure.
Filed herein as Plaintiff exhibit (K) before the “Honorable Court”.
Providing, and legally well documented additional proof with all of the court records, exhibit(s) and files herein cause No. A-180805
Thus 100% Proving the Following official legal material facts before any “Honorable Court” of Law in and for The State of Texas as follows:
1. Attorney of Record Antoine L. Freeman, J. D. Texas Bar No. 24058299 was in fact full acting Attorney of record from dates of filing a General Denial December 18th 2007 as he claim in the records and doing so further acting as Attorney of record in filing a reply to Plaintiff (Interrogatories) already filed herein and dated October 14th 2009 as Exhibit (I)
2. To now include Attorney of record was in fact full acting legal capacity in filing a reply the Plaintiff Request for Admissions exhibit (K) and dated October 14, 2009 at this point the Plaintiff point out further that Attorney of record made a illegal bogus claim before The Honorable Judge “Bob Wortham that his only legal duties as described in Plaintiff exhibit (B) paragraph III. As Stated by said Attorney of Record Antoine L. Freeman, J. D. Texas Bar No. 24058299 follows:
3. At the time of Plaintiffs discovery request Defendant’s Attorney had not been retain by Defendants to represent their interest with regard to this lawsuit, Defendant, Joyce Guy, retain the services of Antoine Freeman for the purpose of writing a general denial so as to avoid default judgment being rendered against her.
4. The Honorable Court 58th District Court Judge Bob Wortham” ruled completely erroneously in favor of said Defendant’s Attorney of record Antoine L. Freeman, J. D. Against Pro Se Plaintiff request for sanctions being level and citied against said Attorney of record Antoine L. Freeman, J. D. Texas Bar No. 24058299
In official court docket No. A-180805 records when all of Plaintiff evidence filed herein support that a legal finding that Defendant’s Attorney did violated Rule 193.1 by failing to respond to Plaintiff’s discovery request up to almost 2 years while having full legal knowledge of such a discovery request was being pursued by the Pro Se Plaintiff
A. Attorney of Record Antoine L. Freeman, J. D. Was acting with physical fiduciary capacities as an Attorney of Law for the State of Texas Bar. No. 24058299 on or about December 18th 2007 and continue doing the same legal capacities being fully intact as acting Attorney of record and filed official court records with the Plaintiff as described in Plaintiff exhibit (I) and (K) dated October 14, 2009
B. The Attorney of record Antoine L. Freeman, J. D. then at this point took his civil wrongful lie, and false presentation filing before the 58th District Jefferson County Honorable Court Judge “Bob Wortham” stating he was not the Attorney of record and only filed a general denial with the Court and this was his only legal obligations, and this ended on December 18th 2007
C. To include as further evidence to support the Plaintiff cause for sanctions against said Attorney Antoine L. Freeman, J. D. the Plaintiff exhibit (A) Affidavit of Defendant “Joyce M. Guy” dated September 11, 2009 to support another bogus Defendant claim too, on behalf of her own Attorney of record Antoine L. Freeman, J. D. rouge acts to “avoid sanctions” in favor of the Plaintiff when both Defendant(s) collectively and Attorney of record Antoine L. Freeman, J. D. having full legal knowledge of such a discovery request being in place, and pursued from December 18th 2007 throughout October 14, 2009
D. Attorney of Records Antoine L. Freeman, J. D. maintain his only duties was Just filing a “General Denial” before the Honorable 58th District Court Judge “Bob Wortham” as his Attorney of record signature and Bar No. 24058299 is materially present on both Plaintiff exhibit (I) and (K) dated October 14, 2009 well beyond the filing of said General Denial on December 18th 2007
E. Namely official Court discovery documents devise in the form of “Request for Admissions” pursuant to Rule 198 of the Texas Rules of Civil Procedure and Plaintiff First set of Interrogatories” pursuant to 197 of the Texas Rules of Civil Procedure both being dated on October 14, 2009 proving the Pro Se Plaintiff was in pursuit of civil discovery well up to 2 years through Defendant(s) Attorney of Record, Antoine L. Freeman, J. D. with his signature and Bar No. 24058299 being materially present against said Attorney Claims he was only acting in December 18th 2007
F. As this Rouge Attorney did aid in criminally stalling against the Rules of Civil Procedures tactics with full payment to doing such actions by said defendant(s) to achieve this lawless civil act against the Pro Se Plaintiff rights to a Just cause of action before any court of Law within the State of Texas in Docket No. A-180805
G. Yet” Attorney of Record Antoine L. Freeman, J. D. right after October 14, 2009 was granted in addition to sanctions ruling in his favor his additional Motion to be removed as acting Attorney from this case dated November 13th 2009, after 2 years being the official acting Attorney of record but claiming, and representing before the Honorable 58th District Court Judge “Bob Wortham” that this was not the legal case at hand in court records after December 18th 2007 general denial filing.
H. “However” elementary material legal facts containing Attorney Antoine L. Freeman, J. D. “very own signature” and Bar No. 24058299 is materially present in Plaintiff Exhibit(s) (I) and (K) proving Attorney Antoine L. Freeman, J. D. was representing the Defendant(s) “Joyce M. Guy and Edward McCray” collectively with actual payment render and received for billing hours throughout the years of 2007, 2008 and October of 2009, up to the actual date of November 13th 2009 but previously made claims before the Honorable 58th District Court Judge “Bob Wortham” in Plaintiff exhibit (B) *Response to Plaintiff’s Motion for Sanctions dated 11th of September of 2009 his only “Attorney duties” was to Draft and file a general denial on December 18th 2007 in his Attorney capacities at this time frame with payment for such as a Attorney of Law for the State of Texas Bar. No. 24058299 on or about December 18th 2007 such general denial being official filed in Court records.
I. While Pro Se Plaintiff without any law degree already being completely robbed of his profession by the actions of the Defendant(s) in the stealing namely of all of the Plaintiff Construction tools, inflicting real Hardship in this act alone
J. (Now) Plaintiff being giving a additional 100% unfair disadvantage by a “Thug Rouge” Lic# Attorney of Law in and for The State of Texas, and his Bogus counsel of law professional degree representation before the “Honorable 58th District Court Judge “Bob Wortham” in Jefferson County Texas to wit:
K. Said Attorney of record Antoine L. Freeman, J. D. did in all facts aid in hiding the Defendant(s) Collectively Material Facts of Construction Corruption of Hurricane Damages funds at 3 counts, Fraud on Insurance Monies at 3 counts, and Fraud of FEMA at 1 count, while further aiding through the Court discovery records process further theft of the Plaintiff Property namely all of Plaintiff Construction tools and further aids in all acts as described in Plaintiff Complaint filed in the records before the Honorable Court against the described Defendant(s)
L. In order that this “bogus rouge” Attorney of Law Antoine L. Freeman, J. D. “legal commitment” was to being paid in his official capacity before the “Honorable 58th District Court” and The State of Texas” to hide such “Major Grand thievery” commitment(s) of the Defendants collectively from December 18th 2007 to October 14, 2009 as described by all of the Plaintiff Exhibit(s) (I) and (K) “Request for Admissions” pursuant to Rule 198 of the Texas Rules of Civil Procedure and Plaintiff First set of Interrogatories” pursuant to 197 of the Texas Rules of Civil Procedure both being dated on October 14, 2009 and there (Now) official filing herein this undersigned date before the Honorable 58th District Court of Jefferson County Texas
M. Attorney of Record Antoine L. Freeman, J. D. being fully committed to this “actual physical constructive fraud” of The State of Texas Jefferson County Court records and actual physical constructive fraud in conspire against the Rules of Civil procedures as warrant by Pro Se Plaintiff Motion for sanctions as Attorney of record actual physical constructive fraud for this cause No. A-180805 to conspire to do the “Same Scheme of Crooked things” in his no less legal “attorney capacity” in and for the State of Texas on the full benefit package and behalf of the described Defendant(s) “Joyce M. Guy” and Edward McCray full legal behalf to achieve wrongfully civil advantages against the Plaintiff to commit continue collectively fraud of court records, while producing many bald face lie’s before a Honorable Court Judge Namely “Judge Bob Wortham”
N. And all of Court records for docket No. A-180805 with intent of sleight of hand document deception and derailment of the Plaintiff civil claim completely at that time frame described now again before the 58th District Court in Jefferson County Texas while defendant(s) doing such thievery in the past and now continue doing the same by through their acting “legal capacity status” of Professional “Attorney of Record” Namely Antoine L. Freeman, J. D. Texas Bar No. 24058299. As this Civil Action being fully investigated and prosecuted by Pro Se Plaintiff herein and now all evidence of support are official exhibit(s) and filed within the “Jefferson County Texas” court records.
“The Defendant(s) By and through their Attorney of record Antoine L. Freeman, J.D. Texas Bar No. 24058299 was in fact served Plaintiff Request for Admissions propounded by Louis Charles Hamilton II Pro Se Plaintiff herein pursuant to rule 198 of the Texas Rules of Civil Procedure.
Filed herein as Plaintiff exhibit (K) before the “Honorable Court”.
Providing, and legally well documented additional proof with all of the court records, exhibit(s) and files herein cause No. A-180805
Thus 100% Proving the Following official legal material facts before any “Honorable Court” of Law in and for The State of Texas as follows:
1. Attorney of Record Antoine L. Freeman, J. D. Texas Bar No. 24058299 was in fact full acting Attorney of record from dates of filing a General Denial December 18th 2007 as he claim in the records and doing so further acting as Attorney of record in filing a reply to Plaintiff (Interrogatories) already filed herein and dated October 14th 2009 as Exhibit (I)
2. To now include Attorney of record was in fact full acting legal capacity in filing a reply the Plaintiff Request for Admissions exhibit (K) and dated October 14, 2009 at this point the Plaintiff point out further that Attorney of record made a illegal bogus claim before The Honorable Judge “Bob Wortham that his only legal duties as described in Plaintiff exhibit (B) paragraph III. As Stated by said Attorney of Record Antoine L. Freeman, J. D. Texas Bar No. 24058299 follows:
3. At the time of Plaintiffs discovery request Defendant’s Attorney had not been retain by Defendants to represent their interest with regard to this lawsuit, Defendant, Joyce Guy, retain the services of Antoine Freeman for the purpose of writing a general denial so as to avoid default judgment being rendered against her.
4. The Honorable Court 58th District Court Judge Bob Wortham” ruled completely erroneously in favor of said Defendant’s Attorney of record Antoine L. Freeman, J. D. Against Pro Se Plaintiff request for sanctions being level and citied against said Attorney of record Antoine L. Freeman, J. D. Texas Bar No. 24058299
In official court docket No. A-180805 records when all of Plaintiff evidence filed herein support that a legal finding that Defendant’s Attorney did violated Rule 193.1 by failing to respond to Plaintiff’s discovery request up to almost 2 years while having full legal knowledge of such a discovery request was being pursued by the Pro Se Plaintiff
A. Attorney of Record Antoine L. Freeman, J. D. Was acting with physical fiduciary capacities as an Attorney of Law for the State of Texas Bar. No. 24058299 on or about December 18th 2007 and continue doing the same legal capacities being fully intact as acting Attorney of record and filed official court records with the Plaintiff as described in Plaintiff exhibit (I) and (K) dated October 14, 2009
B. The Attorney of record Antoine L. Freeman, J. D. then at this point took his civil wrongful lie, and false presentation filing before the 58th District Jefferson County Honorable Court Judge “Bob Wortham” stating he was not the Attorney of record and only filed a general denial with the Court and this was his only legal obligations, and this ended on December 18th 2007
C. To include as further evidence to support the Plaintiff cause for sanctions against said Attorney Antoine L. Freeman, J. D. the Plaintiff exhibit (A) Affidavit of Defendant “Joyce M. Guy” dated September 11, 2009 to support another bogus Defendant claim too, on behalf of her own Attorney of record Antoine L. Freeman, J. D. rouge acts to “avoid sanctions” in favor of the Plaintiff when both Defendant(s) collectively and Attorney of record Antoine L. Freeman, J. D. having full legal knowledge of such a discovery request being in place, and pursued from December 18th 2007 throughout October 14, 2009
D. Attorney of Records Antoine L. Freeman, J. D. maintain his only duties was Just filing a “General Denial” before the Honorable 58th District Court Judge “Bob Wortham” as his Attorney of record signature and Bar No. 24058299 is materially present on both Plaintiff exhibit (I) and (K) dated October 14, 2009 well beyond the filing of said General Denial on December 18th 2007
E. Namely official Court discovery documents devise in the form of “Request for Admissions” pursuant to Rule 198 of the Texas Rules of Civil Procedure and Plaintiff First set of Interrogatories” pursuant to 197 of the Texas Rules of Civil Procedure both being dated on October 14, 2009 proving the Pro Se Plaintiff was in pursuit of civil discovery well up to 2 years through Defendant(s) Attorney of Record, Antoine L. Freeman, J. D. with his signature and Bar No. 24058299 being materially present against said Attorney Claims he was only acting in December 18th 2007
F. As this Rouge Attorney did aid in criminally stalling against the Rules of Civil Procedures tactics with full payment to doing such actions by said defendant(s) to achieve this lawless civil act against the Pro Se Plaintiff rights to a Just cause of action before any court of Law within the State of Texas in Docket No. A-180805
G. Yet” Attorney of Record Antoine L. Freeman, J. D. right after October 14, 2009 was granted in addition to sanctions ruling in his favor his additional Motion to be removed as acting Attorney from this case dated November 13th 2009, after 2 years being the official acting Attorney of record but claiming, and representing before the Honorable 58th District Court Judge “Bob Wortham” that this was not the legal case at hand in court records after December 18th 2007 general denial filing.
H. “However” elementary material legal facts containing Attorney Antoine L. Freeman, J. D. “very own signature” and Bar No. 24058299 is materially present in Plaintiff Exhibit(s) (I) and (K) proving Attorney Antoine L. Freeman, J. D. was representing the Defendant(s) “Joyce M. Guy and Edward McCray” collectively with actual payment render and received for billing hours throughout the years of 2007, 2008 and October of 2009, up to the actual date of November 13th 2009 but previously made claims before the Honorable 58th District Court Judge “Bob Wortham” in Plaintiff exhibit (B) *Response to Plaintiff’s Motion for Sanctions dated 11th of September of 2009 his only “Attorney duties” was to Draft and file a general denial on December 18th 2007 in his Attorney capacities at this time frame with payment for such as a Attorney of Law for the State of Texas Bar. No. 24058299 on or about December 18th 2007 such general denial being official filed in Court records.
I. While Pro Se Plaintiff without any law degree already being completely robbed of his profession by the actions of the Defendant(s) in the stealing namely of all of the Plaintiff Construction tools, inflicting real Hardship in this act alone
J. (Now) Plaintiff being giving a additional 100% unfair disadvantage by a “Thug Rouge” Lic# Attorney of Law in and for The State of Texas, and his Bogus counsel of law professional degree representation before the “Honorable 58th District Court Judge “Bob Wortham” in Jefferson County Texas to wit:
K. Said Attorney of record Antoine L. Freeman, J. D. did in all facts aid in hiding the Defendant(s) Collectively Material Facts of Construction Corruption of Hurricane Damages funds at 3 counts, Fraud on Insurance Monies at 3 counts, and Fraud of FEMA at 1 count, while further aiding through the Court discovery records process further theft of the Plaintiff Property namely all of Plaintiff Construction tools and further aids in all acts as described in Plaintiff Complaint filed in the records before the Honorable Court against the described Defendant(s)
L. In order that this “bogus rouge” Attorney of Law Antoine L. Freeman, J. D. “legal commitment” was to being paid in his official capacity before the “Honorable 58th District Court” and The State of Texas” to hide such “Major Grand thievery” commitment(s) of the Defendants collectively from December 18th 2007 to October 14, 2009 as described by all of the Plaintiff Exhibit(s) (I) and (K) “Request for Admissions” pursuant to Rule 198 of the Texas Rules of Civil Procedure and Plaintiff First set of Interrogatories” pursuant to 197 of the Texas Rules of Civil Procedure both being dated on October 14, 2009 and there (Now) official filing herein this undersigned date before the Honorable 58th District Court of Jefferson County Texas
M. Attorney of Record Antoine L. Freeman, J. D. being fully committed to this “actual physical constructive fraud” of The State of Texas Jefferson County Court records and actual physical constructive fraud in conspire against the Rules of Civil procedures as warrant by Pro Se Plaintiff Motion for sanctions as Attorney of record actual physical constructive fraud for this cause No. A-180805 to conspire to do the “Same Scheme of Crooked things” in his no less legal “attorney capacity” in and for the State of Texas on the full benefit package and behalf of the described Defendant(s) “Joyce M. Guy” and Edward McCray full legal behalf to achieve wrongfully civil advantages against the Plaintiff to commit continue collectively fraud of court records, while producing many bald face lie’s before a Honorable Court Judge Namely “Judge Bob Wortham”
N. And all of Court records for docket No. A-180805 with intent of sleight of hand document deception and derailment of the Plaintiff civil claim completely at that time frame described now again before the 58th District Court in Jefferson County Texas while defendant(s) doing such thievery in the past and now continue doing the same by through their acting “legal capacity status” of Professional “Attorney of Record” Namely Antoine L. Freeman, J. D. Texas Bar No. 24058299. As this Civil Action being fully investigated and prosecuted by Pro Se Plaintiff herein and now all evidence of support are official exhibit(s) and filed within the “Jefferson County Texas” court records.
Wednesday, November 5, 2014
Sherlock Holmes Adventure of Lord Nigel Rupert Hollingberry Chapter 13
A Catalogue of selected “Chinese Recipes” with “China Emperor” permission was the most vulnerable valuable legal responsibility of instructions that came about
“Sherlock Holmes” Commanding advice, acceptance and being a delight tasty Prosperity Ending from being almost completely slaughter in a disastrous out number Ground Horse Battle,
To being now one of “China” official chief exported custom trades mark served even in all of vast “Liverpool” streets as being known
“Sweet and Sour Pork, SICHUAN-Style Fish Dishes, with likes of “Fried Rice” and “Stir fried Noodles”, “Meats”, and “Vegetables”, dancing about mouth-watering recipe
Proven now “Holmes” passion for life by offering the “Chinese Government”,
a well deserved “financial presentation” of the quite unique collection of “delicious recipes” being straightforward introduced even before the “Queen of England” and across the pond way with the “Americans”
Entertaining a New East-West Trade Pact, secret agreement Between “Great Britain”, and “China”
simply supplied by “elementary deuced suggestions” that the issues involving “Professor James Moriarty and his Dark Rumors “Quest” for the “Book of Leaves”
Untimely being better well spent from useless utter acts of “War” by a little flavor introductions, full treatments and entertaining of all of “China Ingredients” abroad...
With “step-by-step” instructions, being both beneficial beautifully entertaining and impress to the “many hungry stomachs” in all of England Countrymen spending pockets
and “food taste liking”
thus proving absolutely “financially stylish” for The Guangxu Emperor.
(Kuang-hsu Emperor; born Aisin-Gioro Zaitian (Aisin-Gioro Tsai-tien; Manchu: Aisin-Gioro Dzai-Tiyan),
Being the eleventh emperor of the Qing Dynasty, and the ninth Qing emperor to rule over China. His regnal name means "glorious succession".
“Sherlock Holmes” dictated further facts to our returning Traveling War Party that In March 1891, Guangxu received the foreign ministers to China at an audience in the "Pavilion of Purple Light,"
in what is now part of Zhongnanhai, repeating something that had also been done by his cousin, Tongzhi, in 1873.
That summer, under pressure from the foreign legations and in response to revolts in the Yangtze River valley that were targeting Christian missionaries, Guangxu issued an edict giving Christians imperial protection.
Guangxu, growing up, apparently had been instilled with the notion of the importance of frugality.
In this vein, in 1892, he tried to implement a series of draconian measures in order to reduce expenditures by the Imperial Household Department, which proved to be one of his few administrative successes
But, it was only a partial victory, as he nevertheless had to approve higher expenditures than he would have liked, in order to meet the needs of the empress dowager
And a simple influx in “Chinese immigration” conversions by their designed increase into England population and fresh “KUNG PAO” dishes among many tradition Chinese everyday cooking being quite vital to Peace.
As (I) “Doctor Watson” seeing it “Mrs. Martha Louise Hudson” shall be even further unsympathetic, purely provoked hostile “landlady” of our 221B Baker Street flat...
trying to manage and reproduce such dishes as “Chicken Chow Mein” at the sour bequest of “Sherlock Holmes”. As our lodging may soon come under real subjects of British pistol fire..!
To Be Continue By Louis Charles Hamilton II
“Sherlock Holmes” Commanding advice, acceptance and being a delight tasty Prosperity Ending from being almost completely slaughter in a disastrous out number Ground Horse Battle,
To being now one of “China” official chief exported custom trades mark served even in all of vast “Liverpool” streets as being known
“Sweet and Sour Pork, SICHUAN-Style Fish Dishes, with likes of “Fried Rice” and “Stir fried Noodles”, “Meats”, and “Vegetables”, dancing about mouth-watering recipe
Proven now “Holmes” passion for life by offering the “Chinese Government”,
a well deserved “financial presentation” of the quite unique collection of “delicious recipes” being straightforward introduced even before the “Queen of England” and across the pond way with the “Americans”
Entertaining a New East-West Trade Pact, secret agreement Between “Great Britain”, and “China”
simply supplied by “elementary deuced suggestions” that the issues involving “Professor James Moriarty and his Dark Rumors “Quest” for the “Book of Leaves”
Untimely being better well spent from useless utter acts of “War” by a little flavor introductions, full treatments and entertaining of all of “China Ingredients” abroad...
With “step-by-step” instructions, being both beneficial beautifully entertaining and impress to the “many hungry stomachs” in all of England Countrymen spending pockets
and “food taste liking”
thus proving absolutely “financially stylish” for The Guangxu Emperor.
(Kuang-hsu Emperor; born Aisin-Gioro Zaitian (Aisin-Gioro Tsai-tien; Manchu: Aisin-Gioro Dzai-Tiyan),
Being the eleventh emperor of the Qing Dynasty, and the ninth Qing emperor to rule over China. His regnal name means "glorious succession".
“Sherlock Holmes” dictated further facts to our returning Traveling War Party that In March 1891, Guangxu received the foreign ministers to China at an audience in the "Pavilion of Purple Light,"
in what is now part of Zhongnanhai, repeating something that had also been done by his cousin, Tongzhi, in 1873.
That summer, under pressure from the foreign legations and in response to revolts in the Yangtze River valley that were targeting Christian missionaries, Guangxu issued an edict giving Christians imperial protection.
Guangxu, growing up, apparently had been instilled with the notion of the importance of frugality.
In this vein, in 1892, he tried to implement a series of draconian measures in order to reduce expenditures by the Imperial Household Department, which proved to be one of his few administrative successes
But, it was only a partial victory, as he nevertheless had to approve higher expenditures than he would have liked, in order to meet the needs of the empress dowager
And a simple influx in “Chinese immigration” conversions by their designed increase into England population and fresh “KUNG PAO” dishes among many tradition Chinese everyday cooking being quite vital to Peace.
As (I) “Doctor Watson” seeing it “Mrs. Martha Louise Hudson” shall be even further unsympathetic, purely provoked hostile “landlady” of our 221B Baker Street flat...
trying to manage and reproduce such dishes as “Chicken Chow Mein” at the sour bequest of “Sherlock Holmes”. As our lodging may soon come under real subjects of British pistol fire..!
To Be Continue By Louis Charles Hamilton II
Louis Charles Hamilton II PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT No. A-180805
The Plaintiff Further State before “The Honorable Court”,
The Defendant was served a First Set of “Interrogatories” in this action, Pursuant to Rule 197 of the Texas Rules of Civil Procedure. By and through their Attorney of Record and filing such now
As Plaintiff Exhibit (I), Herein as The Plaintiff state Brief material facts that the Defendant(s) collectively answer to question 24 and 25 as follows:
(24) What was all of the terms and conditions of said contract in regards to repairs to the home located 448 Dequeen blvd. in Port Arthur, Texas
Answer
Plaintiff would repair damages done by Hurricane for a total price of $10,800 and Defendant would put $3,616 down towards the total price.
(25) Was the Contract forward to any insurance companies for payment to cover said construction cost?
Answer
Yes
The Plaintiff fully direct the Honorable Court attention to these facts
1. Defendant (Already) in facts received from said “Unknown Insurance” company in excess of approximately $6,500 dollars to fix said home and this money was squander and spent up from their Banking saving/checking account quite very long before The Defendants even enter into said Construction Contract with Plaintiff on 11/05/2007
Defendants were served Pursuant to Rule 194 Texas Rules of Civil Procedure. By and through their Attorney of Record Plaintiff request for Disclosure which Defendants at that time refused through their Attorney of record
To simply Identify Said “Unknown Insurance Company” which is very Material to this Action and was pursued long before “Plaintiff Interrogatories” was even served upon the Defendant(s) and Filed
Now as Plaintiff Exhibit (J) herein Plaintiff request for Disclosure Pursuant to rule 194
Defendant(s) did in fact received from this “Unknown Insurance Company” a balance of Monetary Funds in addition from what already was forwards to said Defendant(s) based upon the Plaintiff “Construction Contract” of $10,800.00,
Which the Defendants further supply and combine their “twisted scheme of things” was to physically use the Plaintiff Construction Contract of $10.800.00 to achieve such a “Cruel Criminal Scheme of things” against not only the Plaintiff
But also to include The “Unknown Insurance Company” for More Monies in addition to the amount already received from said “Unknown Insurance Company” for repairs as being described now
before the Honorable Court in PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT,
Notwithstanding “Facts” to the “Honorable Court”
“Yours Honor”
Never Ever, Ever, Was Any Actual Monies ever being spent on any Actual Physical Construction Repairs from any described storm damages in the past by any
Construction Contractors and or Sub-Contractors ever being performed at any time at the home located at 448 Dequeen Blvd. in Port Arthur Texas,
From any Hurricane damages by (Rita & Humberto) as such repair funds was indeed paid out to cover all extreme needed structural repairs in the Past for these “Trifling Defendant(s)”, making such claims against their “Insurance Companies, Construction Contractors in the Past, and to include now FEMA
As this same “Crooked Scheme of Things” was in fact executed more than once by the Defendants collectively in the past from another Hurricane (Rita) Damage of said 448 Dequeen Home,
long before the Plaintiff Construction Contract filed herein was even drafted for Repairs for Damages of “Hurricane Humberto” against another such Building Construction Contractor for (Rita) storm damages…
And as this same “Crooked Scheme of Things” was in fact executed in the past by the Defendants collectively on The Home Located at 5050 East 7th Street in Port Arthur Texas
Namely Defendant (Joyce Guy) owns Mother Home (Norma J. Guy) whom Defendant (Joyce Guy) had power of Attorney over her mother legal affairs at this time frame and used this to “Her” continued wrongful crooked advantages
To include such a “bogus rip off scheme of things” by the Defendant(s) collectively against all Hurricane damages of both said homes and “Unknown Insurance Companies” which moneys was in fact paid out for all needed repairs in full in the past storm history,
And defendants completely civil/criminally squander every nickel in a “Long History “ of “thievery” Scheme of things against “FEMA and Insurances Companies” following such “Natural Hurricane Damages” and Now the same Scheme of things involved against the Plaintiff herein and his personal property
(Construction tools),
And The Insurance Company, and FEMA, in which the Defendant “Home” At 448 Dequeen Blvd. in Port Arthur Texas was in facts completely demolished for Defendants crooked combine failures to supply any needed repairs (Ever) when all such funds being legally designed for such said Hurricane Repairs to said property located at 448 Dequeen Blvd. in Port Arthur Texas
As The Plaintiff States now Before “The Honorable Court” facts that a New Home being built at the cost of $76,000.00 on a Federal Grant.
As described in Plaintiff exhibit (I) First Set of “Interrogatories” in this action, question(s) 7-12
On Defendants collectively long continue corrupted history road of scams, rip off’s, thievery acts, as described herein fully being executed by Both Defendant Collectively.
All building materials as being described herein Plaintiff Exhibit (E) *Parker Lumber In Port Arthur Texas 2948 GulfWay Drive for the delivery of $2869.08 dollars in building materials for repairs to said 448 Dequeen home that was in fact delivery was refunded and or sold,
And not for any benefit of the said home storm damages but pure wrongful monetary Defendant(s) collectively financial gains.
The Defendant was served a First Set of “Interrogatories” in this action, Pursuant to Rule 197 of the Texas Rules of Civil Procedure. By and through their Attorney of Record and filing such now
As Plaintiff Exhibit (I), Herein as The Plaintiff state Brief material facts that the Defendant(s) collectively answer to question 24 and 25 as follows:
(24) What was all of the terms and conditions of said contract in regards to repairs to the home located 448 Dequeen blvd. in Port Arthur, Texas
Answer
Plaintiff would repair damages done by Hurricane for a total price of $10,800 and Defendant would put $3,616 down towards the total price.
(25) Was the Contract forward to any insurance companies for payment to cover said construction cost?
Answer
Yes
The Plaintiff fully direct the Honorable Court attention to these facts
1. Defendant (Already) in facts received from said “Unknown Insurance” company in excess of approximately $6,500 dollars to fix said home and this money was squander and spent up from their Banking saving/checking account quite very long before The Defendants even enter into said Construction Contract with Plaintiff on 11/05/2007
Defendants were served Pursuant to Rule 194 Texas Rules of Civil Procedure. By and through their Attorney of Record Plaintiff request for Disclosure which Defendants at that time refused through their Attorney of record
To simply Identify Said “Unknown Insurance Company” which is very Material to this Action and was pursued long before “Plaintiff Interrogatories” was even served upon the Defendant(s) and Filed
Now as Plaintiff Exhibit (J) herein Plaintiff request for Disclosure Pursuant to rule 194
Defendant(s) did in fact received from this “Unknown Insurance Company” a balance of Monetary Funds in addition from what already was forwards to said Defendant(s) based upon the Plaintiff “Construction Contract” of $10,800.00,
Which the Defendants further supply and combine their “twisted scheme of things” was to physically use the Plaintiff Construction Contract of $10.800.00 to achieve such a “Cruel Criminal Scheme of things” against not only the Plaintiff
But also to include The “Unknown Insurance Company” for More Monies in addition to the amount already received from said “Unknown Insurance Company” for repairs as being described now
before the Honorable Court in PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT,
Notwithstanding “Facts” to the “Honorable Court”
“Yours Honor”
Never Ever, Ever, Was Any Actual Monies ever being spent on any Actual Physical Construction Repairs from any described storm damages in the past by any
Construction Contractors and or Sub-Contractors ever being performed at any time at the home located at 448 Dequeen Blvd. in Port Arthur Texas,
From any Hurricane damages by (Rita & Humberto) as such repair funds was indeed paid out to cover all extreme needed structural repairs in the Past for these “Trifling Defendant(s)”, making such claims against their “Insurance Companies, Construction Contractors in the Past, and to include now FEMA
As this same “Crooked Scheme of Things” was in fact executed more than once by the Defendants collectively in the past from another Hurricane (Rita) Damage of said 448 Dequeen Home,
long before the Plaintiff Construction Contract filed herein was even drafted for Repairs for Damages of “Hurricane Humberto” against another such Building Construction Contractor for (Rita) storm damages…
And as this same “Crooked Scheme of Things” was in fact executed in the past by the Defendants collectively on The Home Located at 5050 East 7th Street in Port Arthur Texas
Namely Defendant (Joyce Guy) owns Mother Home (Norma J. Guy) whom Defendant (Joyce Guy) had power of Attorney over her mother legal affairs at this time frame and used this to “Her” continued wrongful crooked advantages
To include such a “bogus rip off scheme of things” by the Defendant(s) collectively against all Hurricane damages of both said homes and “Unknown Insurance Companies” which moneys was in fact paid out for all needed repairs in full in the past storm history,
And defendants completely civil/criminally squander every nickel in a “Long History “ of “thievery” Scheme of things against “FEMA and Insurances Companies” following such “Natural Hurricane Damages” and Now the same Scheme of things involved against the Plaintiff herein and his personal property
(Construction tools),
And The Insurance Company, and FEMA, in which the Defendant “Home” At 448 Dequeen Blvd. in Port Arthur Texas was in facts completely demolished for Defendants crooked combine failures to supply any needed repairs (Ever) when all such funds being legally designed for such said Hurricane Repairs to said property located at 448 Dequeen Blvd. in Port Arthur Texas
As The Plaintiff States now Before “The Honorable Court” facts that a New Home being built at the cost of $76,000.00 on a Federal Grant.
As described in Plaintiff exhibit (I) First Set of “Interrogatories” in this action, question(s) 7-12
On Defendants collectively long continue corrupted history road of scams, rip off’s, thievery acts, as described herein fully being executed by Both Defendant Collectively.
All building materials as being described herein Plaintiff Exhibit (E) *Parker Lumber In Port Arthur Texas 2948 GulfWay Drive for the delivery of $2869.08 dollars in building materials for repairs to said 448 Dequeen home that was in fact delivery was refunded and or sold,
And not for any benefit of the said home storm damages but pure wrongful monetary Defendant(s) collectively financial gains.
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