In The United States District Court
For The Eastern Division of Texas
Beaumont Division
Louis Charles Hamilton II
Pro Se Plaintiff
Vs.
Antoine L. Freeman J. D.
(Attorney at Law) Texas Bar No. 24058299
Defendant
Joyce M. Guy
Edward McCray
Co-Defendant(s)
Civil Complaint
Tuesday, November 18, 2014
Thursday, November 13, 2014
Plaintiff Louis Charles Hamilton II Motion For “Writ of Garnishment” and Brief in Support No. A-180805
No. A-180805
Louis
Charles Hamilton II
IN THE DISTRICT COURT
Plaintiff 58TH JUDICIAL DISTRICT
V.
Joyce Guy
& Edward McCray ET AL OF
JEFFERSON COUNTY, TEXAS
Defendants.
Plaintiff
Motion For “Writ of Garnishment”
Comes Now Before The Honorable 58th
District Court the Pro Se Plaintiff, Louis Charles Hamilton II, herein
Motion
before the Honorable Court, For “Writ of Garnishment” against the Defendant(s) Business
listed as Follows:
(1).
E and J Collectibles
(409) 330-048 448 DeQueen Blvd. in Port Arthur Texas
Information
about E & J Collectibles
E & J
Collectibles is in the Used Merchandise Stores business and this category has 2
companies in Port Arthur and a total number of businesses in Texas.
(2).
R J Can
Company 1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen
Blvd. in Port Arthur Texas 77640
(3).
G and G
Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas (Office)
located at 448 DeQueen Blvd. in Port Arthur Texas 77640
(4).
“Cars and
Pieces” Located in Beaumont Texas (Office) also located at 448 DeQueen Blvd. in
Port Arthur Texas 77640
And for just
cause Before the Honorable 58th District Court of Jefferson County Texas the
Pro Se Plaintiff herein declares, affirm and state as Follows:
I.
Defendant(s) “Joyce Guy and Edward McCray” having a Civil
dispute in regards to among other things:
“Actual
Damages” being owed to the Plaintiff in the Amount of $11,024.00 with full 6%
interest rate incurred since date of injury November 16th 2007
As described
in Plaintiff “Motion for Summary Judgment” with all of the exhibit(s),
documents, and records herein.
II.
Defendant(s) “Joyce Guy and Edward McCray” Continue to be in
the physical custody, control, and possession of the Property located at 448
DeQueen Blvd. in Port Arthur Texas being well within Jefferson County
Jurisdiction, Authority Namely this Honorable 58th District Court of Jefferson
County Texas.
As of this undersigned date in 2014 while Defendant(s)
collectively refusal before this Honorable 58th District Court Orders to
provide actual ownership of said disputed property in this Civil Matter Docket
No. A-180805 as of this undersigned date in the Month of November 2014.
III.
Defendant(s) “Joyce Guy and Edward McCray” mutable business E
and J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur Texas, J Can
Company 1807 East 7th Street Port Arthur Texas,
G and G
Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas and, “Cars
and Pieces” Located in Beaumont Texas (Office) also located at 448 DeQueen Blvd.
in Port Arthur Texas 77640
Are all in fact legally owned by the Defendant(s)
collectively herein as records do in fact “indicate” and on file with the “Jefferson
County clerk”
At this time
the Pro Se Plaintiff Louis Charles Hamilton II Respectfully caution the
“Honorable Judicial 58th District Court” to
take Calm raised eye brow calculations of "Judicial Notice" to the
Following Plaintiff Brief in Support of a “Writ of Garnishment” against the
Defendant(s) “Joyce Guy and Edward
McCray”
Plaintiff
Attached Brief in Support
1.
Defendant(s) “Joyce
Guy and Edward McCray” refused to file proof of the required discovery as
required in a “direct court order” which the Defendant(s) both were in fact in “full
attendance” before The Honorable Court when such an Order was so enforced by
the Court and stated on Court Records.
“Elementary
Simply” Defendant(s) “Joyce Guy and Edward McCray” collectively
thinking not only The Pro Se Plaintiff “Louis Charles Hamilton II herein but to
include but not limited to
The “Honorable 58th District Court” of
Jefferson County Texas to be at a sad state of being absolutely extra green-n- slow,
lacking “intelligence or common sense” and very dull to understand the cold,
scheming, cunning, calculating, dishonest, corrupted, double-dealing,
fraudulent “Grand Theft” history of the Defendant(s) involving among other
things,
Committed to many counts of “Insurance and FEMA” $$$ Heisting
which said discovery of the Pro Se Plaintiff Defendant(s) “Joyce Guy and Edward McCray” refusing the said court order would
in fact produce quite a “Outstanding” scary “Criminal and Civil extremely high
profile embarrassing situation and predicament of “prison penalties” both being
100% against the Peace and Dignity against The “State of Texas” and The “U.S.
Federal Government Justice Dept.” criminal codes.
To the Point this “civil action” herein is also known
to be Pro Se Plaintiff Louis Charles Hamilton II a/k/a Cmdr. Bluefin (USN)
“Sherlock
Holmes” Case of “The Dead Man Who Paid Taxes”
2.
Plaintiff further
state that on or about June/18/2009 a “Mechanics Lien” was filed in Jefferson
County Texas by: SWMJ Construction against Blk. 172 Lt. 1-2 own by Defendant(s)
“Joyce
Guy and Edward McCray” for primary “Hurricane “Rita”, “Ike” and “Humberto ” related
Construction storm damages,
“First American Title Insurance Co. 510 Bienville
Street, Floor 2r “Johanna” New Orleans LA 70130 being the Returnee
Which the Defendant(s) “Joyce Guy and Edward McCray”
Collectively refusal of said Court Order in this said
discovery documents ,involving full details, of the Construction Company and
the terms and condition of the contract for repairs, Funds paid out for
repairs, by all parties involved namely “First American Title Insurance Co.
3.
Plaintiff further
state that on or about November/16/2010 a “Mechanics Lien” was filed in
Jefferson County Texas by: DSW Homes on Property own by Defendant(s) “Joyce Guy and Edward McCray” BlK.4 Lt. 10 For primary
“Hurricane “Rita”, “Ike” and “Humberto ”
related Construction storm damages,
“First American Title Insurance Co. 510 Bienville
Street, Floor 2r “Johanna” New Orleans LA 70130 being the Returnee
4.
Plaintiff further
state before the “Honorable Court” that Defendant(s) “Joyce Guy
and Edward McCray” having “Deed” to the Property located in Port Arthur
Texas Lt. 1-2 Blk. 172 filed in Jefferson County Texas #2014012455 filed
04/22/2014
5.
Plaintiff further
state before the “Honorable Court” that Defendant(s) “Joyce Guy
and Edward McCray” having “Deed” to the Property located in Port Arthur
Texas Lt. 8 Blk. 210 filed in Jefferson County Texas #2007032430 filed
08/17/2007
6.
Plaintiff further
state before the “Honorable Court” that Defendant(s) “Joyce Guy
and Edward McCray” having “Deed” to the Property located in Port Arthur
Texas Lt. 11 Blk. 94 filed in Jefferson County Texas #2008022271 filed
06/20/2008
7.
Plaintiff further state before the
Honorable Court that Defendant(s) “Joyce Guy” having “Power of Attorney” over Norma Guy
Her dead mother and Now “Deed” to the Property located in Lakeview Texas Lt. 10
Blk. 4 filed in Jefferson County Texas #2010042042
8.
Plaintiff further
state before the Honorable Court that Defendant(s) “Joyce Guy” having “Deed” to the Property
located in Port Arthur Texas Lt. 8 Blk. 210 filed in Jefferson County Texas
#2007032430 filed 08/17/2007 real estate 1807 Rev. Ransom Howard Street Port
Texas Geographic ID 053400-000-237400-00000-5 “Commercial Vacant Lot”.
9.
Plaintiff further state
before the Honorable Court that Defendant(s) “Joyce Guy” having “Power of
Attorney” over “Norma Guy” Her dead mother “legal affairs” and Now upon
information and belief “Deed” to the Property located 5050 east 7th
street in Port Arthur Texas
Notwithstanding
Defendant(s) “Joyce Guy” having “Power of Attorney” over “Norma Guy”
Her dead mother legal affairs primary for
“Hurricane “Rita”, “Ike” and “Humberto ”
related Construction storm damages, to the Property located 5050 east 7th
street in Port Arthur Texas.
10.
Plaintiff further state
before the “Honorable Court” quite Judicially seriously that Defendant(s) “Joyce Guy
and Edward McCray” secretly conspire in full conclusion to keep hidden through their retained “Attorney of Record”
Antoine L. Freeman J. D. Texas Bar No.
24058299 that actually being filed in Jefferson County Clerk office on the June/18/2009
While This “Live”
Civil Action is ongoing since November 17th 2007 and a legal
discovery request already being made by The Pro Se Plaintiff “Louis Charles
Hamilton II” herein into the Records of Hurricane “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm
damages, and its involvement with
“First American Title Insurance Co.” 510 Bienville
Street, Floor 2r “Johanna” New Orleans LA 70130 being the Returnee and the
property located at 448 Dequeen Blvd. in Port Arthur Texas
Defendant(s) 100% Bold in being a flat out refused of
the Honorable 58th District Court “Court Order” to produce said Records
relating to “Hurricane “Rita”, “Ike” and
“Humberto ” related Construction storm damages, and its involvement with
the Defendant(s) “Joyce Guy and Edward
McCray”
Shockingly a legal transfer of the Defendant(s) “Joyce Guy and Edward McCray” collectively
property of 448 DeQueen blvd. Said
property Namely 448 DeQueen Blvd. in Port Arthur Texas 77640
Namely being Lot 1-2 Block 172 Jefferson County Texas
records #2009022762 filed on June/18/2009 was in fact transfer to the “Texas Department of Housing &
Community Affairs” and Attorney of Record Antoine L. Freeman J. D. Texas Bar
No. 24058299
Now boldly as
a Attorney of Law” lying to The “Honorable 58th District Court”
about his position as Attorney of
record for the Defendant(s) “Joyce Guy and Edward McCray” Docket No. A-180805
Antoine L.
Freeman J. D. Texas Bar No. 24058299 fully hidden the Pro Se Plaintiff herein Louis
Charles Hamilton II “Request for Admission”, Disclosure Documents and
“Interrogatories” request and legally refused to file a timely reply to them
for over 3 + years
11.
Plaintiff further
state before the “Honorable Court” Defendant(s) “Joyce Guy and Edward McCray” while this
civil action ongoing since November 17th 2007 and with their retained “Attorney of Record” Antoine L. Freeman J. D. Texas Bar No.
24058299 filed Financing statement on June /18/2009 with “Texas Department
of Housing & Community Affairs” Jefferson County Texas records #2009022763
12.
Plaintiff further
state before the “Honorable Court” Defendant(s) “Joyce Guy and Edward McCray” while this
civil action ongoing since November 17th 2007 Defendant(s) received a release of “Deed” dated on
July/22/2013 from the “Texas Department of Housing & Community Affairs”
Jefferson County Texas records #2013023794
13.
Plaintiff further
state before the “Honorable Court” Defendant(s) “Joyce Guy and Edward McCray” while this
civil action ongoing since November 17th 2007 Defendant(s) received a Termination from the “Texas
Department of Housing & Community Affairs” Jefferson County Texas records
#2013023794
448 DeQueen Blvd. “Property Deed” being in the
possession of the Defendant(s) “Joyce
Guy and Edward McCray”
As of
April/22/2014 which the “Texas Department
of Housing & Community Affairs”
housing Grant the Defendant(s) fraudulently obtain was in fact a “Federal Housing Grant” for “Texas
Department of Housing & Community Affairs”
As admitted by
the Defendant(s) through their “Attorney of Record” Antoine L. Freeman J. D. Texas Bar No. 24058299 in his reply to
Plaintiff First Set of Interrogatories” dated October 14th 2009
Exactly 4
months and 5 days from June/18/2009 to October 14th 2009 a knowing legal transfer of the Defendant(s) “Joyce Guy and Edward McCray”
collectively property of 448 DeQueen blvd. was in fact transfer to the “Texas Department of Housing &
Community Affairs” during this ongoing civil action
Meanwhile “Attorney of Record” making numerous false claiming
before the “Honorable Court” he was never was acting or having any involvement on
the behalf of the Defendant(s) “legal interest”
However Antoine
L. Freeman J. D. Texas Bar No. 24058299 being in the possession, custody and
control of the Pro Se Plaintiff “Request for Admission”, “Disclosure Documents”
And
“Interrogatories” now filed as Exhibit(s) attached to Pro Se Plaintiff Motion
for Final Summary Judgment filed by “Attorney
of Record” on signature Antoine L.
Freeman J. D. Texas Bar No. 24058299 proves in addition;
14.
Pro Se Plaintiff seeking Federal Action in The Eastern
District Court of Texas of “Racketeer
Influenced and Corrupt Organizations Act” (RICO) Hamilton v. Freeman et al Filed: February 2, 2010
as 1:2010cv00055 Plaintiff:
Louis Charles Hamilton, II Defendant: Antoine L Freeman, Edward McCray, Joyce
M Guy
Against the Defendant(s) “Joyce Guy and Edward McCray” and their Attorney of Record Antoine L.
Freeman J. D. Texas Bar No. 24058299
When said
Attorney of Record did in fact filed Court Document(s) herein the files of this
“civil action”
Claiming “among
other things” that Attorney of record did not violated Rule 193.1 as was only
retain to file a “General Denial” to this action (ONLY) “However Plaintiff
exhibit(s) “Request for Admission”, “Disclosure Documents” And
“Interrogatories” dictate before the “Honorable Court”
Attorney of Record conspire with Defendant(s) “Joyce
Guy and Edward McCray” to fully Withholding all discovery information from
2007-2010 when Attorney was release from Defendant(s) defense
To include Attorney
of Record Antoine L. Freeman J. D. Texas Bar No. 24058299 conspire with
Defendant(s) “Joyce Guy and Edward McCray”
Collective
outlandish criminal failure to supply any “materials facts” of the physical
property transfer of 448 DeQueen
Blvd. in Port Arthur Texas 77640
Namely being Lot 1-2 Block 172 Jefferson County Texas to the ownership of “Texas Department of Housing & Community
Affairs” during this ongoing civil action before the 58th District
Court of Jefferson County Texas Before the “Honorable Bob Wortham” Judicial
Watch.
Wednesday, November 12, 2014
Pro Se Plaintiff Louis Charles Hamilton II "Motion for Sanctions " No. A-180805 Jefferson County Texas 58th District Court
No. A-180805
IN THE DISTRICT COURT 58TH JUDICIAL DISTRICT OF JEFFERSON COUNTY, TEXAS
Louis Charles Hamilton II
Plaintiff
V.
Joyce Guy & Edward McCray ET AL
Defendants.
PLAINTIFF MOTION FOR SANCTIONS
Motion before the Honorable Court, For a Sanctions, being enforced against the Defendant(s) and for just cause the Pro Se Plaintiff state as Follows:
Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 to 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., in Port Arthur Texas and fully failing to adhere to an Honorable Court Order.
Defendant(s) already refused completely discovery devises being numerous requests of the Plaintiff threw the Crafty shady slights of hand acts and actions Attorney of Record “Antoine L. Freeman, J.D. Texas Bar No. 24058299
Fully Committing to the same fraud in conspiring with the Defendant(s) to with hold all records of to this civil action at any cost, considering the enforced criminal penalties in light of the many frauds being committed against Insurance companies, and FEMA claims for damages, as a result of this History of Hurricane Damages of related God Act’s as described by the Plaintiff his “Investigation Concluded”
That Elementary Indeed, the Defendant(s) are quite crafty in hustling numerous fake business, to include but not limited to Defendant(s) engaging illegal sales of a “Crack Industry” for which Defendant (Edward McCray) convicted twice of Federal Traffic of Crack Cokecaine, serving two separate prison terms,
Which Plaintiff also described before the Honorable Court Defendant(s) business of recycle of Cans, as resulting also raid by PAPD Dept. for the City of Port Arthur Texas engaging in “illegal scrap metal Industry”
While Defendant(s) “Joyce Guy” already committed for way to many uncountless years of a undocumented “gruesome medical business” taking care of the Poor elderly Senior Citizens not even having documented health Lic# or any kind with the State of Texas or any kind of Insurance on this medical business, or proper personal dealing with Poor elderly Senior Citizens.
Pro Se Plaintiff moves respectfully before the Honorable Court that these Crude Defendant(s) be dealt there on devise
To include having a total disregard for the Honorable Court, Plaintiff, Civil Rights, Peace and Dignity
And an Ordered into these records for sanctions being fully merit against the Defendant(s) “Joyce Guy” and “Edward McCray” for their collective refusal of the 58th District Court Orders attached herein with this Motion for sanctions against the Defendant(s).
Defendant(s) having stolen the Plaintiff lively hood of Construction tools’ in excess of $3093..00 dollars in their possession, custody and control over now a period of 7 years and counting.
Defendant and Defendant’s Attorney did in fact violated rule 193.1 by failing to respond to Plaintiff’s discovery request AS Plaintiff files all Proof attached to Plaintiff Motion for Final Summary Judgment
Defendant(s) continue to commit to the same, and refusal of a Court Order to submit to Plaintiff Discovery Request
Court Order was enforced on the 10th day of May 2010
Defendant(s) continual to commit to refusal of The Jefferson County 58th District Judicial “Court Order” being now 4 years and 6 Months and counting
The Defendant(s) Extreme “Wicked” and “Hostile” unwanted actions Directed at the Plaintiff “Civil Rights”, “Peace” and “Dignity” within Jefferson County Texas with actual damages being in excess of the Amount of $11,024.00 combine for Defendant(s) “Breach of Contract” with full 6% interest rate incurred since date of injury November 16th 2007
1.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court to grant the Plaintiff attached joining motion for sanctions filed herein with good “Merit” for the Discovery which was Order to be produced by The Court
Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 to 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., in Port Arthur Texas
Defendant(s) Further Order to be produced by The Court Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 to produce
Copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to damage caused by Hurricanes Rita, Humberto and Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas.
And apply civil sanctions against the Defendant(s) in excess of $1000.00 U.S. dollars per every year between the dates of 2010-2014 the Defendant(s) collectively being quite bold hostile disrespectful fleeing absconded completely from the civil actions as they were so required to produce such discovery via the Honorable Court Order of the 58th District Court of Jefferson County Texas.
2.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court sanctions amount being granted in favor of the Plaintiff in the amount of $4500.00 U.S. Dollars from dates of 10th day of May 2010 throughout December 17th 2014
As undersigned date being before “Oral Arguments/Hearing” on the 17th day of December 2014 at 8:30 before the Court.
3.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for any further, Just, proper until this Civil Dispute has reach a Full, Final and Complete Judgment of This Honorable 58th District Court of Jefferson County Texas in Favor of the Pro Se Plaintiff.
By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
IN THE DISTRICT COURT 58TH JUDICIAL DISTRICT OF JEFFERSON COUNTY, TEXAS
Louis Charles Hamilton II
Plaintiff
V.
Joyce Guy & Edward McCray ET AL
Defendants.
PLAINTIFF MOTION FOR SANCTIONS
Motion before the Honorable Court, For a Sanctions, being enforced against the Defendant(s) and for just cause the Pro Se Plaintiff state as Follows:
Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 to 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., in Port Arthur Texas and fully failing to adhere to an Honorable Court Order.
Defendant(s) already refused completely discovery devises being numerous requests of the Plaintiff threw the Crafty shady slights of hand acts and actions Attorney of Record “Antoine L. Freeman, J.D. Texas Bar No. 24058299
Fully Committing to the same fraud in conspiring with the Defendant(s) to with hold all records of to this civil action at any cost, considering the enforced criminal penalties in light of the many frauds being committed against Insurance companies, and FEMA claims for damages, as a result of this History of Hurricane Damages of related God Act’s as described by the Plaintiff his “Investigation Concluded”
That Elementary Indeed, the Defendant(s) are quite crafty in hustling numerous fake business, to include but not limited to Defendant(s) engaging illegal sales of a “Crack Industry” for which Defendant (Edward McCray) convicted twice of Federal Traffic of Crack Cokecaine, serving two separate prison terms,
Which Plaintiff also described before the Honorable Court Defendant(s) business of recycle of Cans, as resulting also raid by PAPD Dept. for the City of Port Arthur Texas engaging in “illegal scrap metal Industry”
While Defendant(s) “Joyce Guy” already committed for way to many uncountless years of a undocumented “gruesome medical business” taking care of the Poor elderly Senior Citizens not even having documented health Lic# or any kind with the State of Texas or any kind of Insurance on this medical business, or proper personal dealing with Poor elderly Senior Citizens.
Pro Se Plaintiff moves respectfully before the Honorable Court that these Crude Defendant(s) be dealt there on devise
To include having a total disregard for the Honorable Court, Plaintiff, Civil Rights, Peace and Dignity
And an Ordered into these records for sanctions being fully merit against the Defendant(s) “Joyce Guy” and “Edward McCray” for their collective refusal of the 58th District Court Orders attached herein with this Motion for sanctions against the Defendant(s).
Defendant(s) having stolen the Plaintiff lively hood of Construction tools’ in excess of $3093..00 dollars in their possession, custody and control over now a period of 7 years and counting.
Defendant and Defendant’s Attorney did in fact violated rule 193.1 by failing to respond to Plaintiff’s discovery request AS Plaintiff files all Proof attached to Plaintiff Motion for Final Summary Judgment
Defendant(s) continue to commit to the same, and refusal of a Court Order to submit to Plaintiff Discovery Request
Court Order was enforced on the 10th day of May 2010
Defendant(s) continual to commit to refusal of The Jefferson County 58th District Judicial “Court Order” being now 4 years and 6 Months and counting
The Defendant(s) Extreme “Wicked” and “Hostile” unwanted actions Directed at the Plaintiff “Civil Rights”, “Peace” and “Dignity” within Jefferson County Texas with actual damages being in excess of the Amount of $11,024.00 combine for Defendant(s) “Breach of Contract” with full 6% interest rate incurred since date of injury November 16th 2007
1.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court to grant the Plaintiff attached joining motion for sanctions filed herein with good “Merit” for the Discovery which was Order to be produced by The Court
Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 to 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., in Port Arthur Texas
Defendant(s) Further Order to be produced by The Court Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 to produce
Copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to damage caused by Hurricanes Rita, Humberto and Ike to the property located at 448 DeQueen Blvd. in Port Arthur, Texas.
And apply civil sanctions against the Defendant(s) in excess of $1000.00 U.S. dollars per every year between the dates of 2010-2014 the Defendant(s) collectively being quite bold hostile disrespectful fleeing absconded completely from the civil actions as they were so required to produce such discovery via the Honorable Court Order of the 58th District Court of Jefferson County Texas.
2.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court sanctions amount being granted in favor of the Plaintiff in the amount of $4500.00 U.S. Dollars from dates of 10th day of May 2010 throughout December 17th 2014
As undersigned date being before “Oral Arguments/Hearing” on the 17th day of December 2014 at 8:30 before the Court.
3.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for any further, Just, proper until this Civil Dispute has reach a Full, Final and Complete Judgment of This Honorable 58th District Court of Jefferson County Texas in Favor of the Pro Se Plaintiff.
By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
Monday, November 10, 2014
Pro Se Plaintiff Louis Charles Hamilton II "Writ of Execution" No. A-180805 Jefferson County Texas 58th District Court
No. A-180805
Louis Charles Hamilton II IN THE DISTRICT COURT
Plaintiff 58TH JUDICIAL DISTRICT
V.
Joyce Guy & Edward McCray ET AL OF JEFFERSON COUNTY, TEXAS
Defendants.
Writ of Execution
Comes Now Before the Honorable 58th District Court the Pro Se Plaintiff, Louis Charles Hamilton II,
Motion before the Honorable Court, For a Writ of Execution, being enforced on the Property located at 448 DeQueen Blvd. in Port Arthur Texas and for just cause the Pro Se Plaintiff state as Follows:
1. Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010
2. To 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., in Port Arthur Texas and fully failing to adhere to an Honorable Court Order. Said Court order attached as Plaintiff exhibit (A) herein
3. And actual real ownership of said Property is in fact being in a state of “unknown ownership” before the Plaintiff and This Honorable Court as proof was so required before the Honorable 58th District Court of Jefferson County Texas to be produced while a “civil dispute” is ongoing over said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas with the Pro Se Plaintiff “Louis Charles Hamilton II” herein
4. As a question of disputed Law Plaintiff raise now real concern further before this Honorable 58th District Court of actual real property ownership of said dwelling the possible sells of said Property while being in such Defendant(s) “Joyce Guy and Edward McCray” as of this undersigned date in 2014 Fully in Possession, Custody and Control of the said unidentified actual property and dwelling located at 448 DeQueen Blvd., in Port Arthur Texas with a Judgment being render against the Defendant(s) Collectively
5. To include but not limited to Defendant(s) “Joyce Guy and Edward McCray” having possible Possession, Custody, and Control over many other Properties located in Port Arthur Texas, Jefferson County
6. “Actual Damages” being owed to the Plaintiff from the Defendant(s) in the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007
7. Being as of 2008 rate incurred $661.44 total of $11,685.88
8. Being as of 2009 rate incurred $701.15 total of $12,387.03
9. Being as of 2010 rate incurred $743.22 total of $13,130.25
10. Being as of 2011 rate incurred $787.81 total of $13,918.06
11. Being as of 2012 rate incurred$835.08 total of $14,753.14
12. Being as of 2013 rate incurred$885.18 total of $15,638.32
13. Being as of 2014 November 17 rate incurred $938.29 total of $16,576.61
*This do not include any other monetary “Exemplary Awards” Granted to the Pr Se Plaintiff as Order for Final Judgment in this Civil Action against said Defendant(s) “Joyce Guy and Edward McCray” for their combine wrongfully actions, against the civil rights, peace and dignity of the Pro Se Plaintiff “Louis Charles Hamilton II herein.
Defendant(s) collectively seeks to “really physically abscond secretly” from the 58th District Court Jurisdiction Justice during a “ongoing civil” action pending before the Honorable Court against them,
To among other “slow simple minded dizzy bold reasoning” of the Defendant(s) collective behavior also include avoiding 100% being monetary accountable and responsible for their combine acts
and actions within the Jurisdiction of this civil action for the unlawful civil acts and actions as fully described against the Defendants “Joyce Guy and Edward McCray” in Complaint of the Pro Se
Plaintiff filed Cause No. A-180805
To include the “Actual Theft” of the Plaintiff entire Construction set of tools in excess of $$3093.00 Dollars Defendant(s) further seeks to fully abscond to avoid paying real damages for
such “Thievery” as described by the Plaintiff now ongoing over 7 years and 30 days to date as of November 17, 2014 Defendant(s) “Joyce Guy and Edward McCray” collectively being in possession of Plaintiff “Personal Property”
The “unknown ownership dwelling” Located at 448 DeQueen in Port Arthur Texas having a real “Property Lien” being now enforced against this said property herein by The Jefferson County Sheriffs Dept. as per Order by this Honorable Court for the covering the full amount of Judgment render of this Civil Action Docket No. A-180805 as required by the Pro Se Plaintiff.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court herein that 30 days after entry of said “Final Summary Judgment” against Defendant(s)
“Joyce Guy and Edward McCray” in favor of the Pro Se Plaintiff being fully recorded in the Court records at the “Clerk of Court” office of Jefferson County Texas
This “Writ of Execution” being fully enforced thereby 30 days after entry of said “Final Summary Judgment” for The Jefferson County Sherriff’s Office herein to physically seize the said unidentified ownership property and dwelling located at 448 Dequeen Blvd. in Port Arthur, Texas
To include “Jefferson County Sherriff’s Office to fully evict all unknown “Person and or Person(s)” having, possession, custody, and control over the dwelling being physically removed them from the Unidentified Ownership Property located at 448 Dequeen Blvd. in Port Arthur Texas
there after
Said “Writ of Execution” being enforced by the “Clerk of Court of “Jefferson County Texas directing The Jefferson County Sherriff’s Office hereby to commence fully in the “sale of said Property” Already having a “Property Lien Enforcement” against it in Favor of the Plaintiff for such sales
For payments of any and all such, Damages, Awards, and full interest incurred for full compensation of this “civil action” being paid to the Pro Se Plaintiff herein with interest incurred being still paid to Plaintiff at a rate of 6% on all Judgment until final sale of Unidentified Property and dwelling located at 448 DeQueen Blvd. in Port Arthur Texas is completed as Order by the Honorable Court. To
Include the said seize unidentified ownership property and dwelling located at 448 Dequeen Blvd. in Port Arthur, Texas
Being made to cover for full payments to The Jefferson County Sherriff’s render from such sells of undefined property and dwelling located at 448 Dequeen Blvd. in Port Arthur Texas and to cover all court cost of this civil action fully being complete,
And covering any and all Sherriff’s Office Cost derived in the Execution of this “Writ of Execution” and any other cost Sherriff’s Office incurred as required by the court during this civil action as directed by this Honorable Court.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for any further, Just, proper devise to secure Plaintiff
“Writ of Execution” Until this Civil Dispute has reach a Full, Final and Complete Judgment Before This Honorable 58th District Court of Jefferson County Texas
By,_______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
Louis Charles Hamilton II IN THE DISTRICT COURT
Plaintiff 58TH JUDICIAL DISTRICT
V.
Joyce Guy & Edward McCray ET AL OF JEFFERSON COUNTY, TEXAS
Defendants.
Writ of Execution
Comes Now Before the Honorable 58th District Court the Pro Se Plaintiff, Louis Charles Hamilton II,
Motion before the Honorable Court, For a Writ of Execution, being enforced on the Property located at 448 DeQueen Blvd. in Port Arthur Texas and for just cause the Pro Se Plaintiff state as Follows:
1. Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010
2. To 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., in Port Arthur Texas and fully failing to adhere to an Honorable Court Order. Said Court order attached as Plaintiff exhibit (A) herein
3. And actual real ownership of said Property is in fact being in a state of “unknown ownership” before the Plaintiff and This Honorable Court as proof was so required before the Honorable 58th District Court of Jefferson County Texas to be produced while a “civil dispute” is ongoing over said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas with the Pro Se Plaintiff “Louis Charles Hamilton II” herein
4. As a question of disputed Law Plaintiff raise now real concern further before this Honorable 58th District Court of actual real property ownership of said dwelling the possible sells of said Property while being in such Defendant(s) “Joyce Guy and Edward McCray” as of this undersigned date in 2014 Fully in Possession, Custody and Control of the said unidentified actual property and dwelling located at 448 DeQueen Blvd., in Port Arthur Texas with a Judgment being render against the Defendant(s) Collectively
5. To include but not limited to Defendant(s) “Joyce Guy and Edward McCray” having possible Possession, Custody, and Control over many other Properties located in Port Arthur Texas, Jefferson County
6. “Actual Damages” being owed to the Plaintiff from the Defendant(s) in the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007
7. Being as of 2008 rate incurred $661.44 total of $11,685.88
8. Being as of 2009 rate incurred $701.15 total of $12,387.03
9. Being as of 2010 rate incurred $743.22 total of $13,130.25
10. Being as of 2011 rate incurred $787.81 total of $13,918.06
11. Being as of 2012 rate incurred$835.08 total of $14,753.14
12. Being as of 2013 rate incurred$885.18 total of $15,638.32
13. Being as of 2014 November 17 rate incurred $938.29 total of $16,576.61
*This do not include any other monetary “Exemplary Awards” Granted to the Pr Se Plaintiff as Order for Final Judgment in this Civil Action against said Defendant(s) “Joyce Guy and Edward McCray” for their combine wrongfully actions, against the civil rights, peace and dignity of the Pro Se Plaintiff “Louis Charles Hamilton II herein.
Defendant(s) collectively seeks to “really physically abscond secretly” from the 58th District Court Jurisdiction Justice during a “ongoing civil” action pending before the Honorable Court against them,
To among other “slow simple minded dizzy bold reasoning” of the Defendant(s) collective behavior also include avoiding 100% being monetary accountable and responsible for their combine acts
and actions within the Jurisdiction of this civil action for the unlawful civil acts and actions as fully described against the Defendants “Joyce Guy and Edward McCray” in Complaint of the Pro Se
Plaintiff filed Cause No. A-180805
To include the “Actual Theft” of the Plaintiff entire Construction set of tools in excess of $$3093.00 Dollars Defendant(s) further seeks to fully abscond to avoid paying real damages for
such “Thievery” as described by the Plaintiff now ongoing over 7 years and 30 days to date as of November 17, 2014 Defendant(s) “Joyce Guy and Edward McCray” collectively being in possession of Plaintiff “Personal Property”
The “unknown ownership dwelling” Located at 448 DeQueen in Port Arthur Texas having a real “Property Lien” being now enforced against this said property herein by The Jefferson County Sheriffs Dept. as per Order by this Honorable Court for the covering the full amount of Judgment render of this Civil Action Docket No. A-180805 as required by the Pro Se Plaintiff.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court herein that 30 days after entry of said “Final Summary Judgment” against Defendant(s)
“Joyce Guy and Edward McCray” in favor of the Pro Se Plaintiff being fully recorded in the Court records at the “Clerk of Court” office of Jefferson County Texas
This “Writ of Execution” being fully enforced thereby 30 days after entry of said “Final Summary Judgment” for The Jefferson County Sherriff’s Office herein to physically seize the said unidentified ownership property and dwelling located at 448 Dequeen Blvd. in Port Arthur, Texas
To include “Jefferson County Sherriff’s Office to fully evict all unknown “Person and or Person(s)” having, possession, custody, and control over the dwelling being physically removed them from the Unidentified Ownership Property located at 448 Dequeen Blvd. in Port Arthur Texas
there after
Said “Writ of Execution” being enforced by the “Clerk of Court of “Jefferson County Texas directing The Jefferson County Sherriff’s Office hereby to commence fully in the “sale of said Property” Already having a “Property Lien Enforcement” against it in Favor of the Plaintiff for such sales
For payments of any and all such, Damages, Awards, and full interest incurred for full compensation of this “civil action” being paid to the Pro Se Plaintiff herein with interest incurred being still paid to Plaintiff at a rate of 6% on all Judgment until final sale of Unidentified Property and dwelling located at 448 DeQueen Blvd. in Port Arthur Texas is completed as Order by the Honorable Court. To
Include the said seize unidentified ownership property and dwelling located at 448 Dequeen Blvd. in Port Arthur, Texas
Being made to cover for full payments to The Jefferson County Sherriff’s render from such sells of undefined property and dwelling located at 448 Dequeen Blvd. in Port Arthur Texas and to cover all court cost of this civil action fully being complete,
And covering any and all Sherriff’s Office Cost derived in the Execution of this “Writ of Execution” and any other cost Sherriff’s Office incurred as required by the court during this civil action as directed by this Honorable Court.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for any further, Just, proper devise to secure Plaintiff
“Writ of Execution” Until this Civil Dispute has reach a Full, Final and Complete Judgment Before This Honorable 58th District Court of Jefferson County Texas
By,_______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
Louis Charles Hamilton II PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT No. A-180805 "Court Order"
No. A-180805
Louis Charles Hamilton II IN THE DISTRICT COURT
Plaintiff 58TH JUDICIAL DISTRICT
V.
Joyce Guy & Edward McCray ET AL OF JEFFERSON COUNTY, TEXAS
Defendants.
ORDER
Came on to be Considered Plaintiff’s Motion for Final Summary Judgment and the Court, after review of the files, records, exhibit(s), and hearing on this Final Judgment Motion before The Honorable Court Entertainment.
The 58th District Court of Jefferson County Texas being of the opinion that said “Final Summary Judgment Motion” is with merit and should be granted, it is therefore
1.
Ordered that Plaintiff’s Motion for Final Summary Judgment is Granted in Full and Made enter in to The Court Records of Docket No. A-180805
2.
Ordered that Plaintiff recovery damages for wrongful lost of tools in excess of $3093.00 dollars with full 6% interest rate incurred since date of injury from November 16th 2007
3.
Ordered that Plaintiff recovery damages for “Breach of Contract” at the rate of Profit Plaintiff would have incurred,
$7931.00 dollars subtracted from the $10,800.00 dollars Contract being Profit. Said damages and Profit is $7931.00 dollars with full 6% interest rate incurred since date of injury November 16th 2007
4.
Ordered that Plaintiff recovery damages from “Joyce Guy and Edward McCray” in the amount of “Actual Damages” to the Plaintiff for a total of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007 as derived from paragraph (2) and (3) above.
5.
Ordered that Plaintiff recovery damages suffrage of “Intentional Infliction of Emotional distress, “Loss of earning capacity and Hardship” incurred in the “Theft” of the Plaintiff Construction tools”,
And Judicial Awards of this 58th District Court of Jefferson County Texas further is granted to the Plaintiff “Louis Charles Hamilton II for “Exemplary Damages” from Defendant(s) “Joyce Guy and Edward McCray” in the Amount of _________.
6.
Ordered that Defendant(s), paying all filing fees and all “Court Cost” incurred in this Civil Matter.
Signed this _______day of __________________2014
__________________________________
PRESIDING JUDGE
Louis Charles Hamilton II IN THE DISTRICT COURT
Plaintiff 58TH JUDICIAL DISTRICT
V.
Joyce Guy & Edward McCray ET AL OF JEFFERSON COUNTY, TEXAS
Defendants.
ORDER
Came on to be Considered Plaintiff’s Motion for Final Summary Judgment and the Court, after review of the files, records, exhibit(s), and hearing on this Final Judgment Motion before The Honorable Court Entertainment.
The 58th District Court of Jefferson County Texas being of the opinion that said “Final Summary Judgment Motion” is with merit and should be granted, it is therefore
1.
Ordered that Plaintiff’s Motion for Final Summary Judgment is Granted in Full and Made enter in to The Court Records of Docket No. A-180805
2.
Ordered that Plaintiff recovery damages for wrongful lost of tools in excess of $3093.00 dollars with full 6% interest rate incurred since date of injury from November 16th 2007
3.
Ordered that Plaintiff recovery damages for “Breach of Contract” at the rate of Profit Plaintiff would have incurred,
$7931.00 dollars subtracted from the $10,800.00 dollars Contract being Profit. Said damages and Profit is $7931.00 dollars with full 6% interest rate incurred since date of injury November 16th 2007
4.
Ordered that Plaintiff recovery damages from “Joyce Guy and Edward McCray” in the amount of “Actual Damages” to the Plaintiff for a total of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007 as derived from paragraph (2) and (3) above.
5.
Ordered that Plaintiff recovery damages suffrage of “Intentional Infliction of Emotional distress, “Loss of earning capacity and Hardship” incurred in the “Theft” of the Plaintiff Construction tools”,
And Judicial Awards of this 58th District Court of Jefferson County Texas further is granted to the Plaintiff “Louis Charles Hamilton II for “Exemplary Damages” from Defendant(s) “Joyce Guy and Edward McCray” in the Amount of _________.
6.
Ordered that Defendant(s), paying all filing fees and all “Court Cost” incurred in this Civil Matter.
Signed this _______day of __________________2014
__________________________________
PRESIDING JUDGE
Friday, November 7, 2014
Louis Charles Hamilton II PLAINTIFF MOTION FOR PROPERTY LIEN No. A-180805 IN THE DISTRICT COURT OF jEFFERSON COUNTY TEXAS
No. A-180805
Louis Charles Hamilton II IN THE DISTRICT COURT
Plaintiff 58TH JUDICIAL DISTRICT
V.
Joyce Guy & Edward McCray ET AL OF JEFFERSON COUNTY, TEXAS
Defendants.
PLAINTIFF MOTION FOR PROPERTY LIEN
Comes Now Before The Honorable 58th District Court the Pro Se Plaintiff, Louis Charles Hamilton II,
Motion before the Honorable Court, For a Property Lien, being enforced on the Property located at 448 DeQueen Blvd. in Port Arthur Texas and for just cause the Pro Se Plaintiff state as Follows:
Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 to 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., in Port Arthur Texas and fully failing to adhere to an Honorable Court Order.
As described in Plaintiff Exhibit (L) attached herein to Plaintiff Motion for Final Summary Judgment. Defendant(s) “Joyce Guy and Edward McCray” quite secure in their combine all out refusal to except the Honorable Court Authority, in Producing such said documents by this “Honorable Court” being as physical document in Defendants’ possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., in Port Arthur Texas
And actual real ownership of said Property is in fact being in a state of unknown ownership while a civil dispute is ongoing over said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas and stands as a question of disputed Law now concern before this Honorable 58th District Court
Said described dwelling above herein is in a ongoing “Live” Civil Construction “Breach of Contract” dispute, among other cause of actions before this Honorable 58th District Court of Jefferson County Texas in docket No. A-180805 And as of this undersigned day in the month of November in the year of 2014 said Defendant “Joyce Guy and Edward McCray”
Remain faithful in their combine refusal to identify the actual ownership of the said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas as was required by this Honorable Court to do so, Defendant(s) already shown the Plaintiff he having no civil rights in this action in Jefferson County Texas and continue showing said Honorable 58th District Court of Jefferson County Texas having no real “Authority” at all Over said described Defendant(s) listed above namely “Joyce Guy and Edward McCray”
Further Defendant(s) collectively showing said Honorable 58th District Court of Jefferson County Texas having no real “Authority” over the Property located at 448 DeQueen Blvd. in Port Arthur Texas being well within Jefferson County Jurisdiction, Authority Namely this Honorable 58th District Court of Jefferson County Texas.
Defendant(s) “Joyce Guy and Edward McCray” having a Civil dispute in regards to among other things:
“Actual Damages” being owed to the Plaintiff in the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007
As described in Plaintiff “Motion for Summary Judgment” with all of the exhibit(s), documents, and records herein. This Property is in fact under the Control of said Defendant(s) at the time this dispute derived thereof and said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas
Defendant(s) “Joyce Guy and Edward McCray” Continue to be in the physical custody, control, and possession of the Property located at 448 DeQueen Blvd. in Port Arthur Texas being well within Jefferson County Jurisdiction, Authority Namely this Honorable 58th District Court of Jefferson County Texas.
As of this undersigned date in 2014 while Defendant(s) collectively refusal before this Honorable 58th District Court Orders to provide actual ownership of said disputed property in this Civil Matter
Docket No. A-180805 as of this undersigned date in the Month of November 2014.
Plaintiff Respectfully Moves before the Court that a Court Order being justly enforce against said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas is justified in light of The Defendant(s) “Wicked” “Hostile” unwanted actions Directed at the Plaintiff with actual damages being in excess of the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007
Further Plaintiff Respectfully Moves before the Court that a Court Order being justly enforce against said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas in light of The Defendant(s) Bold Refusal of this 58th District Court of Jefferson County Texas “Honorable Court Orders” dated the 10th day of May 2010 For Defendant(s) “Joyce Guy and Edward McCray” herein
To 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., in Port Arthur Texas as described in said Court Orders attached to the records of this Civil action and being filed as Plaintiff exhibit (L) in support of a issuance of a Final Summary Judgment in Favor of The Pro Se Plaintiff Louis Charles Hamilton II herein.
Plaintiff state Respectfully before The Honorable Court such an order is required to secure a proper judgment in this matter before this Honorable Court in favor of the Plaintiff, to include the Defendant(s) combine Numerous Crafty Fraudulent behavior as described by the Pro Se Plaintiff
And Investigated by the State of Texas in Exhibit(s) also files herein the records of this civil action, showing Plaintiff Judgment, damages, and compensation derived from the Defendant(s) actions is at risk if such a Court Order is not enforce further by the “Honorable 58th District Court” herein Jefferson County Texas against Defendant(s) “Joyce Guy and Edward McCray”.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court to grant the Plaintiff attached joining motion filed herein with good “Merit” to have the “Long Arm of The Jefferson County Texas State Law”
Namely “The Jefferson County Sherriff’s Office” on behalf of the “Honorable 58th District Court to fully enforce and place a “Property Lien” on the described unknown ownership Property located at 448 DeQueen Blvd. in Port Arthur Texas, in favor of the Pro Se Plaintiff herein Louis Charles Hamilton II in light of this ongoing civil litigation pending against said dwelling at the Hands of the described Defendant(s) herein.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court that Defendant(s) “Joyce Guy and Edward McCray” pay the full amount incurred by the “Honorable Court” and The Jefferson County Sheriff’s Office to execute PLAINTIFF MOTION FOR PROPERTY LIEN against said Defendant(s) herein and the enforcement of said Property Lien.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for any further, Just, proper devise to secure said dwelling until this Civil Dispute has reach a Full, Final and Complete Judgment of This Honorable 58th District Court of Jefferson County Texas
By,_______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
Louis Charles Hamilton II IN THE DISTRICT COURT
Plaintiff 58TH JUDICIAL DISTRICT
V.
Joyce Guy & Edward McCray ET AL OF JEFFERSON COUNTY, TEXAS
Defendants.
PLAINTIFF MOTION FOR PROPERTY LIEN
Comes Now Before The Honorable 58th District Court the Pro Se Plaintiff, Louis Charles Hamilton II,
Motion before the Honorable Court, For a Property Lien, being enforced on the Property located at 448 DeQueen Blvd. in Port Arthur Texas and for just cause the Pro Se Plaintiff state as Follows:
Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District Court of Jefferson County Texas on the 10th day of May 2010 to 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., in Port Arthur Texas and fully failing to adhere to an Honorable Court Order.
As described in Plaintiff Exhibit (L) attached herein to Plaintiff Motion for Final Summary Judgment. Defendant(s) “Joyce Guy and Edward McCray” quite secure in their combine all out refusal to except the Honorable Court Authority, in Producing such said documents by this “Honorable Court” being as physical document in Defendants’ possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., in Port Arthur Texas
And actual real ownership of said Property is in fact being in a state of unknown ownership while a civil dispute is ongoing over said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas and stands as a question of disputed Law now concern before this Honorable 58th District Court
Said described dwelling above herein is in a ongoing “Live” Civil Construction “Breach of Contract” dispute, among other cause of actions before this Honorable 58th District Court of Jefferson County Texas in docket No. A-180805 And as of this undersigned day in the month of November in the year of 2014 said Defendant “Joyce Guy and Edward McCray”
Remain faithful in their combine refusal to identify the actual ownership of the said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas as was required by this Honorable Court to do so, Defendant(s) already shown the Plaintiff he having no civil rights in this action in Jefferson County Texas and continue showing said Honorable 58th District Court of Jefferson County Texas having no real “Authority” at all Over said described Defendant(s) listed above namely “Joyce Guy and Edward McCray”
Further Defendant(s) collectively showing said Honorable 58th District Court of Jefferson County Texas having no real “Authority” over the Property located at 448 DeQueen Blvd. in Port Arthur Texas being well within Jefferson County Jurisdiction, Authority Namely this Honorable 58th District Court of Jefferson County Texas.
Defendant(s) “Joyce Guy and Edward McCray” having a Civil dispute in regards to among other things:
“Actual Damages” being owed to the Plaintiff in the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007
As described in Plaintiff “Motion for Summary Judgment” with all of the exhibit(s), documents, and records herein. This Property is in fact under the Control of said Defendant(s) at the time this dispute derived thereof and said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas
Defendant(s) “Joyce Guy and Edward McCray” Continue to be in the physical custody, control, and possession of the Property located at 448 DeQueen Blvd. in Port Arthur Texas being well within Jefferson County Jurisdiction, Authority Namely this Honorable 58th District Court of Jefferson County Texas.
As of this undersigned date in 2014 while Defendant(s) collectively refusal before this Honorable 58th District Court Orders to provide actual ownership of said disputed property in this Civil Matter
Docket No. A-180805 as of this undersigned date in the Month of November 2014.
Plaintiff Respectfully Moves before the Court that a Court Order being justly enforce against said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas is justified in light of The Defendant(s) “Wicked” “Hostile” unwanted actions Directed at the Plaintiff with actual damages being in excess of the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007
Further Plaintiff Respectfully Moves before the Court that a Court Order being justly enforce against said dwelling located at 448 DeQueen Blvd., in Port Arthur Texas in light of The Defendant(s) Bold Refusal of this 58th District Court of Jefferson County Texas “Honorable Court Orders” dated the 10th day of May 2010 For Defendant(s) “Joyce Guy and Edward McCray” herein
To 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., in Port Arthur Texas as described in said Court Orders attached to the records of this Civil action and being filed as Plaintiff exhibit (L) in support of a issuance of a Final Summary Judgment in Favor of The Pro Se Plaintiff Louis Charles Hamilton II herein.
Plaintiff state Respectfully before The Honorable Court such an order is required to secure a proper judgment in this matter before this Honorable Court in favor of the Plaintiff, to include the Defendant(s) combine Numerous Crafty Fraudulent behavior as described by the Pro Se Plaintiff
And Investigated by the State of Texas in Exhibit(s) also files herein the records of this civil action, showing Plaintiff Judgment, damages, and compensation derived from the Defendant(s) actions is at risk if such a Court Order is not enforce further by the “Honorable 58th District Court” herein Jefferson County Texas against Defendant(s) “Joyce Guy and Edward McCray”.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court to grant the Plaintiff attached joining motion filed herein with good “Merit” to have the “Long Arm of The Jefferson County Texas State Law”
Namely “The Jefferson County Sherriff’s Office” on behalf of the “Honorable 58th District Court to fully enforce and place a “Property Lien” on the described unknown ownership Property located at 448 DeQueen Blvd. in Port Arthur Texas, in favor of the Pro Se Plaintiff herein Louis Charles Hamilton II in light of this ongoing civil litigation pending against said dwelling at the Hands of the described Defendant(s) herein.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court that Defendant(s) “Joyce Guy and Edward McCray” pay the full amount incurred by the “Honorable Court” and The Jefferson County Sheriff’s Office to execute PLAINTIFF MOTION FOR PROPERTY LIEN against said Defendant(s) herein and the enforcement of said Property Lien.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for any further, Just, proper devise to secure said dwelling until this Civil Dispute has reach a Full, Final and Complete Judgment of This Honorable 58th District Court of Jefferson County Texas
By,_______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
Louis Charles Hamilton II PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT No. A-180805
1.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket No. A-180805, filed and Respectfully Moves before the Honorable 58th District Court of Jefferson County Texas His “Honorable Court” except, Plaintiff motion for Traditional Summary with all exhibit(s) A-1, and A-L,
being filed with the Clerk of Court Records of Jefferson County Texas, and The Honorable Court further being most favorable to the Pr Se Plaintiff claims as presented and supported, and the Honorable Court Being of the opinion Plaintiff Motion is with “merit” and should be granted into the Court Records.
2.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket No. A-180805, Further Respectfully Moves the Honorable 58th District Court of Jefferson County Texas His “Honorable Court” Plaintiff recovery damages for wrongful lost of tools in excess of $3093.00 dollars with full 6% interest rate incurred since date of injury from November 16th 2007
3.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket No. A-180805, Further Respectfully Moves the Honorable 58th District Court of Jefferson County Texas His “Honorable Court” Plaintiff recovery damages for “Breach of Contract” at the rate of Profit Plaintiff would have incurred,
Said being “Breach of Contract” incurred before any construction was started “However” Plaintiff purchased $2869.08 dollars in building materials as described in Plaintiff exhibit (E) to repair said home at 448 Dequeen Blvd. in Port Arthur Texas which the Plaintiff is entitled to $7931.00 dollars subtracted from the $10,800.00 dollars Contract being Profit.
4.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for said damages and Profit of $7931.00 dollars with full 6% interest rate incurred since date of injury November 16th 2007
5.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for damages in the amount of the Honorable Court Justice for the Plaintiff suffrage of “Intentional Infliction of Emotional distress,
“Loss of earning capacity and Hardship” incurred in the “Theft” of the Plaintiff Construction tools”, and extreme Judicial Awards further being granted to the Plaintiff “Louis Charles Hamilton II for “Exemplary Damages” being well enforced by this “Honorable Court”
against said Defendant(s) “Joyce Guy” and Edward McCray” for their combine extreme, dishonest, hostile, corrupted, actions, directed at the Plaintiff herein’,
and his personal property and assault upon the Plaintiff.
To include but not limited” to Defendant “Joyce Guy and Edward McCray”
Fraud of the Insurance Company scheme of things involving Pro Se Plaintiff $10,800.00 dollars construction contract in a
“Exemplary Damages” respectfully set by this Honorable Court with full 6% interest rate incurred since date of injury November 16th 2007
6.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court that Defendant(s) “Joyce Guy and Edward McCray” pay the amount of “Actual Damages” to the Plaintiff in the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007
To include Defendant(s) paying all filing fees and all “Court Cost” incurred in this Civil Matter.
7.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court to grant the Plaintiff attached joining motion filed herein with good “Merit” to have the “Long Arm of The Law” Namely
8.
“The Jefferson County Sherriff’s Office” to fully enforce and place a “Property Lien” on the described Property of 448 DeQueen Blvd. in Port Arthur Texas, in favor of the Pro Se Plaintiff herein Louis Charles Hamilton II which Defendant(s) “Joyce Guy and Edward McCray”
Was so Order By This Honorable 58th District Court of Jefferson County Texas to 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., and fully failing to adhere to an Honorable Court Order.
As described in Plaintiff Exhibit (L) attached herein.
Further providing The “Honorable 58th Judicial Court” a secured Judicial Honest biting well deserved Judgment being rendered in this quite seriously civil matter of the collectively Defendant(s) namely “Joyce Guy and Edward McCray” ill manner back woods buck wild country state of extreme,
“Hostile and Fraudulent” actions being most favorable to the “Laws of the State of Texas”,
Most favorable to the Pro Se Plaintiff Civil Rights, Damages and Compensation as described fully in the records herein this Civil Action.
9.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court
for any further, Just, proper, Damages and Awards The Honorable Court Deems Judicial in and For 58th District Court of Jefferson County Texas in Favor of The Pro Se Plaintiff herein.
By,_______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket No. A-180805, filed and Respectfully Moves before the Honorable 58th District Court of Jefferson County Texas His “Honorable Court” except, Plaintiff motion for Traditional Summary with all exhibit(s) A-1, and A-L,
being filed with the Clerk of Court Records of Jefferson County Texas, and The Honorable Court further being most favorable to the Pr Se Plaintiff claims as presented and supported, and the Honorable Court Being of the opinion Plaintiff Motion is with “merit” and should be granted into the Court Records.
2.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket No. A-180805, Further Respectfully Moves the Honorable 58th District Court of Jefferson County Texas His “Honorable Court” Plaintiff recovery damages for wrongful lost of tools in excess of $3093.00 dollars with full 6% interest rate incurred since date of injury from November 16th 2007
3.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket No. A-180805, Further Respectfully Moves the Honorable 58th District Court of Jefferson County Texas His “Honorable Court” Plaintiff recovery damages for “Breach of Contract” at the rate of Profit Plaintiff would have incurred,
Said being “Breach of Contract” incurred before any construction was started “However” Plaintiff purchased $2869.08 dollars in building materials as described in Plaintiff exhibit (E) to repair said home at 448 Dequeen Blvd. in Port Arthur Texas which the Plaintiff is entitled to $7931.00 dollars subtracted from the $10,800.00 dollars Contract being Profit.
4.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for said damages and Profit of $7931.00 dollars with full 6% interest rate incurred since date of injury November 16th 2007
5.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court for damages in the amount of the Honorable Court Justice for the Plaintiff suffrage of “Intentional Infliction of Emotional distress,
“Loss of earning capacity and Hardship” incurred in the “Theft” of the Plaintiff Construction tools”, and extreme Judicial Awards further being granted to the Plaintiff “Louis Charles Hamilton II for “Exemplary Damages” being well enforced by this “Honorable Court”
against said Defendant(s) “Joyce Guy” and Edward McCray” for their combine extreme, dishonest, hostile, corrupted, actions, directed at the Plaintiff herein’,
and his personal property and assault upon the Plaintiff.
To include but not limited” to Defendant “Joyce Guy and Edward McCray”
Fraud of the Insurance Company scheme of things involving Pro Se Plaintiff $10,800.00 dollars construction contract in a
“Exemplary Damages” respectfully set by this Honorable Court with full 6% interest rate incurred since date of injury November 16th 2007
6.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court that Defendant(s) “Joyce Guy and Edward McCray” pay the amount of “Actual Damages” to the Plaintiff in the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007
To include Defendant(s) paying all filing fees and all “Court Cost” incurred in this Civil Matter.
7.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court to grant the Plaintiff attached joining motion filed herein with good “Merit” to have the “Long Arm of The Law” Namely
8.
“The Jefferson County Sherriff’s Office” to fully enforce and place a “Property Lien” on the described Property of 448 DeQueen Blvd. in Port Arthur Texas, in favor of the Pro Se Plaintiff herein Louis Charles Hamilton II which Defendant(s) “Joyce Guy and Edward McCray”
Was so Order By This Honorable 58th District Court of Jefferson County Texas to 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., and fully failing to adhere to an Honorable Court Order.
As described in Plaintiff Exhibit (L) attached herein.
Further providing The “Honorable 58th Judicial Court” a secured Judicial Honest biting well deserved Judgment being rendered in this quite seriously civil matter of the collectively Defendant(s) namely “Joyce Guy and Edward McCray” ill manner back woods buck wild country state of extreme,
“Hostile and Fraudulent” actions being most favorable to the “Laws of the State of Texas”,
Most favorable to the Pro Se Plaintiff Civil Rights, Damages and Compensation as described fully in the records herein this Civil Action.
9.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The Honorable Court
for any further, Just, proper, Damages and Awards The Honorable Court Deems Judicial in and For 58th District Court of Jefferson County Texas in Favor of The Pro Se Plaintiff herein.
By,_______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496
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