"U.S. District Court" Louis Charles Hamilton II vs. Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 et al

38.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendants Antoine L. Freeman, J.D. “Attorney at Law” at the very start clearly in December of 2007  was engaging in Professional Skills of a Attorney at Law” in a “Legal” ongoing court room obligations to defend this civil case A-180805 against Pro Se Plaintiff

Defendant made Fraud upon the 58^th Judicial Court claiming in a document filed by defendant his only legal job was to draft a (Simple) General denial on behalf of the Defendants filed on December 18^th 2007, as such to avoid a default on behalf of Co-Defendant(s) by filing his original Answer and at that point his “Fiduciary Duty” to his clients and before the Court ended on that date December 18^th 2007 and was legally completely over,

Which this is not the case as Defendant (Attorney at Law) Fully scuttles all discovery materials received from Plaintiff in this civil matter from December 18^th 2007- November 13^th 2009 being the official day while in possession of Plaintiff request to disclose Pursuant to Rule 194 during the entire year of 2008-2009 Defendant Antoine L. Freeman, J.D. “Attorney at Law fail well within (30) days of this request, for the information or material described in Rule 194.2: by a period of over (2) years past the (30) days requirement to answer not only Pro Se Plaintiff “Request to Disclose” Pursuant to Rule 194,

Defendant (Attorney at Law) was also served Pursuant to Rule 198 of the Texas Rules of Civil Procedure Plaintiff Request for Admission(s) and Pursuant to Rule 197 of the Texas Rules of Civil Procedure Pro Se Plaintiff Set of Interrogatories all of which required a reply within (30) days of these request as Defendant a skilled (Attorney at Law) having full knowledge that a discovery phase process had commence in this civil legal matter refuse to submit any “response or reply” to all being described in paragraph (38) herein for a period of (1) year and (11) Months and Pro Se Plaintiff Filed “Motion for sanctions” against said Defendant (Attorney at Law) in violation of Rule 193.1 of the Texas Rules of Civil Procedure.

                                                39.

Defendant (Attorney at Law) in his defense of Plaintiff motion for Sanctions committed to the Following Fraudulent activities upon the 58^th Judicial District Court of Jefferson County Texas and all court records derive thereof.

a.     Engage in having Co-Defendant “Joyce M. Guy” Subscribed and Sworn a Affidavit in Support of Defendant (Attorney at Law) dated September 11, 2009

b.     File a Response to Plaintiff’s Motion For Sanctions also committed to the same act of having this document “Subscribed and Sworn on the 11^th day of September 2009

c.      Submitted all fact therein as being true before a Court of Law.

40.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Affidavit of Co-Defendant “Joyce M. Guy” admit Defendant (Attorney at Law) informed Co-Defendant between April 2^nd, 2008 and April 11^th, 2008 about Pro Se Plaintiff “Discovery Request” providing proof that Defendant (Attorney at Law) was in fact in possession, custody, and control of said discovery request while representing to the “Honorable Court” this was not the case.

                                                41.

Defendant (Attorney at Law) herein did not file any notice with the Pro Se Plaintiff or the District Court of Jefferson County Texas that he was not representing the legal interest of the Co-Defendant(s) “Joyce Guy and Edward McCray”, there after filing “the original answer” with the District Court back in December 18^th of 2007 when Defendant (Attorney at Law) herein in fact stating having Pro Se Plaintiff Discovery in Defendant own Affidavit being in his possession as of April 2^nd, 2008.

                                                42.

 Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant (Attorney at Law) herein stated to the Honorable 58^th Judicial District Court also, that his only duty was to file a original general denial (only) and this was what his “Legal” services as a Attorney in this matter was only retain for in his defense for Sanctions against him as described herein this complaint.,”

“However” Pro Se Plaintiff States”, “Affirm” and “Declare” and further maintain that Defendant Antoine L. Freeman J. D. “Attorney at Law” Texas Bar No. 24058299 did in fact make a court appearance in a hearing the Pro Se “set” before the Honorable 58^th District Court

Pro Se Plaintiff also filed a (TRO) “Temporary Restraining Order” in this same civil matter A-180805 against Co-Defendant “Joyce M. Guy” to protect her own “Mother” Norma Guy, and the resident living in that dwelling whom Co-Defendant (Guy) having “Power of Attorney” Over her Mother Legal Affairs, filed in Jefferson County #2010042042 at which during this same time frame Co-Defendant having process the same scheme and scam of things regarding Insurance and FEMA fraud of the property of 5050 East 7^th street in Port Arthur Texas being Norma Guy Home Mother of the Co-Defendant (Guy).

                                                43.

Defendant (Attorney at Law) made another court appearance and argued this issue of a (TRO) alone before the Honorable Judge Bob Wortham, and at no time was Defendant not acting in the capacity as “Attorney of Record” from the time of filing his notice of counsel until Defendant (Attorney at Law) filed Motion to withdraw as Attorney of Record. 

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant (Attorney at Law) herein sat on Pro Se Plaintiff entire Discovery Request in excess of 16 Months and refuse to file a reply, file any type notice with the court during this 16 Months time period while Texas Rules of Civil Procedure require

Defendant a professional Attorney at Law Adhere to local rules of the Court System and reply within (30) days not on a time table of (16) later after service of Said Discovery request by Pro Se Plaintiff Louis Charles Hamilton II.

                                                44.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant (Attorney at Law) herein, further state Defendant then took a even bolder set in “Obstruction of Justice” in that after (16) of scuttling Pro Se Plaintiff Discovery request to further Hide all of the corruption going on at present time in the destruction of the old home and the new one being built, during this ongoing Civil Suit and all of the inquiries being made by the Pro Se Plaintiff regarding Fraud relating to Insurance Companies Former Contractors, and Hurricane “Rita”, “Ike” and “Humberto”.

Defendant (Attorney at Law) herein provided further Fraud upon the Court in Fraudulent Information in the Interrogatories, and Never Investigated the circumstances of the questions being raised surrounding the “Theft” of The Pro Se Plaintiff Construction Tools by the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”,

 Defendant (Attorney at Law) completely cover up the Co-Defendant(s) collective wrong doings from the Honorable Court per Pro Se Plaintiff Discovery Request being scuttled for (16) months time frame as being described in paragraph (43) above.

                                                45.

 Defendant (Attorney at Law) made as if no Construction tools where ever on the property of the Pro Se Plaintiff being complain of

 To include Defendant (Attorney at Law) supply false answer(s) in the same Interrogatories that the Co-Defendant “Edward McCray” never even meeting the Pro Se Plaintiff Step Father (Lewis Garza) whom actually help delivery all of Pro Se Plaintiff said in excess of $3000.00 U.S. Dollars in construction tools to the dwelling in his Truck to the Home of The Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” on November 16^th 2007. Defendant (Attorney at Law) did not Investigate any of these facts nor was he ever even concern to attempt to investigate into the issues of the were about of Pro Se Plaintiff Construction tools.

                                                45.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” after Defendant (Attorney at Law) was officially no longer “Attorney of record” of the Civil action in Texas State Court from the time frame of December 18^th 2007 – filing General Denial to November 13^th 2009 when Defendant (Attorney at Law) filed with the Clerk of Court of Jefferson County Texas a Motion for Withdrawal of Counsel

The Co-Defendant “Joyce M. Guy and Edward McCray” continue to refuse to turn over said “Discovery Request” of the Pro Se Plaintiff

 To the point a Court Order of the 58^th Judicial District Court was obtain and enforced as Follows:

                                                46.

Ordered that Co-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

                                                47.

Ordered that Co-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 the damages caused by Hurricanes Rita, Humberto and Ike to the Property located at 448 DeQueen Blvd. in Port Arthur, Texas.

As so Ordered on the 10^th day of May 2010 by the 58^th Judicial District Court of Jefferson County Texas filed at 11:46 am.

                                                48.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” that Co-Defendants “Joyce Guy and Edward McCray” remain in Hostile abscond scuttle refusal of the Honorable Court Order as of the undersigned date in the Month of November 2014 of this Complaint being refilled in U.S. District Court.

                                                49.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” because of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 acting in his skilled profession to fraud the court and belittle the Pro Se Plaintiff and his discovery request for a period in excess of 16 months in possession thereof

To include Defendant (Attorney at Law) herein unethical commitment to conspire further under the disguise of “Attorney/Client” privileges. Work Product doctrine, and all Communications thereof being secrete between the Defendant (Attorney at Law) and the Co-Defendant(s) “Joyce Guy and Edward McCray”

To the point such Fraud commits by the Defendant (Attorney at Law) on the Jefferson County 58^th Judicial District Court completely forced the Pro Se Plaintiff to be at an extreme “civil disadvantage” in the ongoing court proceeding in the time frame of 2007-2009 and present in 2014 throughout 2015

Based solely upon Defendant (Attorney at Law) Rouge (RICO) “obstruction of Justice” among other things being fully professional hire “Legal Gun” knowledge thereof to scuttle, omit, delay and fraudulently mishandling required duties to supply a honest, required respond to all of Pro Se Plaintiff discovery request in a timely fashion, within the (16) months being in possession, custody and control of said Pro Se Plaintiff Discovery request.

                                                 50.

 Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299  retainer fees was solely paid to keep the Co-Defendant(s) numerous discover fraud by the Pro Se Plaintiff absolutely 100% top secret from the 58^th Judicial Court”

while the other newer $76,000.00 U.S. Dollars “scheme of things” being in current play and  process to now a ongoing (RICO) fraud the Co-Defendant(s) concocted involving Fraud (Now) The “Texas Department of Housing & Community Affairs” issuance of a “Housing Grant” in favor for the Co- Defendant(s) “Joyce Guy and Edward McCray”

All of which in fact being fraudulently obtain from “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs” while the civil suit is “Live” and pending” which Co-Defendant(s) conspire to keep this under wraps from any financial setback glitches being fully caused by The Pro Se Plaintiff bring this additional Fraudulent activities before The Honorable Court well deserved attention.

                                                51.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 in his History of being a Skilled “Attorney at Law” in and for the State of Texas

“Never” once scuttle, hide and thereof flat out being in refusal in the filing of a timely Discovery request for a period exceeding over (30) days against any Attorney, Law Firm or other Pro Se (Litigant)

In comparison to the double dealing, 100% skilled rouge super late filing reply to Pro Se Plaintiff numerous Discovery request being late in excess of (16) months and absolutely 100% in full violation of Texas Rules of Civil Procedures 193.1 All of which Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” solely done by Defendant (Attorney at Law) (Only) to conspire in the illegal (RICO) aid to hide all of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray”  many corrupted Business Enterprises endeavors,

Mutable Counts of Fraudulent activities involving Hurricane “Rita”, “Ike” and Humberto” Monetary rip off scams against FEMA, Building Contractors estimate and invoices and Home Owner Insurances Companies repair funds

Couple with the (Now) live ongoing new 2009 fraud activities of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray” involving “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs” in excess of $76,000.00 U.S. Dollars

                                                52.

 Defendant (Attorney at Law) herein known lying with a consciousness mind and disregard for the consequences for his actions in the “capacity as an Attorney of Law”, Antoine L. Freeman J. D.  conspire to continue to use his legal lawyer skills” in the full “aid and abetting”, and commitment to “Obstruction of Justice” in the capacity of a Attorney at Law forthwith in providing his own numerous Attorney fraud legal commitment upon the 58^th Judicial District of Court of Jefferson County Texas, the Court records thereof as being fully described in this U.S. District Court Complaint.

 And being in full criminal (RICO) concert, collusion, corruption and conspiracies thereof for all monetary fraudulent assets gains of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray”

 Both being “ill-gotten pirate loot” from the “past” Hurricanes Seasons “Rita”, Ike” and “Humberto” and “present” pirate loot” “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs” in excess of $76,000.00 U.S. Dollars of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray”

                                                53.

Fully affecting the Pro Se Plaintiff (Life) with “among other things” cause of action for “actual damages” being in excess of $336,000.00 U.S. Dollars in “lost wages” from 2007 – 2014 and “actual damages” in excess of “3093.00 U.S. Dollars in all of the Pro Se Plaintiff Construction tools causing the Plaintiff undue unwanted extreme hardship, infliction of emotional distress and anguish  in the  “Theft of Pro Se  Construction Profession” for a ongoing time frame over (7) years and still counting well into 2015 The Texas State Civil Suit is “Live” and ongoing due in large part to Defendant (Attorney at Law) herein

Numerous (RICO) “acts and activities” to commit “among other things” a ,complete assault of “Obstruction of Justice” and “Fraud upon a Court” in the 58^th Judicial District Court of Jefferson County Texas

In a Suit in “Common Law” for the rouge disgrace benefit of his skilled profession as a “Attorney of Law” to skillfully cover up a Co-Defendant(s) “Joy M. Guy” and “Edward McCray” clients “Long Bogus Quite Profitable Crooked Road of “Fraudulent History” being described fully herein and direct against The civil rights, peace and dignity of the Pro Se Plaintiff herein. 

 

 

"U.S. District Court" Louis Charles Hamilton II vs. Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 et al

                                                22.

Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 filed an original answer on behalf of the Co-Defendant(s) and then later making false discovery procedure claiming to the Honorable Judge Bob Wortham on or about 11^th day of September 2009 in a reply motion for sanction against said “Attorney” for violations of Texas Rules of Civil Procedure 193.1 by failing to respond to Pro Se Plaintiff’s Discovery Request

” Defendant Antoine L. Freeman J. D. Attorney at Law Texas further making factual material claims in court filed documents and before the Honorable Court in a hearing his only “Legal obligation” was to provide Co-Defendant(s) “Joyce Guy and Edward McCray” involving in this civil case A-180805 in Jefferson County Texas was to draft a (Simple) General denial on behalf of the described “Co-Defendants” behalf being filed on December 18^th 2007 in Jefferson County Clerk of Court records in order Co-Defendant(s) collectively do not be filed for a default Judgment against them for the Civil Complaint.

                                                23.

Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 told a bald face “Lie” to “Judge Bob Wortham” to avoid “monetary sanctions” against him for his (Indeed) violate of Rule 193.1

 Defendant in his capacities as a “Attorney of Law” no less “kept secretly” in his possession, custody and Control for a period of over (3) years while being actual the “Attorney of Record” in this civil matter safely Hidden from the “Honorable 58^th Judicial Court” proceeding

All of Pro Se Plaintiff first round of Chief Discovery request document(s) Request for Disclosure and “Request for Admissions” pursuant to Rule 198 of the Texas Rules of Civil Procedure to include Pro Se Plaintiff First set of Interrogatories” pursuant to 197 of the Texas Rules of Civil Procedure at which Defendant Antoine L. Freeman J. D. “Attorney at Law” Texas Bar No. 24058299 finally admitted to the Pro Se Plaintiff (alone)

The “actual physical existences” after 3 years and counting Defendant “Attorney at Law” omitted of being in such possession, custody and control while keeping such discovery request of the Pro Se Plaintiff secretly hidden from the “Court Proceedings” Moreover” especially Hidden From “Judge Bob Wortham” Judicial studying of the civil case at hand before his Honorable Court proceeding

At which Defendant Antoine L. Freeman J. D. “Attorney at Law” providing proof of all discovery document and material facts derive thereof and their now existences being dated proof on or about October 14, 2009 when these discovery document(s) “Request for Admissions and “Interrogatories” among other legal documents was finally being place in the U.S. mail and forwarded back to the Pro Se Plaintiff herein who made the discovery request over 2 and ½ years ago.

                                                24.

Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 cleverly crafty abusing his “attorney/client privileges, all work doctrine documents derive thereof;

And all known communications between “Attorney and Client”

Namely Defendant Antoine L. Freeman J. D. and Co-Defendant(s) “Joyce Guy and Edward McCray” herein to “Grand style” deceive the “Honorable Court” from having any “Legal Knowledge Via Pro Se Plaintiff herein “direct discovery request” and  “Investigation” fully focus on among other things Co-Defendant(s) “Joyce Guy and Edward McCray”

 Collectively in the past did in fact submit numerous Hurricane relief damages claims being in the form of construction contractor’s estimates to their “Insurance Companies” and possibly FEMA for relief of damages caused by Hurricanes Rita, Humberto, and Ike for the property located at 448 DeQueen blvd. in Port Arthur, Texas.

To include Property located at 5050 east 7^th Street in Port Arthur Texas, and Property Located at Blk 4 Lot. 10 Lake View in Jefferson County Texas all own and in the possession, custody, and control of the Co-Defendant(s)

 As Pro Se Plaintiff making claims before the 58^th Judicial District Honorable Court of Co-Defendant(s) “Joyce Guy and Edward McCray” past fraudulent “practice and patterns” thereof after the corrupted hostile “acts and actions” directed at the Pro Se Plaintiff herein as being described in paragraph (17-24) above.

                                                25.

Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 having full prior knowledge that existence of a “property lien” was enforced by SWMJ Construction Inc. filed on June 18^th 2009 in Jefferson County Clerk Office

Being against Co-Defendant(s) “Joyce Guy and Edward McCray” as it was relating to “among other things” “Material Evidence” Pro Se Plaintiff sought history showing Co-Defendant(s) making other Fraudulently scheme of things involving monetary relief of damages caused by Hurricanes Rita, Humberto, and Ike for the property located at 448 DeQueen blvd. in Port Arthur, Texas. There after already ripping off the Pro Se Plaintiff in 2007 storm season.

                                                26.

Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 having a Profession eye on the civil damages this discovery would affect Defendant(s) presumed innocent standing before the Honorable Judge Bob Wortham conspire with “obstruction of Justice” to continue to commit to conceal this “material evidence” from the Plaintiff when it was required to be produce in Pro Se Plaintiff Discovery Request devise.

                                                27.

Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 also having “insider information and communications” with Co-Defendant(s) “Joyce Guy and Edward McCray” conspire further with “obstruction of Justice” to continue to commit to conceal this “material evidence” that Co-Defendant(s) “Joyce Guy and Edward McCray” was in fact in the legal process of having the old Home torn down while the ongoing civil actions was still pending before the 58^th District Court of Jefferson County Texas to include Co-Defendant(s) “Joyce Guy and Edward McCray”

Collectively having a “New Home” secretly being built at the cost of $76,000.00 U.S. Dollars on a “Federal Grant” kept 100% secret from the Pro Se Plaintiff Discovery and The State Court while this Civil Suit in common Law had commence in 2007 as was well ongoing out of control at this point under (RICO). 

As Defendant himself Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 confirm and described in Pro Se Plaintiff First Set of “Interrogatories” the “Texas Department of Housing & Community Affairs” issuance of a “Housing Grant” in favor for the Co- Defendant(s) “Joyce Guy and Edward McCray” all of which in fact fraudulently obtain being in fact a “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs”

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co-Defendant(s) herein making further fraudulent claims before said “Texas Department of Housing & Community Affairs” that Pro Se Plaintiff was the primary cause of damages to the old home derive thereof for Co- Defendant(s) “Joyce Guy and Edward McCray” needing a “New Home” based upon poor,

Unsatisfactory contractor “workmanships” and “craftsmanship” being committed by Pro Se Plaintiff Louis Charles Hamilton II herein for the $10,800.00 U.S. Dollars Contract already sub-mitted to previous “Insurance Company” by Co-Defendant(s) in regards to Hurricane Humberto storm related damages.

                                                28.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 having a Profession legal eye on the “civil damages” this Pro Se Plaintiff discovery request would affect Co- Defendant(s) “Joyce Guy and Edward McCray

Presumed innocent standing before the Honorable Judge Bob Wortham clear back in 2008 long before Co-Defendant(s) “Joyce Guy and Edward McCray further fraudulently obtain a “New Home” secretly being built at the cost of $76,000.00 on a Federal Grant Defendant Antoine L. Freeman J. D. Attorney at Law conspire further with “obstruction of Justice” to conceal the destruction of the old home And the new home being built

 Defendant Antoine L. Freeman J. D. Attorney at Law further conspire and work in concert to assure no delays ever being a factor in the construction of the New Home” Located at 448 DeQueen Blvd. in Port Arthur Texas would be primary cause if the “Honorable Judge” Bob Wortham, of 58^th Judicial District Court of Jefferson County Texas would in all facts and circumstances reach Pro Se Plaintiff discovery document(s) containing “Material Facts” of among other things while this ongoing civil suit still pending a “Property Lien” already previously in Forced against Co-Defendant(s) collectively as described in paragraph (25) above

 To include a “New Home” secretly being built under the noise of the Pro Se Plaintiff herein and the “Honorable Judge” Bob Wortham, during this pending civil action Docket No. A-180805 at the cost of $76,000.00 on a “Federal Grant” as the secretly destruction of the older home took place once being

“Official Dwelling” to this ongoing Civil Suit involving the dwelling in 2007 located at 448 DeQueen Blvd. in Port Arthur Texas, Now secretly destroyed in 2009 before the Honorable 58^th Judicial District Court of Jefferson County, Texas ongoing civil court case.

                                                29.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co-Defendant “Joyce Guy and Edward McCray” secretly filed on June 18^th 2009 transfer of property over to the “Texas Department of Housing & Community Affairs” at the Jefferson County Clerk Office File #2009022762 during this ongoing civil action with the Defendant collusion to keep all of this absolutely secretly claiming under

 “Attorney/Client Privileges”, Product of Work Doctrine and Communications made between Attorney and Client absent the fact this is very material facts in a ongoing civil suit against the Co-Defendant(s) collectively under the legal defense of Attorney at Law criminally withhold such discovery as request to release such favorable Document, Material facts, and circumstances.

                                                30.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co-Defendant “Joyce Guy and Edward McCray” secretly filed on June 18^th 2009 Fraudulent “Financing Statement” at the Jefferson County Clerk Office File #2009022763 to obtain from “Texas Department of Housing & Community Affairs” $76,000.00 on a “Federal Grant” as the secretly destruction of the older home took place during this ongoing “Civil Suit”

                                                31.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 having full knowledge of all this transfer of the Home, and the destruction of the older one and all circumstance involved thereof being secretly conspire further fraudulently in the capacitates of a “Attorney at Law” with the Co-Defendant(s)

To achieve the same fraudulently monetary objective(s) gain being $76,000.00 “New Home” on a “Federal Grant” shamefully submitted Before the “Texas Department of Housing & Community Affairs” by Co-Defendant(s) after already “Greedy Squandering” all of the Numerous Insurance Funding” from each previously Hurricane “Rita”, “Humberto”, and “IKE” related storm damages on the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 had a duty to disclose all material facts as described herein and regardless of his “Attorney/Client defense of the Co-Defendant(s)

Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 was obligated to conform with the Texas Rules of Civil procedures in Discovery phase of a Civil Suit in common law within the State of Texas

Regardless of it criminal/civil fall out affect being properly in placement upon the Co-Defendant numerous fraudulent acts and actions discovery of a shocking further investigation involving “among other things” the actual designed “Fraud of Contractors” related to “Insurance Company” Scams and scheme of things the Co-Defendant(s) monetary calculated and concocted.  

                                                32.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 at no time did the Defendant file any notice with the court from the time frame of December 18^th of 2007 throughout December 11^th 2009 request for “Motion For Withdrawal of Counsel” exactly 7 days shy of two years

 Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 was retain to commit to numerous fraudulent acts and actions involving withholding all discovery material during this entire (2) year time frame and shield all of Co-Defendant(s) mutable fraudulent indiscretions of Corrupted Illegal (RICO) Business dealing within Jefferson County Texas being instituted by the Co-Defendant(s) .

                                                33.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Pro Se Plaintiff herein because of the many “hostile” acts and actions direct at the Pro Se Plaintiff civil rights, peace and dignity by the Co-Defendant(s) herein

Pro Se Plaintiff conducted a Special Exclusive in-depth Investigation into the Co- Defendant(s) “Joyce Guy and Edward McCray” to provide the Honorable 58^th Judicial Court of Jefferson County Texas”,

Solid proof of the Co-Defendant(s) collective History of corrupted “pattern and practices” involving “fraudulent monetary scheme of things Nature” to” legally discovery” all of the following ongoing corrupted in design acts and in one primary case being a actual “Illegal Medical Enterprise” for the elderly disable senior citizens within in Jefferson County Texas

                                                34.

Co- 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 Co-Defendant(s) collectively herein as records do in fact “indicate” and on file with the “Jefferson County clerk”

                                                35.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” the Co-Defendant(s) “Joyce Guy and Edward McCray”, filed with the Jefferson County Clerk #2009022763 “Financing statement” to obtain the “Texas Department of Housing & Community Affairs” $76,000.00 on a “New Home Federal Grant”

“However” Co-Defendant(s) “Joyce M. Guy” omitted and refused to provide correctly all factual income detail in this “Financing Statement” of the Assumed Name Business 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

In which this is in facts and circumstances a “illegal medical business” for the disable elderly senior citizens of Jefferson County Texas has never had a HCSSA license on filed with the State of Texas nor was a HCSSA license ever attempted to be correctly filed with the State of Texas which all of this was ongoing from the dates of May 5^th1997 throughout January 7^th 2010 for a period of 13 years of “Earn Income” with cash being paid to all “employees” when it was order shut down by the State of Texas Department of Aging and Disability Services until a real licensed being obtain.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” on December 1^st of 2009 is when the (Pro Se Plaintiff) filed a formal complaint with “Texas Department of Aging and Disability Services” in regard to this “Illegal” Medical Business”  namely “G and G Service Company”

 P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas of Co-Defendant(s) “Joyce M. Guy” (Actually) this medical business operations of G and G Service Company being secretly conducted on a (Vacant Lot)  J

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” as a result of Pro Se Plaintiff “Investigation” Co-Defendant(s) “Joyce M. Guy” was order in Person as Pro Se Plaintiff was on his cell phone by the “State of Texas” “Texas Department of Aging and Disability Services” to shut down said “Illegal medical business” until a real HCSSA license is obtain with the State of Texas.

                                                36.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” at this time frame Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 was fully aware of the “Texas Department of Aging and Disability Services shutting down said “Illegal medical business”

“G and G Service Company” until a real HCSSA license is obtains with the State of Texas which Defendant Antoine L. Freeman J. D. “Attorney at Law” understood directly Pro Se Plaintiff himself being the direct cause for “Illegal medical business” G and G Service Company being closed against Co-Defendant(s) while this civil suit was ongoing in the 58^th Judicial District Court of Jefferson County Texas

Defendant (Attorney at Law) herein conspire further to protect the Co-Defendant(s) from any further civil/criminal fall outs there past history might dictate in Fraud scheme of things as described herein to the point Defendant conceal all of the Pro Se Plaintiff Discovery request document(s) throughout the years of 2007, 2008 and 2009 when Texas law of Civil procedure require a reply well within 30 days of receiving said discovery request.

Defendant (Attorney at Law) herein told “Judge Bob Wortham” he was only retain to file a “General Denial” (Only) while secretly conceal all of the Pro Se Plaintiff Discovery request document throughout the years of 2007, 2008 and 2009 to assure Co-Defendant(s) “Joyce Guy and Edward McCray” fully protected from any present and future civil/criminal fall outs occurring

Based upon Pro Se Plaintiff Investigations into the Mutable Corrupted Business “patterns and practices of the Co-Defendant(s) herein to include but not limited to The Pro Se Plaintiff knew Co-Defendant “Edward McCray” seriously engage in “sales” of a “Crack Cocaine” Industry and having mutable arrest.

                                                37.

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Special Exclusive in-depth Investigation into the Co- Defendant(s) “Joyce Guy and Edward McCray” further reveal J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640 being owned by the Defendant(s) “Joyce Guy and Edward McCray”, assumed name filed on April 11^th 2008 Jefferson County Clerk records #72594

1807 East 7^th street in Port Arthur Texas is actually a “Vacant Lot” which has been raided by the PAPD Dept. (Police) several times for engaging in “illegal Scrap Industry”

“Moreover” once all “Illegal Scrap Metal” other then used Cans being recycle and obtain in the City of Port Arthur Texas city limits by Defendant “Edward McCray”, by the business J Can Company being now introduced as “Scrap Metal” in connection with “Cars and Pieces” business Located in Beaumont Texas (Office) also located at 448 DeQueen Blvd. in Port Arthur Texas 77640

Making the final “Legal sales” of all “illegal scrap” obtain in the City of Port Arthur Texas city limits by Defendant “Edward McCray”,

 “Moreover” Pro Se Plaintiff Louis Charles Hamilton II herein (Fully) quite “elementary sure and certain” after prior raid by the (PAPD) Police into “illegal scrap” of J Can Company that this “many years of “baffling exchange” transfer rate of

 “Illegal scrap”  from Port Arthur Texas City Limits has been confusing the (PAPD) Police in the exchange rate form now “legal scrap” derived in “Beaumont Texas” from J Can Company “Namely”, “Cars and Pieces” business in Beaumont Texas being now major illegal scrap metal “money laundering” “Earn Income” system for Co-Defendant (Edward McCray) derived from this “criminal endeavor.

 To include but not limited to, upon information, belief and personally witness Co-Defendant “Edward McCray” usage of “Vacant Lot” being J Can Company to secretly continue engaging in the sales of a “Crack Cocaine Industry”.

 

"U.S. District Court" Louis Charles Hamilton II vs. Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 et al

7.

Subject Matter Jurisdiction

        Venue

Pro Se Plaintiff Louis Charles Hamilton II herein States, Affirm, and Declare Before The “Honorable Justice” Subject Matter Jurisdiction is proper before this U.S. District Court “primary exclusive many “federal Questions” involving among other things

Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and related activity in connection with identification documents), Section 1503(relating to obstruction of justice),

Falsification of “Material facts”, with Conspiracies by all described Defendant(s) to pursue to the same Criminal Monetary Objective(s) involving the Pro Se Plaintiff herein,

With mutable counts of constructive fraud activities “hiding behind” among other things “attorney-client privilege” and all “work-product doctrine” derive thereof, to include but not limited to all “communications” between an “Attorney and his client”,

Namely Defendant Antoine L. Freeman J. D. (Attorney at Law) (Active) in and for the State of Texas Bar No. 24058299 in collusion and conspiracies with Co-Defendant(s) “Joyce M. Guy” and “Edward McCray  et al”

To Commit to Fraudulent acts in all “prepared legal court documents”, “affidavit(s)”, “interrogatories”, “request for admissions”, sign statements and all other materials of Jefferson County Court records, document(s) and materials facts in 58^th Judicial District Court of Jefferson County Texas Court Docket No. A-180805

“To include but not limited” to fraud upon the Honorable Judge Bob Wortham, and His Court

Fraud in all records of the Jefferson County Clerk Office records involving  financial records of “Insurance Companies”, “Financial Statements” for primary monetary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and “Humberto ” scheme of things related Construction storm damages, derive thereof further involving the Pro Se Plaintiff herein

                                                8.

“To include but not limited to” the ” Actual Fraud”, upon the “Texas Department of Housing & Community Affairs” of Jefferson County Texas and “Federal Grants of $76,000 U.S. Dollars” derive thereof  

In Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and related activity in connection with identification documents), Section 1503(relating to obstruction of justice), with “Actual Fraud(s)”  Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” conspiracies of mutable “Insurance Companies”, for primary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages, Involving further The Pro Se Plaintiff herein as a “unwilling blind” party into this cold calculated fraudulent acts and action(s), and complex scheme of things to further fraud the “Texas Department of Housing & Community Affairs” of Jefferson County Texas and a “Federal Grants in excess of $76,000 U.S. Dollars” derived thereof

                                                9.

“Actual Fraud”, upon the 58^th Judicial Court of Jefferson County Texas and all records derive thereof,

 To include but not limited to Actual Fraud of Insurance Companies”, FEMA for primary monetary fraudulent acts and actions during “Hurricane “Rita”, “Ike” and “Humberto” related Construction storm damages, involving the Pro Se Plaintiff Louis Charles Hamilton II herein

All this “Complex Mutable Grand Scheme of Things” committed By the Name Defendant Antoine L. Freeman J. D. a (Attorney at Law) (Active) in and for the State of Texas Bar No. 24058299 in collusion and conspiracies with Co-Defendant(s) “Joyce M. Guy” and “Edward McCray et al” corrupted activities fully designed prepared with an eye towards the “realistic possibility of impending litigation” by the Pro Se Plaintiff herein Defendant and Co-Defendant(s) commit to Grand (RICO) Fraud of The 58^th Judicial District Court of Jefferson County thereof in this civil scheme of things.

And the realistic object by all described Defendant and Co- Defendant(s) herein to further commit to Fraud for “monetary value gain in excess” of $87,024.00 U.S. Dollars, against the Pro Se Plaintiff Civil rights, peace, will and dignity

                                                10.

With further combine conspiracy of fraudulent acts and actions by the Defendant and Co-Defendant(s) to plan a scheme of things in the Theft of Pro Se Plaintiff “Personal Property” herein against the Pro Se Plaintiff Louis Charles Hamilton II “Civil Rights”, “Peace”, and “Dignity” being wrongfully done within the Jurisdiction of the “Honorable Justice” further causing the Pro Se Plaintiff herein to suffer “among other things”

Extreme real life hardship, Extreme Intentional Infliction of emotional distress and mental anguish from all of the combine Defendant and Co-Defendant(s) among other things conspire in (RICO) “Racketeer Influenced and Corrupt Organizations Act”,

“Fraud on the Court”, “Mail and Wire Fraud”, “Obstruction of Justice” “Direct Fraud” and “Constructive Fraud” of Jefferson County Texas 58^th Judicial District Court Records,

Fraud upon the Jefferson County Public Records combine with all other extreme hostile corrupted wicked cruel civil/criminal acts and actions being fully described in this complaint herein.

                                                11.

Pro Se Plaintiff herein States, Affirm and Declare before the Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and related activity in connection with identification documents), Section 1503(relating to obstruction of justice), Fraud upon the 58^th Judicial District Court of Jefferson County Texas in connection with

Falsification of “Material facts”, and Numerous Fraudulent Activities in the Capacity of a “Attorney at Law” cause Pro Se Plaintiff “Louis Charles Hamilton II” herein to suffer “actual damages” in excess of $336,000.00 U.S. Dollars and This “actual damages” is ongoing as of this undersigned date of this Complaint before the Honorable Court since date of injury November 17^th 2007.

                                                12. 

Pro Se Plaintiff seeks Actual, accumulative, compensatory, consequential, continuing, expectation damages, foreseeable, Future, incidental, indeterminate, reparable, lawful, proximate, prospective, special, speculative, substantial, Punitive, and Permanent damages;.

Pro Se Plaintiff seeks Actual Awards for Intentional Infliction of emotional distress and mental anguish.

                                                13.

Pro Se Plaintiff herein States, Affirm and Declare before the Honorable Justice” this action was filed before this Honorable Court February 2, 2010 U.S. Docket No. 1:2010-CV-00055 and at that time frame Pro Se Plaintiff was under extreme mental stress caused by the many “acts and actions” of the primary Defendant in the capacity of a “Skilled Attorney of Law” no less a Officer of The State of Texas Court System and Co-Defendant(s) herein whom collectively together are responsible for the Pro Se Plaintiff suffrage of among other things “Mental Illness” and Living on SSI since date of injury… of 2007 as of this undersigned date.

Pro Se Plaintiff further states, affirm and declare before the Honorable Justice” also at the time of filing the original complaint against the Described Defendant(s) herein

(Plaintiff) U.S. Government and Federal Court Mail was being stolen, by among others

(Thee) U.S. Attorney Office them self (Proof) already on Filed in this herein U.S. Federal Court Clerk Office in the matter of Hamilton Vs. United States of America, U.S. Attorney Eric Holder et al (1:2011-CV-00240)

Plaintiff was also forced into a “State Hospital” for a period of time, accused of Violent Life Threaten Crimes” never being near of or a party thereof and Pro Se Plaintiff “mental state” being quite scary indeed in light of all the legal hostile activities ongoing against the Plaintiff will caused by each Defendant(s) herein.

                                                14.

Pro Se Plaintiff herein States, Affirm and Declare further before the “Honorable Justice” this New Improved Complaint made against each Defendant(s) herein is still criminal/civil corrupted conduct being still quite “civilly ongoing” against the “legal rights” of the Pro Se Plaintiff “Louis Charles Hamilton II

As Defendant(s) combine further “Fraudulent activities” continue to cause the Pro Se Plaintiff to suffrage continually monetary damages in excess of $48,000.00 U.S. Dollars per year since 2007, as of this undersigned date of this complaint well into the future year of 2015.

Further causing Pro Se Plaintiff a “limbo state” of extreme hardship, Intentional Infliction of emotional distress accompanying continue Gross state of complete “mental anguish” direct at the Defendant(s) from all of the numerous hostile corrupted acts and actions of the described Defendant(s) herein as this “Civil Matter” is unresolved before the Jurisdiction of this Honorable U.S. District Court which has real subject matter jurisdiction over all detail material facts being complained of respectfully before “Honorable Justice”

                                                15.

Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” that his current “Mental State” is processing a bit better, as these causes of actions derived from Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 direct criminal/civil illegal, hostile, corrupted conduct in collusion with Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” need to be legally address

And Pro Se Plaintiff seeks a just proper legal, lawful respectable accountable end to this civil matter in which the above Honorable U.S. District Court has unfetter Judicial Subject matter over.

                                                16.

Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” the Defendant(s) continue imposed mental suffrage, hardship, and Major Monetary losses caused by the described Defendant(s) collectively herein as Pro Se Plaintiff “Mental State” has improved slightly as of this undersigned date to uncover all of the real in life cruel intentions scheme, facts and fraudulent circumstances of each described Defendant(s) acts and actions herein direct against the rights, will, peace and dignity of The Pro Se Plaintiff notably being on a Grand scale corrupted involvement

To the point the once (crafty hidden) “Racketeer Influenced and Corrupt Organizations Act”, “Obstruction of Justice”

“Fraud on the Court”, “Mail and Wire Fraud”, “Direct Fraud” and “Constructive Fraud” of Jefferson County Texas 58^th District Court Records,

Committed fully by Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299

And precise fraud upon the 58^th Judicial Court of Jefferson County Texas to now as of this undersigned date

Being official new discovery in Jefferson County Texas Public records, quite correct and respectable evidence being complained of before the Honorable Justice”

Now identified is this complaint in precise, sound proof calculations into each responsible direct “acts and actions” of each Defendant(s) exacts responsible & accountable “federal jurisdiction” conduct giving rise for a cause of “Justice” Before this “Honorable Justice” United States of America Court .

                                                17.

                               Factual Background       

Co-Defendant(s) “Joyce Guy and Edward McCray” living at the dwelling (Blk. 172 Lt. 1-2) being located at 448 DeQueen Blvd. in Port Arthur Texas 77640 knowingly collectively did enter into a Contract for the Amount of $10,850.00 for Construction following Hurricane Humberto damages.

                                                18.

 Co-Defendant(s) “Joyce Guy and Edward McCray” already received funds for repairs from the “Home Owner Insurance Company” in excess of $7000.00 U.S. Dollars and unknown to the (Plaintiff) Co-Defendant(s) simply squander all of these funds on them self and their quite “selfish needs other than making the repairs to the already seriously damaged home as required by the first installment Insurance Funds proceeds.

At this point Co-Defendant(s) “Joyce Guy and Edward McCray” devised a financial “wicked plan” to fraudulently involving the Pro Se Plaintiff “Louis Charles Hamilton II” herein and his Construction contract $10,800.00 U.S. Dollars for Hurricane Damages in a continue “scheme of things” to obtain additional Funds from the same “Insurance Company”. 

                                                19.

Co-Defendant(s) “Joyce Guy and Edward McCray” Breach the Contract of the Pro Se Plaintiff on November 17, 2007 for the same scheme of things as being described in paragraph (18) above in addition Co-Defendant(s) collectively took possession, custody and complete control over all of the Plaintiff property Namely (Construction Tools) in excess of $3093.00 being Pro Se Plaintiff entire “Construction Business of tools”...!

Wrongfully abducted and obtain in this “hostile takeover” to include Pro Se Plaintiff herein being “physically assaulted” by Co-Defendant “Edward McCray” while this same ongoing “criminal scheme of things” is in effect fully committed and directed, and orchestrate by Co-Defendant(s) “Joyce Guy and Edward McCray for the absolutely purpose to Fraud further of The “insurances companies “Repair Moneys” for Co-Defendant(s) collectively “personal monetary gain” other than making needed repairs

As all described in paragraph (18 & 19) above involving The Pro Se Plaintiff Louis Charles Hamilton II and a Construction contract drafted by Pro Se Plaintiff for Co-Defendant(s) “Joyce Guy and Edward McCray” collective behalf for “monetary relief” by said “Insurance Companies” to cover dwelling located at 448 DeQueen Blvd. in Port Arthur Texas home structural repairs cost for Hurricane Humberto related storm damages.

                                                20.

Co-Defendant(s) “Joyce Guy and Edward McCray” for their combine corrupted conduct direct against the Plaintiff civil rights, peace, and dignity within Jefferson County Texas as being described in paragraph (17, 18, and 19) above

Pro Se Plaintiff filed civil action in Jefferson County Texas 58^th Judicial District Court, before the “Honorable Judge” Bob Wortham.

 Complaint Docket No. A-180805 filed on November 26^th 2007 with the Jefferson County Clerk of Court office. And Co- Defendant(s) “Joyce Guy and Edward McCray” retain the Professional legal services of Defendant Antoine L. Freeman J. D. “Attorney at Law” Texas Bar No. 24058299

Having “Two Legal Law Offices” in Port Arthur Texas, 3627 Professional Dr. Port Arthur Texas 77642 and 3723 Gulfway Dr. Port Arthur Texas 77642

 

                                                21.

Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” because of the continue chief corrupted effects of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 Skilled Crafty Criminal Mutable Complex

Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and related activity in connection with identification documents), Section 1503(relating to obstruction of justice),

Falsification of “Material facts”, among other things committed by this Defendant with Fraud upon the 58^th Judicial District Jefferson County Court and such Conspiracies involving the Pro Se Plaintiff herein,

The Civil action filed on November, 26^th 2007 in 58^th Judicial Court of Jefferson County Texas remain complexly ongoing well into December 17^th 2014 next court hearing, fully

“Live” as of this undersigned date for a period well exceeding over (7) years and counting ongoing in the 58^th Judicial District Court of Jefferson County Texas for a suit in “Common Law”.

"U.S. District Court" Louis Charles Hamilton II vs. Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 et al

4.

Jurisdiction

Jurisdiction is proper before the “Honorable Court” of Eastern District of Texas in that (Plaintiff) is always a resident of Jefferson County Texas, and all acts and actions described herein by all the Defendant(s) described herein fully occurred within the Jurisdiction of Eastern District of Texas

Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 is a (Active) “Attorney at Law” for the State of Texas as described above in paragraph (2)

Further said Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 was acting in his full capacities as an “License Attorney” on retainer for the legal behalf of (Co)-Defendant(s) “Joyce M. Guy” and “Edward McCray” in a Civil Action in The District Court 58th Judicial District of Jefferson County, Texas, Docket No. A-180805

When said Defendant herein in his fiduciary capacities as an “Attorney of Law” Antoine L. Freeman J. D. ) Texas Bar No. 24058299

Committed to “among many other things” (RICO) “Racketeer Influenced and Corrupt Organizations Act”, Fraud on the Court
“Mail and Wire Fraud”, “Direct Fraud” and “Constructive Fraud” in connection with Jefferson County Texas 58th District Court Records, and Fraud of Jefferson County Public Records

5.

To include Defendant(s) and Co-Defendant(s) collectively in concert, and collaboration in violations of Title 18 U.S.C. § 1341, 1343 and 1349 “Mail and Wire Fraud”, Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299

Aiding and abetting to commit to A Criminal Enterprise in “Racketeer Influenced and Corrupt Organizations Act” in his capacity as a Attorney of Law, against the rights, peace, and dignity, and civil rights of the Pr Se Plaintiff herein in suit in common law in Jefferson County Texas 58th Judicial District Court.

"Computer Fraud and Abuse Act (CFAA) 18 U.S.C. § 1030 in connection with all criminal acts and actions, as described fully herein.

Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 Fully Committed to among other things “Obstruction of Justice” in the capacity as an “Officer of the Court” and “Attorney of Law” for the State of Texas

To commit and conspire to the same causes of all “acts and actions” in concert with the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”

Fully Described herein against the Pro Se Plaintiff, While further willfully Omitting to and Destruction thereof “Material Civil Evidences and Facts” before a ongoing “Civil Suit” in Common Law in Jefferson County Texas 58th Judicial District

With “among other things” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Actual Fraud, upon the “Texas Department of Housing & Community Affairs” Jefferson County Texas and Federal Grants derived thereof in Connection with the Pro Se Plaintiff “Louis Charles Hamilton II” herein

With “among other things” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Actual Fraud of Insurance Companies”, for primary fraud during “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages, in connection with the Pro Se Plaintiff

6.

Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” To commit to the same “Obstruction of Justice” of 58th Judicial District Court, for primary fraud during “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages,

Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) (Active) in and for the State of Texas Bar No. 24058299 and in collusion with Co-Defendant(s) “Joyce M. Guy” and “Edward McCray et al” Conspiracies together to pursue the same Criminal (RICO) “Racketeer Influenced and Corrupt Organizations Act”,

Fraud on the Court “Mail and Wire Fraud”, “Direct Fraud” and “Constructive Fraud” of Jefferson County Texas 58th District Court Records, Fraud of Jefferson County Public Records
All “among other things” being done criminally/civilly against the Pro Se Plaintiff civil rights, peace, will, and dignity,

During an ongoing “Civil Suit” of Common Law in Jefferson County Texas as described in paragraph 4 and 5 above.
All being wrongfully and fully committed to Within the Jurisdiction The Eastern Division of Texas United States District Honorable Court.