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

84.

Chief Defendant Attorney at Law herein and the Co- Defendant Joyce M. Guy” herein supply the following Answer to Pro Se Plaintiff Interrogatories Discovery Document pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.

10. Where is the Funding for the New Home?

Answer: Federal Grant

11. What are the terms and conditions of any contract in regards to the new home?

Answer: Federal Government built home free of charge Defendant must remain in home for at least 3 years.

12. What is the entire cost of the construction for the new home?

Answer: $76,000.00 U.S. Dollars

13. How is the city of Port Arthur Involved?

Answer: Not involved

14. How is the State of Texas Involved?

Answer: Not Involved

15. How is the Federal Government involved?

Answer: Federal Grant

16. How much money did the Co-Defendant actually paid for the new home construction?

Answer: No money paid by Co-Defendant

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Chief Defendant “Attorney at Law” herein and the Co- Defendant Joyce M. Guy” and Edward McCray collectively herein supply the following “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories at question number 14

14. How is the State of Texas Involved?

Answer: Not Involved

In comparison to said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively custody, control and legal possession was Legally Transfer to the

 “Texas Department of Housing & Community Affairs” on June 18^th 2009 for a $72,500.00 U. S. Dollars Housing Grant.

.           And further that Documents along with the fraudulent Affidavit of Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to in regards to possession, custody and control knowledge during the fraudulent dates in cover up this discovery obstruction scheme of things was Placed in the United States Mail and

Publically Mailed to the Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805 and was electronically computer filed in Document # 8 herein 58^th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

                                                85.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein

Fully legally precisely having legal interest with the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively

Having a physical “legal binding contract” of some hidden sorts for such (RICO) enterprise “legal services” of thee’ described Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein from the time exact time frame of December 18^th 2007 when you filed “Your” General Denial…

Throughout the time frame until “You” finally official filed a “Motion for Withdrawal of Counsel”, filed stamp dated November 13^th 2009 10:22 am hour

Being fully quite “Legally” described in Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein “Motion for withdrawal of counsel”

As stated legally by Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein as follows:

To The Honorable Judge of Said Court:

            Now Comes Movant, Antoine L. Freeman J.D., Attorney for Defendants, Joyce Guy and Edward McCray, (hereinafter Defendants), and brings this Motion for withdrawal of Counsel, and in support thereof, shows the court the following:

                                                            I.

Good cause exists for withdrawal of Movant as counsel because Defendants have not complied with the terms of employment agreement with this attorney. Plaintiffs refuse to adhere to the terms of the employment agreement with this attorney.

                                                            II.

The setting and deadlines in this case are as follows: Motion for Sanction & Contempt on December 11^th, 2009 @ 9:00 am (With Your Initials)

                                                            III.

This Motion is not sought for the purposes of delay.

                                                            IV.

A copy of this motion bearing the enclosed notice has been delivered to the last known addresses of the Defendants.

 “Joyce Guy” 5050 7^th street Port Arthur, Texas 77642

“Edward McCray” 5050 7^th street Port Arthur, Texas 77642

                                                            V.

Defendants are hereby notified in writing of the right to object to this motion.

                                                      NOTICE

You are hereby notified that this motion for withdrawal of Counsel is set for hearing at the time and place set out below. You do not agree to this motion. If you wish to contest the withdrawal of Antoine L. Freeman, J.D. as your attorney, you should appear at the hearing.

If you do not oppose Antoine L. Freeman, J.D.’s withdrawal as your attorney, you may notify Antoine L. Freeman, J.D. in writing of your consent to this motion.

Wherefore, Premises Considered, Movant prays that the Court enters as order discharging Movant as attorney of record for Defendants, “Joyce Guy” and “Edward McCray”, and for such other and further relief that may be awarded at law or in equity.

Respectfully submitted, by “Antoine L. Freeman, J.D., Texas Bar No. 24058299, 3723 Gulfway Dr. Ste #104, Port Arthur, Texas 77642 (409) 293-1627, Fax (409) 983-7405

“Attorney for Defendants” Joyce Guy and Edward McCray

                                                86.

Now legally Chief Defendant “Antoine L. Freeman, J.D., Texas Bar No. 24058299 seeking the 58^th Judicial District Court Judge Bob Wortham “honest official approval” to terminate said contract… in December 11^th 2009 Court Hearing after all of this past, present “Grand (RICO) enterprise scheme of things, executed with a skilled attorney real-estate eyes toward future 2015 financial gains of racket maturity on

$54,839.31 U.S. Housing Grant to free and clear property deeds on the dwelling located at 5050 east 7^th street in Port Arthur Texas, Co-Defendant “Joyce M. Guy”

enjoy such control and said “Mother” now being (Dead) providing legally said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively in direct legal, possession, custody and control over (2) Fraudulent (RICO) enterprise “scheme of things”

Namely “Federal Housing Grants” on the behalf of “Texas Department of Housing & Community Affairs” in excess of $72,500.00 U.S. Dollars

And $54,839.31 U.S. Dollars for a combine total additional (RICO) enterprise sham of in excess of $127,339.31 involving the Pro Se Plaintiff as a unwilling party and victim thereof

                                                87.

With the direct (RICO) enterprise “Leadership”, “Director”, CEO, CFO, Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein since March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008,

September of 2008, October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of 2009, June of 2009, July of 2009, August of 2009, and September of 2009 against Texas Rules of Civil Procedures

 Kidnap, pimp slap, spoil, mar, impair, desecrate, and plain old back woods “Negro Brother Esq.” corrupted in the hood with a random “casino buffet law degree” of some sorts “savagely sodomising” repeatedly “Lustita”

The Roman Goddess of “Justice” or as in commonly known in U.S. of America” namely “Lady Justice”

                                                88.

In this shameful extra slooooow chicken thievery quarter-back, skilled “Legal Directional” choice of Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein

 Super half bake mixture of “fermented formaldehyde-n-meth” soaking to formulate a toxic crack cocaine freebase cooking

(RICO) enterprise endeavor cocktail to display an obviously being quite the handsome “smoked out” broken old stove legal professional Esq. of some sorts magically appearing/disappearing “poof “ here and there legally” before a “Honorable 58^th Judicial District Court of Law”

With such deployment, and actions of slipping in and out of this “legal self induce “smoked out” coma” of some sorts” as “acting attorney of record” vs. “not acting attorney of record” between the exact time frame of December 18^th 2007 – throughout the “Motion for Withdrawal of Counsel”, filed stamp and dated November 13^th 2009 10:22 am hour

Being fully quite “Legally” described in Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein, “Motion for withdrawal of counsel” in his bogus, fraudulent “representation and presentation” in obstruction of Justice, Fraud upon the 58^th Judicial District Court of Jefferson County Texas in a collective

Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein secrete, conspire, collusion (RICO) enterprise scheme/sham in crafty hostile complex skilled attorney at law design directed wrongfully now at the

 (Sucker) namely Pro Se Plaintiff Louis Charles Hamilton herein “civil rights” in a suit in common law expensive on now time to depart, abandon, flee from such (RICO) enterprise scheme/sham endeavors of Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein on November 13^th 2009 10:22 am hour.

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

76.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively

(RICO) scheme of things in the direct refusal of the actual request in discover request dated back in March 14^th 2008 with a Court Order further following for such a Production of said “property deeds” now being Pro Se Plaintiff exhibit (L) already on file with the U.S. Clerk office dated May 10^th 2010 notwithstanding factual events and circumstances said

Property deeds being officially “free and clear” from the “Texas Department of Housing and Community affairs” United States Department of Housing and Urban Development Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005 as filed and recorded April 22^nd 2014 at 12:38 pm

As described in Pro Se Plaintiff exhibit (T) already on file with the U.S. Clerk office namely “Property Deeds” of the Co-Defendant(s) Joyce M. Guy and Edward McCray” herein dated April 22^nd 2014for the dwelling located at 448 DeQueen Blvd in Port Arthur Texas

                                                77.

 With the Co-Defendant(s) Joyce M. Guy and Edward McCray” herein fraudulent “Financing Statement” dated June 18^th 10:20 am filed as Pro Se Plaintiff exhibit (U) already on file with the U.S. Clerk office

 And Co-Defendant(s) Joyce M. Guy and Edward McCray” herein Termination of Fraudulent Financing Statement Amendment dated July 22^nd 2013 2:01 pm filed as Pro Se Plaintiff exhibit (V) already on file with the U.S. Clerk office

                                                78.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

And Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively further (RICO) scheme of things is involved in not being honest and providing full disclosure all of the actual Business being owned and all income derive thereof

“Namely” G & G services and E and J collectable, J Can Company, Cars and Pieces, Paragon Business Inc,  in order to obtain fraudulent from the “Texas Department of Housing and Community affairs” and ” United States Department of Housing and Urban Development said Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005 in excess of $72,500.00

Being directly in violation of 18 U.S.C. § 1001 : US Code - Section 1001: Statements or entries generally

(a) Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States,

knowingly and willfully - (1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact;

        (2) makes any materially false, fictitious, or fraudulent statement or representation; or

       (3) makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;

With this whole “Dreamy (RICO) enterprise endeavor furtherance directly in violation of the same 18 U.S.C. § 1001 : US Code - Section 1001: for such grand “Chief Defendant” (Attorney at Law) grand (RICO) enterprise wizard materially false, fictitious, and fraudulent statement(s) and fraudulent representation upon the

58^th Judicial District Court of Jefferson County Texas to pursue the same (RICO) monetary enterprise object(s) of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively, past, presently, and future beyond December 2015, scam, schems and racket life style.

                                                            79.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein further continue

In this well designed (RICO) “Scheme of things”  involved in concealing, obscuring, masking, cloak and shielding corrupted fraudulent “mutable fraudulent business” enterprise operations the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” herein concoct and obtaining massive hidden income over many years and presently described as follows:

A.    Assumed name business “G & G Services” a fraudulent Medical services for obtain “monetary payments” from “Senior Aging Handicap Citizens within Jefferson County Texas which “G & G Services” was never even a litigable Licenses with the State of Texas from May 2^nd 1997- 2010 as being order shut down as described in Pro Se Plaintiff exhibit (F) already on file with the U.S. Clerk office from the Texas Department of Aging and Disability Services. *to include but not limited to “Tax Evasion” being directed at both the “State of Texas” and “The United States of America” for a actual time period of (13) plus years in this (RICO) illegal medical business operation fraudulent corrupted “scheme of things”. To include but not limited to upon information and belief “G & G Services” medical services is secretly still in business operation …….Omg (wow) J

B.    While “G & G Services” income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

C.     Assumed name business “E and J Collectibles” 448 DeQueen Blvd. in Port Arthur Texas which is in the Used Merchandise Stores business for a unknown amount of years having (2) companies in Port Arthur Texas “However” these (2) companies is not registries with “Jefferson County Texas, or the “State of Texas” fully engaging in among other things (RICO) enterprise in “Sales Tax Evasion”, *Business is current in operation as identified on the “internet” for a unknown accountability of time.

D.    While “E and J Collectibles” income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

E.     Assumed Name J Can Company in Port Arthur Texas business operation from April 11^th 2008 – 2015 this J Can Company business operation is a “front company” for (RICO) enterprise scheme of things in “among other things” besides hidden sells of “Crack cocaine” while actually engaging in (RICO) enterprise in “money laundering” in scrap metal materials” in connection with assumed name business “Cars and Pieces”

F.     Another “front company” located in Beaumont Texas. To include but not limited to J Can Company business operation and “Cars and Pieces” business operation (RICO) enterprise in State and Federal Tax Evasion.

G.     While J Can Company income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

H.    Assumed Name “Car and Pieces” in Beaumont Texas business operation from May 10^th 1990 while actually engaging in (RICO) enterprise in “money laundering” in scrap metal materials” in connection with assumed name business J Can Company in Port Arthur Texas. As described in paragraph (C) above.

I.       While “Car and Pieces” income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

J.       Assumed Name Paragon Business Inc. being a unknown company of sorts, current in business operation since May 17^th 2001 while Paragon Business Inc. income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

80.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein continue to engage in among other things “obstruction of Justice” collaboration, racket, and monetary cover up

Plot in their collective (RICO) enterprise “defense” the direct refusal to produce among other things said 58^th Judicial District “Court Order” for discovery of the “property deeds”, and all records involved in Hurricane “Rita,

 Humberto, and Ike, in connection with the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas as of this undersigned date in 2015.

And ruse, dodge, concealing, withholding, destroying, masking, obscuring all past, property deeds, banking records, contractor(s) construction insurances estimates and contract(s)  for (5)-(6) hurricane storm damages claims, homeowner private insurance records,

 FEMA records, (4)-(6) mutable private illegal business company records, Texas Department of Housing and Community Affairs housing records materially false, fictitious, and fraudulent statement and representation being made in such records at the “Texas Department of Housing and Community affairs” and ” United States Department of Housing and Urban Development

To include but not limited to all State Tax Records, Sales Tax records, (IRS) Tax Records and any and all document(s) relating to any discovery into the corrupted (RICO) enterprise endeavor fully executed since the time exact frame of 1997-2015 as being legally described by the Pro Se Plaintiff “Louis Charles Hamilton II” herein.

                                                81.

 “Chief Defendant” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 with legal intent to bring Pro Se Plaintiff “Civil Suit” in Common Law A-180805 to a full collapse lost civil cause of action in a well plan, visionary clever skilled lawyer strategy scheme to “first and foremost” make the bogus (RICO) fraudulent “representation and presentation” as acting “attorney of record” for the legal behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray collectively to fool, hinder, obstruct, and hamper the Pro Se Plaintiff civil suit in common law within the State of Texas docket No. A-180805

While at the same time frame Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein making the same bogus (RICO) fraudulent “representation and presentation” as being not the acting “attorney of record” fraudulent appearing above the law before the Honorable 58^th Judicial District Court of Jefferson County Texas in direct violation in “among other things”

 Pro Se Plaintiff full citizenship of the United States of America and Military Veteran entitlement of the Seventh Amendment of the United States of America, Permanently Disable Veteran protected under: (ADA) American with Disability Act; And also minorities persons cover under Title VII of the Civil Rights Act of 1964; and all full citizenship entitlement of the Seventh Amendment in connection with the State of Texas Constitution,  

Article 16: "General Provisions" Section 37 provides for the constitutional protection of the mechanic's lien, and Section 50 provides for protection of a homestead against forced sale to pay debts, except for foreclosure on debts related to the homestead (mortgage, taxes, mechanic's liens, and home equity loans). Pro Se Plaintiff Louis Charles Hamilton II Being Domiciliary State of Texas, P.O. Box 17524 Sugar Land, Texas 77496

 To Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 execute withholding all discovery as now being escalated as described of the Grand (RICO) enterprise “scheme of things” involving the Pro Plaintiff alone in a sham in excess of  $127,339.31 scam of (2) U.S. Federal Housing Grant.

                                                82.

Couple in providing with Pro Se Plaintiff combines actual damages suffrage in excess of $336,000.00 U.S. Dollars, lost earning and earning capacity, Breach of Construction Contract of $10,800.00, additional scam in a Construction contract for property located at 5050 east 7^th street in Port Arthur Texas 77640, and $3,800 theft of personal property (Construction tools) for Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299

 And Co-Defendant(s) “Joyce M. Guy and Edward McCray” collective conspire concert crafty 2015 ongoing (RICO) enterprise endeavor against the Pro Se Plaintiff Louis Charles Hamilton II herein Civil Rights, Peace, personal property and dignity in excess of $477,939.31 U.S. Dollars.

                                                83.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein

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Date & Time	Status of Item	Location
January 29, 2015 , 10:53 am	Notice Left (No Authorized Recipient Available)	PORT ARTHUR, TX 77640
We attempted to deliver your item at 10:53 am on January 29, 2015 in PORT ARTHUR, TX 77640 and a notice was left because an authorized recipient was not available. You may arrange redelivery by visiting http://www.usps.com/redelivery or calling 800-ASK-USPS 800-ASK-USPS FREE, or may pick up the item at the Post Office indicated on the notice. If this item is unclaimed after 15 days then it will be returned to the sender.
January 29, 2015 , 8:29 am	Out for Delivery	PORT ARTHUR, TX 77640
January 29, 2015 , 8:19 am	Sorting Complete	PORT ARTHUR, TX 77640
January 29, 2015 , 7:15 am	Arrived at Unit	PORT ARTHUR, TX 77640
January 29, 2015 , 6:34 am	Departed USPS Facility	BEAUMONT, TX 77707
January 29, 2015 , 4:15 am	Arrived at USPS Origin Facility	BEAUMONT, TX 77707
January 28, 2015 , 10:37 pm	Arrived at USPS Origin Facility	NORTH HOUSTON, TX 77315
January 28, 2015 , 10:09 am	Acceptance	SUGAR LAND, TX 77479

 

Flat out in refusal to except any “certified Mail” from this particular Pro Se Plaintiff Louis Charles Hamilton II in the State Court action

 A-180805 on January 29, 2015 , 10:53 am as being described

    Tracking Number: 70092820000295595205

For a “Writ of Attachment”, Summary Judgment, Contempt of Court hearing being held on the 19^th day of February 2015 before the 58^th Judicial District Court of Jefferson County Texas at 9:00 am hr.

Once Co-Defendant(s) “Joyce M. Guy and Edward McCray collectively herein in 2015 again with such grand scuttle plans, to hide, melt, destroy, conceal, ruse, scheme, dodge, all records, or being a party thereof in this grand (RICO) scheme of things involving not only the Plaintiff but the entire “United States of America”

And “The State of Texas” in a half bake (RICO) combine “greedy racket enterprise” scheme of things that has accumulated gradually past acquisition of hidden (RICO) monetary earnings cars, possessions and mutable properties estimates in excess of $980,000.00 U.S. dollars from the direct time frame of 1997-2015

And to include but not limited to the Grand (RICO) scheme of things involving the Pro Plaintiff Louis Charles Hamilton II herein alone in excess $127,339.31 monetary scam of (2) U.S. Federal Housing Grant in his Private Profession as a “Independent Construction Contract" since date of injury being in the year of 2007.