MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592
1. In The United States DistrictCourt
For The Eastern Division of Texas
Beaumont Division
Louis Charles Hamilton II
Pro Se Plaintiff
Vs. CauseNo. 1:14-CV-592
Antoine L. Freeman J. D.
Defendant
Joyce M. Guy
Edward McCray
Co-Defendant(s)
PLAINTIFF'S (TRO) MOTION TO FREEZE DOCUMENTS, RECORDS, AND ASSETS OF
DEFENDANT ANTOINE L. FREEMAN J.D.
ATTORNEY AT LAW AND CO-DEFENDANT(S)
JOYCE M. GUY AND EDWARD McCRAY
Comes Now the Pro Se Plaintiff Louis Charles Hamilton II herein, files the
above entitled motion, with attached brief and exhibit(s) in support of Plaintiff
Order
DEFENDANT ANTOINE L. FREEMAN J.D. ATTORNEY AT LAW AND CO-
DEFENDANT(S) JOYCE M. GUY AND EDWARD McCRAY,
To a order to show cause why Pro Se Plaintiff Louis Charles Hamilton II
herein enjoy a “Temporary Restraining Order”, freezing the destruction or alter of
all records, and documents set forth herein,
2. And to secure all of the DEFENDANT ANTOINE L. FREEMAN J.D. ATTORNEY
AT LAW HEREIN AND CO-DEFENDANT(S) JOYCE M. GUY AND EDWARD McCRAY
HEREIN, Collective Assets.
And for just cause the Pro Se Plaintiff Louis Charles Hamilton II will show as
follows:
(1)
On the Emergency application of the Plaintiff (The “Applicant”) for and Order
Defendant Antoine L. Freeman J. D. (Attorney at Law) and all Co-Defendant(s)
listed as: “Joyce M. Guy and Edward McCray” collectively defendant(s) to an
Order”,
Directing Defendant Antoine L. Freeman J. D. (Attorney at Law) and all Co-
Defendant(s) “JoyceM. Guy and Edward McCray” to show why an order should
not be entered, pending a final disposition of this civil action U.S. Cause No. 1:14-
CV-592 Preliminary enjoining
Defendant Antoine L. Freeman J. D. (Attorney at Law) and all Co-
Defendant(s) “JoyceM. Guy and Edward McCray” fromfurther violating the
United States Chapter 96 of Title 18, United State Code: (RICO) Racketeering
Influences Corruption Organization,
1341 (relating to mail fraud), section 1343 (relating to wire fraud), section
1503 (relating to obstruction of Justice), with other Federal and State charges
being levy in connection thereof.
(2)
With further Honorable Courtrequirement(s) directing Defendant Antoine
L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “JoyceM. Guy
and Edward McCray” herein to providea verified accounting immediately,
including, but not limited to,
A verified written accounting of Defendant Antoine L. Freeman J. D.
(Attorney at Law) herein and all Co-Defendant(s) “JoyceM. Guy and Edward
McCray” herein interests in all entities owned, in whole or in part, or controlled
by, related to, or associated or affiliated with DefendantAntoine L. Freeman J. D.
3. (Attorney at Law) herein and all Co-Defendant(s) “JoyceM. Guy and Edward
McCray” in the United States of America.
(3)
Freezing all of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein
and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein business
records, banking records, personalbanking records, property deeds, and all assets
for all of the above listed Defendant(s) collectively in the United States of America
which is necessary to protect this Honorable United States District Court for the
Eastern District of Texas
Ability to decide from the preponderances in deciding the weight of factual
evidence, with furtherance allowances in the Honorable United States District
Court for the Eastern District of Texas ability in fully applying just awards and
compensation for “actual damages” of all equitable relief
Within all assets, moneys and properties held directly or indirectly by the
Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-
Defendant(s) “Joyce M. Guy and Edward McCray” herein for all of the Pro Se
Plaintiff “Louis Charles Hamilton II” Direct Actual damages, emotional pain and
suffrage
(4)
Whereforethe Pro Se Plaintiff herein respectfully seeks and Order directing
collectively DefendantAntoine L. Freeman J. D. (Attorney at Law) herein and all
Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein
Prohibiting fromthe destruction, concealment or alteration of all book
keeping records, courtdocuments, banking records, computer records, Insurance
records, Business records
Prohibiting fromsales, destruction, concealment and or alteration of all
Assets, and Property Deeds
4. Or by others for the Defendant Antoine L. Freeman J. D. (Attorney at Law)
herein and all Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein direct
and indirect beneficial interest which is necessary to effectuate and ensure
compliance with the freezeimposed on the
Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-
Defendant(s) “JoyceM. Guy and Edward McCray” herein,
Assets, preservethebooks, banking records and all business documents
and records of Defendant(s) DefendantAntoine L. Freeman J. D. (Attorney at Law)
herein and all Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein until
this HonorableUnited States DistrictCourt for the Eastern District of Texas having
the ability to determine
The extent to which the freeze should be lifted as to certain records,
documents, and assets in the custody, possession,and legal control of Defendant
Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce
M. Guy and Edward McCray” herein.
(5)
Preliminarily enjoying DefendantAntoine L. Freeman J. D. (Attorney at Law)
herein and all Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein
And their partners, owners, agents, employees, attorneys, or other
Professional, anyoneacting in concertwith them, and any third party from
filing a bankruptcy proceeding for the Defendant Antoine L. Freeman J. D.
(Attorney at Law) herein and all Co-Defendant(s) “JoyceM. Guy and Edward
McCray” herein.
Without filing a motion on at least three (3) day’s notice to the Pro Se
Plaintiff “Louis Charles Hamilton II” herein and approvalof this HonorableUnited
States DistrictCourt for the Eastern District of Texas after hearing; and pending
final adjudication, arbitration, negotiation, mediation, settlement of this U.S.
District CourtCivil CauseNo. 1:14-CV-592
(6)
5. Plaintiff enjoyment of an Order “Temporary Restraining” Defendant
Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce
M. Guy and Edward McCray” herein fromfurther violating the United States
Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences
Corruption Organization, section 1503 (relating to obstruction of Justice),
Relating to the destruction, concealment or alteration of all book keeping
records, courtdocuments, banking records, computer records, Insurancerecords,
Business records as described in the complaint on file with the United States Clerk
of Courtoffice herein
Namely all book keeping records, courtdocuments, banking records,
computer records, Insurancerecords, Businessrecords being further setforth
herein
Plaintiff enjoyment of an Order “Temporary Restraining” Defendant
Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce
M. Guy and Edward McCray” herein prohibit fromsales, destruction, concealment
and or alteration of all Assets, and Property Deeds with other Federal and State
charges being levy in connection thereof.
Is very beneficial Pro Se Plaintiff herein enjoymentof an expedited Order
“Temporary Restraining” the main DefendantAntoine L. Freeman J. D. (Attorney
at Law) herein in Light of the factual circumstances DefendantAntoine L. Freeman
J. D. herein is an actual (Attorney at Law) with the “Legal Law Degrees & Special
Trade Skills” in among other things
Defendant herein is a actual “Attorney at Law” for hire” in Fraud Litigation,
and InsuranceLitigation both of which Defendant Antoine L. Freeman J. D.
(Attorney at Law) herein so did in a all factual circumstances and events from the
time frame of December 18, 2007 throughoutDecember 18, 2014 abused his
legal “Attorney at Law skills” and fully committed to actual “Obstruction of
Justice” of a civil suit in common law filed cause No. A-180805
In deal with the designed “Obstruction of Justice” tactic in covering up
“Direct Fraud”, and “InsuranceFraud” committed along with many, many,
6. numerous other civil/criminal acts and actions of the Co-Defendant(s) “JoyceM.
Guy and Edward McCray” herein
Notwithstanding Defendant himself Antoine L. Freeman J. D. (Attorney at
Law) herein criminal aid and conspireto further commit to a future(RICO) and
Actual Fraud acts and actions on behalf of the Co-Defendant(s) “JoyceM. Guy and
Edward McCray” againstthe Pro Se Plaintiff herein
Namely Defendant conspirein among other things in the concealment of
the actual property deeds and transfer of said Property to the Texas Department
of Housing & Community Affairs
On or before the dates of June 18th
2009 for the dwelling located at 448
DeQueen Blvd. in PortArthur Texas 77640 being in the possession, custodyand
control of the Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein which
said dwelling is the main subjectmatter in Texas State Courtdocket No. A-
180805.
Pro Se Plaintiff
(Brief)
(7)
“Good and sufficient causeand reasoning exist why procedureother then
notice of motion is necessary, for a Order to show cause, Temporary Restraining
Order, Order to Secure Relating to the destruction, concealment or alteration of
all book keeping records, courtdocuments,
Banking records, computer records, Insurancerecords, Businessrecordsas
described in the complaint on file with the United States Clerk of Courtoffice
herein
Namely all book keeping records, courtdocuments, banking records,
computer records, Insurancerecords, Businessrecords being further setforth
herein fromthe dates of November 17th
2007 throughoutDecember 18th
2014 for
7. the DefendantAntoine L. Freeman J. D. (Attorney at Law) herein in his extreme
and outrageous representation of
Co-Defendant(s) “JoyceM. Guy and Edward McCray” againstthe Pro Se
Plaintiff herein civil suit in common law filed causeNo. A-180805 with Pro Se
Plaintiff Motion for Production of Document(s) to Defendant Antoine L. Freeman
J. D. (Attorney at Law) Texas Bar No. 24058299
Attached herein as Pro Se Plaintiff Exhibit (A) filed herein beforethis
HonorableUnited States DistrictCourt For The Eastern Division of Texas
Beaumont Division appearing before“The HonorableZack Hawthorn Magistrate
Judge” as being the exact evidentiary records Pro Se Plaintiff request brought
forth before Justice.
(8)
“Good and sufficient causeand reasoning exist why procedureother then
notice of motion is necessary, for a Order to show cause, Temporary Restraining
Order, Order to Secure evidence Relating to the destruction, concealment or
alteration of all book keeping records, courtdocuments, banking records,
computer records, Insurancerecords, Businessrecords as described in the
complaint on file with the United States Clerk of Courtoffice herein
Namely all book keeping records, courtdocuments, banking records,
computer records, Insurancerecords, Businessrecords, construction estimates,
FEMA, Property lien records, property deeds records and all records in
relationship to the exact time frame damages caused by
Hurricanes “Rita”, “Humberto” and “Ike” to the property located at 448
DeQueen Blvd. in PortArthur, Texas being further set forth herein prohibiting any
further attempts at the destruction, concealment or alteration by the Co-
Defendant(s) “JoyceM. Guy and Edward McCray” herein being “chief”
defendant(s) in a civil suit in common law filed causeNo. A-180805
8. *Pro Se Plaintiff “Louis Charles Hamilton II” herein move quite extra
respectfully as requesting the “HonorableJustice Zack Hawthorn Magistrate
Judge” having crystalclear examination of Pro Se Plaintiff Exhibit (B)
Order of the 58th
Judicial District Courtof Jefferson County Texas filed on
May 10th
2010 at11:46 am
Ordered that Co-Defendant(s) “JoyceM. Guy and Edward McCray” shall
produceall records and construction estimates for damages caused as a result of
Hurricanes “Rita”, “Humberto” and “Ike” to the property located at 448 DeQueen
Blvd. in PortArthur, Texas and as of December 18th
2014 wellinto the year of
2015
Co-Defendant(s) “JoyceM. Guy and Edward McCray” are in complete
refusalto submit of said exhibit (B) Order of the 58th
Judicial District Courtof
Jefferson County Texas filed on May 10th
2010 at11:46 amto producesaid
documents, records, and construction estimates as described in exhibit (B)
Notwithstanding Co-Defendant(s) “JoyceM. Guy and Edward McCray” are
in complete 100% refusalalso to submit to said exhibit (B) Order of the 58th
Judicial DistrictCourt of Jefferson County Texas filed on May 10th
2010 at11:46
am
To producecopies of deeds, property deeds or any other such physical
document in Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein
collective possession, custody and controlthat shows actualownership of the
property of the dwelling located at 448 DeQueen Blvd., in Port Arthur Texas
(Block) 172, Lot 1-2
With Pro Se Plaintiff “Louis Charles Hamilton II” Exhibit (B) filed herein
before this HonorableUnited States District Court for the Eastern Division of
Texas Beaumont Division
Appearing before “The HonorableZack Hawthorn MagistrateJudge” as
being the exact evidentiary records Pro Se Plaintiff requestbrought forth before
Justice.
9. (9)
Pro Se Plaintiff, declare, affirm, and state before the “HonorableJustice”
Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein were
“monetary retain” to file a General Denial on December 18th
2007 and then
Defendant Antoine L. Freeman J. D.
Claims that he was legally retained once again at some point as acting
Attorney of Record (Attorney at Law) Texas Bar. No. 24058299 to prepareand be
ready to attended (2) court hearing before the 58th
Judicial DistrictCourt in
Jefferson County Texas for the legal behalf of Co-Defendant(s) Joyce. M. Guy and
Edward McCray herein causeNo. A-180805 on thedates of “August28th
2009 and
September 11th
2009
While Defendanthimself Antoine L. Freeman J. D. (Attorney at Law) herein
having full possession, custodyand legal control over discovery requestof
Interrogatories, Requestfor Admission, and Request for DisclosurePro Se Plaintiff
mailed to him on the dates of April 2nd
2008 and April11, 2008,
And Defendanthimself Antoine L. Freeman J. D. (Attorney at Law) herein
did not respond to any of said discovery requestuntil on or about October 14th
2009.
Some (1) year and (6) months plus days later as Defendant himself Antoine
L. Freeman J. D. (Attorney at Law) herein was requested to complying with Texas
rules of Civil Procedures, 194.2., 197, and 198. Requestof Interrogatories,
Request of Admission, and Request for Disclosurefor civil cause No. A-180805
However at some point Defendanthimself Antoine L. Freeman J. D.
(Attorney at Law) herein did in Facts and Circumstances file a “Motion for
Withdrawal” as Attorney of record for the behalf of the Co-Defendant(s) JoyceM.
Guy and Edward McCray herein on
November 13th
2009 @ 10:22 AMin the Judicial District“Clerk of Court
Office” of Jefferson County Texas. Being filed as Pro Se Plaintiff Exhibit (F)
attached herein
(10)
10. Pro Se Plaintiff, declares, affirm, and state further before the “Honorable
Justice” Defendanthimself Antoine L. Freeman J. D. (Attorney at Law) herein
legally was acting “Attorney of Record from December 18, 2007 throughout
November 13th
2009 @ 10:22 AMfor cause No. A-180805
As being described in Pro Se Plaintiff exhibit (C) herein DefendantAntoine
L. Freeman J. D. (Attorney at Law) Motion to withdrawalas Counsel for the Co-
Defendant(s) JoyceM. Guy and Edward McCray herein.
(11)
Pro Se Plaintiff, declares, affirm, and state further before the “Honorable
Justice” Defendanthimself Antoine L. Freeman J. D. (Attorney at Law) herein
legally was acting as “Attorney of Record on or about the dates of August28th
2009 and September 11th
2009
“However Legally Underhanded” during the same“time frame” of
Defendant Antoine L. Freeman J. D. (Attorney at Law) representation of civil suit
No. A-180805on or about June 18th
2009
Co-Defendant(s) JoyceM. Guy and Edward McCray herein collectively by
and throughouttheir “Attorney of Record” being Defendant (Attorney at Law)
herein himself conspiretogether with the additional ongoing fraudulent activities
of
Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein whomnow
had conspire, executed and commence further (RICO) Fraud Activities and engage
in the actual concealment of the “identifying property deeds” being a party to a
Breach of Construction Contractwith the
Pro Se Plaintiff Louis Charles Hamilton II herein being filed in Texas State
Court Complaint docket No. A180805and Co-Defendant(s) “JoyceM. Guy and
Edward McCray” during their ongoing Legal Retain Hire Top Gun Representation
with Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299
Transfer of said Property located at 448 DeQueen Blvd. in PortArthur Texas
(Block) 172, (Lot) 1-2 to “Texas Department of Housing & Community Affairs” as
11. Filed in Jefferson County Clerk Records # 2009022762, for a $76,000.00Federal
Housing Grant, as being described in Pro Se Plaintiff attached exhibit (C) herein
“Jefferson County Texas Property Search Index”
(12)
Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein further on June
18th
2009 whileinvolved in this (RICO) activities as being described in paragraph
(13) abovefiled a “fraudulentfinancing statement” in Jefferson County Clerk
Records instrument # 2009022763
In the connection thereof for fraud activities engagement of the “Texas
Department of Housing & Community Affairs” for a monetary gain of in excess of
said $76,000.00 U.S. Dollars FederalHousing Grant
After the Co-Defendant(s)“JoyceM. Guy and Edward McCray” herein
already squandering all of the Home Owner Insurances funds,FEMA Funds
designated for “actual building repairs” of said Property located at 448 DeQueen
Blvd. in PortArthur Texas (Block) 172, (Lot) 1-2
Being as a result of Hurricanes damages from Hurricanes “Rita”, Humberto,
and “Ike” as described in Pro Se Plaintiff attached exhibit (B) herein 58th
Judicial
District Courtof Jefferson County Texas “CourtOrder” and the Pro Se Plaintiff
Louis Charles Hamilton II being a Party thereof docket No. A-180805
During this entire discovery phasetime frame of the Defendant Antoine L.
Freeman J. D. (Attorney at Law) which commenced on or about April 2nd
2008
and April 11, 2008 in all factual circumstances and events
Leading up to a required Court Order being filed by the 58th
Judicial District
Court of Jefferson County Texas and enforced as described in Pro Se Plaintiff
exhibit (B) attached herein
Was fully required after a year plus dates for Co-Defendant(s) “JoyceM.
Guy and Edward McCray” herein to producesuch “Property Deeds” to said
Property located at 448 DeQueen Blvd. in PortArthur Texas (Block) 172, (Lot) 1-2
12. well into 2015 still no compliance fromDefendant and Co-Defendant(s)
collectively.
(13)
As they Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein already
having been so served a “Motion for Production of Document” for copies of said
“Property Deeds” showing actualownership of dwelling located at 448 DeQueen
Blvd. in PortArthur Texas by and through said
“Attorney of Record” being DefendantAntoine L. Freeman J. D. (Attorney at
Law) herein on August12th
2009 to producesuch copies of Property Deeds to the
dwelling located at 448 DeQueen Blvd. in Port Arthur Texas Meanwhile the said
“Attorney of Record”
”The Main Defendant” Antoine L. Freeman J. D. (Attorney at Law) actually
physically appear in his dated (RICO) “Attorney atLaw” presentation on the behalf
of Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein on or about the
dates of firstAugust28th
hearing before the Honorable 58th
JudicialDistrict Court
of Jefferson County Texas
As being fully described in Pro Se Plaintiff attached Exhibit (D) filed herein
The 58th
Judicial District Court of Jefferson County Texas Docket reportCivil Cause
No. A-180805
While said Defendant Antoine L. Freeman J. D. (Attorney at Law) already in
legal possession, custody, and control over said discovery documents of
Interrogatories, Requestfor Admission, andRequest for Disclosure mailed
in accordance withthe Texas Rules of Civil Procedures 194.2, 197, and198,
during this time frame of on or about April 2nd
2008 andApril 11, 2008 request
(30) days thereafter for a respondof some sorts whichthis “Obstructionof
Justice”(RICO) scheme of things
Went clearly unobstructed throughout the dates of on or about June 18th
2009 beforethe 58th
Judicial District Courtof Jefferson County Texas whereby the
Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein legally transfer said
13. Property located at 448 DeQueen Blvd. in PortArthur Texas (Block) 172, (Lot) 1-2
to the “Texas Departmentof Housing & Community Affairs” for said $76,000
Federal Housing grant.
(14)
Notwithstanding “SWMJ CONSTRUCTIONINC.” filed a “Mechanics Lien” on
June 18th
2009 on said Property located at 448 DeQueen Blvd. in PortArthur
Texas (Block) 172, (Lot) 1-2 said property being a party to civil suit in common law
since 2007
With the Pro Se Plaintiff herein as filed into Jefferson County Texas Clerk
records instrument#2009022761
As this “Mechanics Lien” further being respectfully described in Pro Se
Plaintiff Louis Charles Hamilton II attached exhibit (D) herein before the
“HonorableJustice”.
(15)
Meanwhile the said “Attorney of Record”Defendant Antoine L. Freeman J.
D. (Attorney at Law) Texas Bar. No 24058299 still (Stupidity) conspiring to boldly
cutting his very own “legal brake lines” carrying on in his none stop (RICO)
furtherance’s activities by continue engaging ongoing well into the time frame
there after the official dates of June 18th
2009
When the said Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein
legally transfer said Property located at 448 DeQueen Blvd. in Port Arthur Texas
(Block) 172, (Lot) 1-2 to the “Texas Departmentof Housing & Community Affairs”
for future fraudulent activities of said $76,000 Federal Housing grant.
And “SWMJ CONSTRUCTIONINC.” now being identified herein filed a
“Mechanics Lien” on June 18th 2009 on said Property located at 448 DeQueen
Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 the said same property being a
party to civil suit in common law since 2007 involvement with the Pro Se Plaintiff
“Louis Charles Hamilton II herein.
(16)
14. Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar.
No 24058299 herein on September 11th 2009 there after the 9/11 World Trade
Center Memorial was conducted in front of the Jefferson County Texas
Courthouse,
Made his grand (RICO) resurfacing reappearance (Attorney at Law) act II
for the hearing on 9/11/2009 as being described in Pro Se Plaintiff exhibit (D)
herein (2) months and exactly 20 some odd days later thereafter when Co-
Defendant(s) JoyceM. Guy and Edward McCray herein
Legally transfer said Property located at 448 DeQueen Blvd. in PortArthur
Texas (Block) 172, (Lot) 1-2 to the “Texas Department of Housing & Community
Affairs”for said Fraud of $76,000 Federal Housing grant.
Thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar. No 24058299 herein already in legal possession, custody, and control
of discovery documents of Interrogatories, Request for Admission, andRequest
for Disclosure inaccordance withthe Texas Rules of Civil Procedures 194.2, 197,
and 198,
During this time frame of on or about April 2nd
2008 andApril 11th
, 2008
throughout the dates of on or about (Now) in the “new time frame of”
September 11th
2009 when Defendant Antoine L. Freeman J. D.(Attorney at Law)
herein now commencing as acting presently as “Attorney of Record”
On this 9/11/2009 “LiveHearing CourtDate” before the 58th
Judicial District
Court of Jefferson County Texas as being described in Pro Se Plaintiff attached
exhibit (C) herein The 58th
Judicial District Courtof Jefferson County Texas Docket
Report
(17)
Notwithstanding simple “material facts and circumstances” Defendant
“himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299
herein and Co-Defendant(s) JoyceM. Guy and Edward McCray herein collectively
already being furtherancein conspire(RICO)
“Obstruction of Justice” fraudulent activates namely in the concealment
and refusalto comply with all of said discovery request
15. For the entire year time frame of April of 2008 throughout Aprilof 2009
and finally submitted and responding to the Pro Se Plaintiff discovery requestwell
into the New Year of November 13th
2009 this addition of “Obstruction of Justice”
is being provided as Proof beforethe HonorableJustice”
By and through the legal representation of on again and off again slipping in
and out of a “legal coma of some sorts” DefendantAntoine L. Freeman J. D.
(Attorney at Law) Texas Bar No. 24058299 in his extreme outrageous (RICO)
conspirerepresentation of the entire civil suit DocketNo. A-180805 in full
concert, collusion, and corruption assistancewith the Co-Defendant(s) “JoyceM.
Guy and Edward McCray” herein
Resurface as on again acting “Attorney of Record”at this time frame of
September 11th 2009 Defendant “himself” Antoine L. Freeman J. D. (Attorney at
Law) herein as proof being described in Pro Se Plaintiff exhibit (E) attached herein
“Namely” The 58th Judicial District Court of Jefferson County “Ledger report” for
Civil Suit in Common Law Docket No. A-180805
As Pr Se Plaintiff Louis Charles Hamilton II herein attached exhibit (E)
100% sound “Meat-n-Potatoes” legal proofbeing submitted for a showing before
the “Honorable Justice” the actual entire legal status of the “Attorney of Record”
acts and rogue actions directed at the
Pro Se Plaintiff herein from the starting dates of December 18th 2007 and his
(Attorney at Law) continue wrongful “Obstructionof Justice” type engagement in
this (RICO)corrupted conspire activities affairs of some sort in concert with the
Co-Defendant(s) collectively
Some additional (2) months and exactly 20 some odd days later thereafter
when Co-Defendant(s) JoyceM. Guy and Edward McCray herein already legally
transfer said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block)
172, (Lot) 1-2 to the “Texas Department of Housing & Community Affairs”for said
$76,000 Federal Housing grant on June 18th 2009.
(18)
To include but not limited to the factual hostile and bold circumstance and
legal events thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at
Law) Texas Bar. No 24058299 herein during the time frame of “August 28th 2009
16. already being in legal possession, custody, and control over Pro Se Plaintiff
Motion for Production of Documents
For Productionof said “PropertyDeeds” which is a party to the Texas State
Civil Court action in Common Law Cause No. A-180805 and both “Defendant and
Co-Defendant(s)” collectively flat out refusal to Producesuch “PropertyDeeds”
well into 2015 after a Court order was even obtain on May 10th 2010 for the
production of said Property Deeds.
To include but not limited to the factual hostile and bold circumstance and
legal events thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at
Law) Texas Bar. No 24058299 herein during the time frame of “April 2nd 2008 and
April 11, 2008 well into November 13th 2009 when “Defendant and Co-
Defendant(s)” collectively
Already enjoying many (RICO) “Obstructionof Justice” tactics and engage
furtherance in “pilferage and plundering” the “Texas Department of Housing &
Community Affairs” for said in excess of the $76,000 Federal Housing grant.
Thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar. No 24058299 herein executed, and used the United States of America
“innocent mailing system”
And all court records and computer systems derive thereof in this (RICO)
Fraud and “Obstructionof Justice” scheme of things.
To include Defendant (Attorney at Law) herein execute even furtherance
this fraudulent “Skilled at Fraud Law” to his advantages corrupted “scheme of
things” for the legal behalf of the Co-Defendant(s) JoyceM. Guy and Edward
McCray herein
Collection to obtain all ill-gotten Pirate monetary gains as fully described in
Texas States Court before the 58th
Judicial DistrictCourt of Jefferson County Texas
and beforeThe “HonorableUnited States Justice”
“The Honorable Zack Hawthorn United States Magistrate Judge”
Presententertainment and examination herein now in “Justice” against
among others the “Civil Rights”, “Peace”, “Dignity” of the Pro Se Plaintiff “Louis
17. Charles Hamilton II herein a legal citizen and United States Naval Veteran within
the “State of Texas” and “The United States of America”.
“To include but not limited to” adding “insult to injury” actual damages
being inflicted wrongfully to the earning capacity of the Pro Se Plaintiff “Louis
Charles Hamilton II herein
Being legally represented as an “Independent Construction Contractor” in
this ongoing 2015 (RICO)scheme of things corrupted heist since November of
2007 of the Defendant and Co-Defendant(s) collectively herein
(19)
In addition to include but not limited to “Actual damages” in excess of
$3085.00 U.S. Dollars of the Pro Se Plaintiff Entire Independent Contractor
Company Construction tools being in a state of “Theft of Property” in this
“Breach of Construction Contract” civil action in first filed in Texas State
Court now such loss continue (RICO)style under the direction of the hands of the
Defendant for the legal wrong behalf of the Co-Defendant(s) ) Joyce M. Guy and
Edward McCray collectively described correctly herein in this now infamous
ongoing into 2015
(RICO)fashionable complex scheme of things involved with the Co-
Defendant(s) Joyce M. Guy and Edward McCray herein collectively conspire with
the leadershipof “Retainfor Hire” DefendantAntoine L. Freeman J. D.
(Attorney at Law) Texas Bar. No 24058299 herein
Being quite “fraudulently skillful, and legally in the professional
capacityas an “Attorney at Law” dealing with among other things Specialist
in “Fraud & Insurance litigation”
(20)
Being crafty apply againstthe Pro Se Plaintiff Louis Charles Hamilton
II herein in a civil suit in common law within Texas State Court thus now Pro
Se Plaintiff respectfully providing all such (RICO) and “Obstructionof
Justice”
Ongoing activities since 2007 subject matter now to the official handling
Jurisdiction before the “Honorable Justice” ofthe entitled above United
18. States DistrictCourt for the EasternDistrict of Texas namely “the “Honorable
Zack Hawthorn United States Magistrate Judge”
A endless ongoing (RICO) “CourtRoom Drama sorts of scheme of
things since activatedin November 17th
2007 with continue (RICO) acts and
actions of activities involving among other things, past
Hurricanes “Rita, “Humberto” and “Ike” the Co-Defendant(s) causing
among other things to the Pro Se Plaintiff herein “DirectLoss” ofall tools and
of lost wages in excessof$48,000.00U.S. dollars for a time frame exceeding
now seven(7) years and counting into 2015 in collusion, concertand
guidance’s with Defendant(Attorney at Law) herein
With this extreme “buck legalwild” cruel inflicted, unwanted financial
coup, and hardship being (RICO) fashion nicely imposed by “Commanderin
Attorney at Law Chief”
The DefendantAntoine L. Freeman J. D. (Attorney at Law) Texas Bar. No
24058299 himself herein
And for the “Legal financial wrongful benefit and “Civil behalf” of the Co-
Defendant(s) Joyce M. Guy and Edward McCray herein collectively in a Civil Suit
in Common Law within the State of Texas Jefferson County Docket No. A-
180805.
(21)
Pro Se Plaintiff, declares, affirm, and state further before the “Honorable
Justice” Defendanthimself Antoine L. Freeman J. D. (Attorney at Law) herein
legally continue to commit to “Actual Fraud” upon the 58th
Judicial DistrictCourt
of Jefferson County Texas
In this connection of (RICO) “Obstruction of Justice” in that on or about the
same 9/11/2009 “timeframe” filed before 58th
Judicial District Court Judge
“BobWortham” A Response to Pro Se Plaintiff Motion for Sanctions against
Defendant Antoine L. Freeman J. D. (Attorney at Law) herein containing in all
factual legal circumstances
19. “The Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 Public recorded“Affidavit” attachedbeing signed and dated
September 11th
2009 be Defendant “Attorney at Law” herein
Subscribed and Sworn “Statement” admitting among other things
Defendant, Joyce Guy, retained the services ofAntoine L. Freeman J. D.
(Attorney at Law): “For the purposeof writing a general denial so as to avoid a
default judgment being rendered against her.
Dated September 11th
2009 whilePro Se Plaintiff “Louis Charles Hamilton II
herein attached exhibit (D) 58th
Judicial DistrictCourt “DocketReport” for cause
No. A-180805and attached exhibit (E) 58th
Judicial District Court“Ledger Report”
for cause No. A-180805
(22)
Clearly showing beforethe “HonorableJustice” the Defendant Antoine L.
Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 engaging in mutable
“retained” services to include attendance to court hearing dates of August28th
2009 and then again on September 11th
2009
While Defendant(Attorney at Law) herein being in full possession, custody
and legal controlover discovery documents of Interrogatories, Request for
Admission, andRequest for Disclosure mail inthe
“UnitedStates Mailing System inaccordance withthe Texas Rules of Civil
Procedures 194.2, 197, and198,
During this time frame of on or about April 2nd
2008 andApril 11th
,
2008 as being describedin Pro Se Plaintiff attachedexhibit (E) 58th
Judicial
District Court“Ledger Report” for causeNo. A-180805
(23)
Clearly showing before the “HonorableJustice” the Defendant Antoine L.
Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 engaging received
possession, custody, and legalcontrolfrom Pro Se Plaintiff “Louis Charles
Hamilton II” herein a
20. “Motionfor Production of Document(s)dated August 12th
2009” onthe
certificate of mailing services forthe same cause No. A-180805 filedin the
JeffersonCounty Texas Courthouse
Said Motion for Production of Document(s) requested “among other
things” copies ofthe “Property Deeds” showing actualownershipof the
dwelling of 448 DeQueenBlvd. in Port Arthur Texas that’s being in the
possession, custodyand legalcontrol of the Co-Defendant(s) “JoyceM. Guy
and Edward McCray” herein
(24)
When the said Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein
in all factual circumstances and events conspire and retain Defendant Antoine L.
Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 in a (RICO) schemeof
things in December of 2007 and
Legally transfer said Property located at 448 DeQueen Blvd. in Port Arthur
Texas (Block) 172, (Lot) 1-2 to the “Texas Department of Housing & Community
Affairs”on June 18th 2009 having “Defendant (Attorney at Law) herein
For future fraudulent activities of said $76,000 Federal Housing Grant. As
being described in Pro Se Plaintiff exhibit (C) attached herein “Jefferson County
Texas Property Search Index” # 2009022762
And “SWMJ CONSTRUCTIONINC.” now being identified herein filed a
“Mechanics Lien” on June 18th 2009 on the same said Property located at 448
DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2
The said same property being a party to civil suit in common law since 2007
involvement with the Pro Se Plaintiff “Louis Charles Hamilton II herein and
Defendant (Attorney at Law) and the Co-Defendant(s) collectively.
As being described in Pro Se Plaintiff exhibit (C) attached herein “Jefferson
County Texas Property Search Index” # 2009022761 for a Civil Suit that was
conducted and executed on the month of November of 2007.
(25)
Response to Pro Se Plaintiff Motionfor Sanctions againstDefendant
Antoine L. Freeman J. D. (Attorney at Law) with attached “Affidavit” herein filed
21. as Pro Se Plaintiff attached exhibit (G) herein before the “HonorableJustice”
sealing the (RICO) “Obstruction of Justice”,
Fraud upon the Court combine conspiring involvementactivities of
Defendant (Attorney at Law) “legal defense” in an Honorable Court of Law for the
civil legal behalf of the Co-Defendant(s) collectively against the Pro Se Plaintiff in
a civil suit in common law.
(26)
Pro Se Plaintiff, declares, affirm, and state further before the “Honorable
Justice” Pro Se Plaintiff attached exhibit (H) herein before the “HonorableJustice”
Attached Affidavit of Co-DefendantJoyceM. Guy sealing the (RICO) conspiring
involvement activities of Co-Defendant(s) collectively consciousness corrupted
mutable countfraudulent “pattern and practices”
While in all legal factual acts and circumstances executed “among other
things” actually fraudulently appearing fromthe very startbefore a Honorable
Court of Law for the civil legal behalf of the Co-Defendant(s) own legal interest
collectively against the Pro Se Plaintiff in a civil suit in common law in 2007 and
continue to pilferage and plunder in 2009 during a “Live” ongoing docketNo A-
180805
To commit to Fraud of the 58th Judicial District Court of Jefferson county
Texas by and throughout their retain “Attorney at Law” being Defendant Antoine
L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 to wrongfully gaining
in excess of $76,000 U.S. Dollars Federal Housing grant.
And the furtherance’s of such (RICO)scheme of things against all of the
Jefferson County Court House 58th Judicial District court records and against the
“Texas Department of Housing & Community Affairs”for said executed Actual
Fraud thereof.
(26)
Pro Se Plaintiff, declares, affirm, and state further before the “Honorable
Justice” The HonorableUnited States District Courtof Texas Beaumont Division
Presiding Judge: Marcia A. Crone
Referring Judge: Keith F. Giblin
22. Pro Se Plaintiff attached exhibit (I) herein before the “HonorableJustice”
Defendants OriginalAnswer to U.S. Docket No. 1:2010-CV-00055Hamilton vs.
Freeman etal.
As Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 herein honestly “firstfoolish” (RICO) fraudulentmistakewithin
“Federal Jurisdiction Court of Law” was to Proceed as a Defendant being an
“Attorney at Law” representing himself before
“HonorableJustice” "a lawyer who represents himself has a fool for a
client"
*Especially against this particular Pro Se Plaintiff herein on a Federal Level.
(27)
Pro Se Plaintiff declares, affirm, and state further beforethe “Honorable
Justice” DefendantAntoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 herein honestly “second foolish” (RICO) fraudulentmistakewithin a
“Federal Jurisdiction Court of Law”
Was to proceeding in once again “retain Top Gun for Hire “Attorney at Law”
fashion” in the quite foolish (RICO) further “legalrepresentation” attempt of the
Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein
While “retain Top Gun for Hire“Attorney at Law” in April 30th
2010 being
Defendant (Attorney at Law) herein being negative in the pastfull possession,
custody and legal control over discovery documents of
Interrogatories, Requestfor Admission, andRequest for Disclosure mail in
the “UnitedStates Mailing System inaccordance withthe Texas Rules of Civil
Procedures 194.2, 197, and198,
During this time frame of on or about April 2nd
2008 andApril 11th
,
2008 as being describedin Pro Se Plaintiff attachedexhibit (E) 58th
Judicial
District Court“Ledger Report” for causeNo. A-180805.
(28)
23. While “retain Top Gun for Hire “Attorney at Law” in April 30th 2010
appearing before a Federal Court of Law now *Especially againstthis particular
Pro Se Plaintiff herein being a Defendant (Attorney at Law) herein bring forthwith
all of his past (RICO) “Obstructionof Justice” concealment negative activities as
related in the past Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar
No. 24058299
Being quite fully crafty sketchy & precise skill in a ongoing functional
fraudulent “legal objectives” in the concealment possession, custodyand legal
control over discovery documents of a “Motion for Production of Document(s)”
dated August 12th
2009” onthe certificate of mailing services forthe same
cause No. A-180805filed in the JeffersonCounty Texas Courthouse
Said Motion for Production of Document(s) requested“among other
things”copies of the “Property Deeds”showing actual ownershipof the
dwelling of 448 DeQueenBlvd. inPort Arthur Texas that’s being inthe
possession, custody andlegal control of the Co-Defendant(s) “Joyce M. Guy and
Edward McCray”herein
Transferring of said Property located at 448 DeQueen Blvd. in Port Arthur
Texas (Block) 172, (Lot) 1-2 to “Texas Department of Housing & Community
Affairs” as Filed in Jefferson County Clerk Records # 2009022762,for a $76,000.00
Federal Housing Grant,
As being described in Pro Se Plaintiff attached exhibit (C) herein “Jefferson
County Texas Property Search Index” while under the “retained guidance’s
services of Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299
(29)
Being now a (Rogue) “Attorney at Law” directly engaging to continue with
this ongoing (RICO) “buck wild” Top Gun “Attorney at Law” fashionable “scheme
of things” involving “firstand foremost” the complete fraudulent “courtrecords”
of the 58th
Judicial District Courtof Jefferson County Texas
Before the HonorableJustice Presiding United States Judge Marcia A. Crone
and referring HonorableMagistrate Judge Keith F. Giblin
24. (30)
Pro Se Plaintiff declares, affirm, and state further beforethe “Honorable
Justice” DefendantAntoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 herein honestly “thirdly foolish” (RICO) fraudulentmistakewithin a
“Federal Jurisdiction Court of Law”
*Especially against this particular Pro Se Plaintiff herein on a Federal Level
was to proceeding stating in Pro Se Plaintiff exhibit (I)
“Defendantdenieseach and every allegation of Plaintiff’s Original
Petition, and Demandsstrict proof thereof as required by the Texas Rules of Civil
Procedure. (OK)
(31)
Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 herein pasthistory of on again and off again slipping in and out of a self
induced “legal coma of some sorts” for the civil legal behalf and civil interest of
the Co-Defendant(s) Joyce M. Guy and Edward McCray collectively
Against the Pro Se Plaintiff in a civil suit in common law Docket No. A-
180805 with “Actual Damages in excess of $340,000.00 U.S. Dollars since date of
injury November 17th 2007 with 6 % interest incurred since date of Injury
Being now a Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas
Bar No. 24058299 in U.S. Cause No. 1:14-CV-592 demands in the pastbefore a
Subject Matter “Federal Jurisdiction” boldly claiming “among other things”
Pro Se Plaintiff herein must fully adhere to “Texas Rules of Civil
Procedure” and provide the strictest proofthereof before The United States District
Court of Eastern Texas “Beaumont Division
While Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 fully now in 2010 having executed his “Attorney at Law” future (RICO)
fashionable acts and actions status of completed among other things the
outstanding
25. “Obstructionof Justice” Fraud upon a Texas Court of Law fraudulent
concealment of “Property Deeds”, and being a party to the absolutely destruction
of physical court evidence being said dwelling located at 448 DeQueen Blvd. in
Port Arthur Texas (Block) 172, (Lot) 1-2
(32)
Notwithstanding now in April 30th 2010 appearing before a Honorable
Court of Law on a Federal Level no less Defendant Antoine L. Freeman J. D.
(Attorney at Law) Texas Bar No. 24058299 herein completely already “legally
molestation” and having his “rogue wayward relationship”
In enjoyment of “butt screwing” the Pro Se Plaintiff herein” since December
18th 2007 well into the new year of our Lord 2015 before this “Honorable Justice”.
By legal commitments “among other things” (RICO) “Obstructionof
Justice, Fraud of a Texas State Court and denying the Pro Se Plaintiff “Louis
Charles Hamilton II herein appearing as acting “Attorney of record”in a Pro Se
fashion before a Civil Court of Law in a suit in common law in and Forthe State of
Texas Docket No. A-180805
Whereby Pro Se Plaintiff having the full weight and legal enjoyment, &
same required respectof said “Texas Rules of Civil Procedure” as the Defendant
Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein so
fully enjoyed to the complete destructive disadvantage over the Pro Se Plaintiff
“Louis Charles Hamilton II” herein civil rights, peace and dignity
(33)
And justly bringing forth such introduced well legally documented (RICO)
criminal history of a corrupted “Attorney at Law” among other things
And his foolish legal “shenanigans” onceagain brought forth in April 30th
2010 beforethe Honorable Justice Presiding United States Judge “Marcia A.
Crone” and referring HonorableMagistrate “Judge Keith F. Giblin” and
“Justice so served stupidity invited thereby their own (RICO) criminalpast,
present, and future schemeof things “acts and activities of their on making of
Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
26. And Co-Defendant(s) “JoyceM. Guy” and “Edward McCray” collectively
herein into the Federal Jurisdiction Level as being described this undersigned
dated herein in Pro Se Plaintiff exhibit (I).
(34)
Pro Se Plaintiff declares, affirm, and state further beforethe “Honorable
Justice” Co-Defendant(s) “JoyceM. Guy” the moment “she” & Husband Co-
Defendant “Edward McCray”, herein committed to among other things “Physical
Assault& “Theft of Property” Namely all Construction Company Tools as
identified in The Pro Se Plaintiff attached exhibit (J) herein
“Original Complaint” filed in the 58th
Judicial District Courtof Jefferson
County Texas Cause No. A-180805.
As showing the Construction Tools Listed as follows:
a. Brand New Hitachi Air Compressor #2700009 $680.00
b. Bosch Drill M# Brute S# NV $345.00
c. “PortacableSkill saw $137.00
d. Dewalt Sawall$97
e. “Hitachi Nail Gun (Framing) $327.00
f. “Hitachi Roofing Nailer $315.00
g. Gas Power Generator $300.00
h. Extension ladder $127.00
i. 100 ft. of air hose $95.
j. 50ft. of air hose$42.
k. 100ft. electric cord $70
l. 50ft. electric cord $38
m. (4) Framing hammers $37. (each)
n. “Pro Se Plaintiff “PersonalHammer” $48.
o. “Leather tool belt” $50.
p. Kobalt Razor Knife $17.
q. Swanson pencilset & refills $22.
r. “Black tool box & Respiratory $138.00
s. “Extreme Safety Face Shield” $30
t. Ear plugs (2) pack $16.
u. (4) Normal face respirators with strap $12.
v. Small assortmentpliers set $35.
27. w. (2) Tuck pointers $24.
x. (1) Squaremouth shovels $18.
y. (1) set of blueprints $1200.00
z. Gas container 15.
aa.Masonry trowel$18.
bb. “Fatmax 35ft. tape measure$30.
cc. Catspaw nail puller $12.
dd. Speed square$8.
ee. Contractor Calculator $34.
ff. Crowbar $17.
gg.Utility knife (3) $9. (Each)
hh. Nail Punch $8.
ii. Maxx Gloves $34.
jj. Canvas Tarp 95ft. X 180ft. $100.00
kk.Roofing shovels (2) $48. (Each)
ll. Saw blades with drill bits $24.
mm. (2) Speed square(Plastic) $5. (Each)
nn. 25ft. “Fatmaxx tape measure $19.00
oo. 3-way air hose fitting set $38.
pp. Case of Gatorade $12.
qq. Residential framing book $21.
rr. (2) Paint brushes $14. (Each)
ss. (1) Paint scraper $14.
tt. (1) Paint scraper wirehandle $10.
(35)
Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.
24058299 herein fully conspire, and direct his (RICO) Obstruction of Justice”,
Fraud of the 58th
Judicial Court of Jefferson County Texas
Among other fraudulent devices concocted by said Defendant for the
WrongfulCivil Benefit and behalf of the Co-Defendant(s) “JoyceM. Guy” and
“Edward McCray” herein againstthe Pro Se Plaintiff
To deprive the Pro Se Plaintiff in addition to the “Breach of Construction
Contract to fix said dwelling which Insurances money(s) in excess of $10,800.00
28. U.S. Dollars had been designated for said damages repairs as a resultof
Hurricanes “Humberto”
Defendant (Attorney at Law) fully awareof the complaint and all discovery
requests therein fromDecember 18th
2007- April30th
2010 and attached
“Himself” to deprivethe Pro Se Plaintiff of his entire Construction Company tools
as being described abovein paragraph (34) aboveand further illustrated in Pro Se
Plaintiff attached exhibit (J) herein
(36)
Pro Se Plaintiff declares, affirm, and state further beforethe “Honorable
Justice” such Construction Company tools do in fact did exist and is fully described
and fully supported in Pro Se Plaintiff attached exhibit (K) herein “Copy” of Lewis
Garza “Affidavit” original being filed in the Jefferson County Texas Courthouse
DocketNo A-180805
Subscribed and Sworn” Affidavitof “Lewis Garza”
Stating: On November 17th
, 2007 I took my stepson to 448 DeQueen Blvd. in Port
Arthur Texas. To do work on a house. He had a few thousand dollars in tools.
The Owner of the home kept all of the tools and refused to return them.
Ladders, generator, Nail guns, & numerous hand tools.
Lewis Garza
Subscribed and Sworn on the 14th
day of November 2014
“Kendra Monk” Notary Public, State of Texas
(37)
Pro Se Plaintiff declares, affirm, and state further beforethe “Honorable
Justice” as a result of Defendant Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar No. 24058299 (RICO),
29. “Obstructionof Justice”, Fraud of the 58th Judicial Court of Jefferson
County Texas among other acts and actions Defendant (Attorney at Law) herein
“Foolishly” directed, being in concert, collusion, “Attorney at Law”
concealment of records and legally engaging collectively with the Co-Defendant
“JoyceM. Guy and Edward McCray herein the “absolutely destruction” of
“physical evidence” …
Namely the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas
(Block) 172, (Lot) 1-2 while being in an ongoing civil action in November of 2007
Pro Se Plaintiff declares, affirm, and state furtherancebeforethe
“HonorableJustice” added into this equation in 2009 Defendant Antoine L.
Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 (RICO) in concert,
collusion, concealment and legally engaging collectively
With the Co-Defendant “JoyceM. Guy and Edward McCray herein in the
further fraudulent plunder for more “Pirate Loot” there after already in the past of
scheming, plotting twisted robbery,
And actual heist thereof of “Private Insurances Companies repair funds and
FEMA repair Funds, for the following Hurricanes “Rita”, Humberto, and “Ike” on
the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas
(38)
To include but not limited to the Co-Defendant “JoyceM. Guy and Edward
McCray herein scheming, plotting twisted robbery, and actual heist thereof of
“Private Insurances Companies repair funds and FEMA repair Funds, for the
following Hurricanes “Rita”, Humberto, and “Ike” on the dwelling located at 448
DeQueen Blvd. in Port Arthur Texas
Scheming, plotting twisted robbery, and actual heist thereof of “Private
Insurances Companies repair funds and FEMA repair Funds, for the following
Hurricanes “Rita”, Humberto, and “Ike” on the dwelling located at SBD Lake
View block 4 Lot 10
which said Co-Defendant “JoyceM. Guy” having enjoyment over her
Mother Legal Affairs as described in the “Powerof Attorney” on filed and attached
herein Pro Se Plaintiff exhibit (C) “Jefferson County Search Index Instrument #
2010042042
30. As this additional property also located at SBD Lake View block 4 Lot 10
being in the possession, custody, and legal control of Co-Defendant “Joyce M.
Guy” herein having also a “”Mechanics Lien”
Filed against this property on November 16th 2010 on file and attached
herein Pro Se Plaintiff exhibit (C) “Jefferson County Search Index Instrument
#2010042043
(39)
Notwithstanding Co-Defendant “JoyceM. Guy” herein Scheming, plotting
twisted robbery, and actual heist thereof of “Private Insurances Companies repair
funds and FEMA repair Funds, for the following Hurricanes
“Rita”, Humberto, and “Ike” on the dwelling located at 5050 east 7th street in
Port Arthur Texas (Being) Norma Guy home (Mother)
(40)
Notwithstanding Co-Defendant “JoyceM. Guy herein scheming, plotting
her twisted robbery, and actual heist thereof against the “Aging, and Disability
Elderly Citizens within Jefferson County Texas from
the start time frame of May 7th 1997 the company called 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 identified herein also under Pro
Se Plaintiff attached exhibit (C) as Instrument # 49894
In which this company called G and G Service Company P.O. Box 515, 416
DeQueen Blvd. in Port Arthur Texas is “Actually” an illegalmedical business
designed for the disable elderly senior citizens of Jefferson County Texas
On going from the dates of May 5th1997 throughout January 7th 2010 for a
period of 13 years of “Earn Income” with cash being paid to all “employees” no
taxes being paid ever to the “State of Texas or (IRS) for the United States of
America
(41)
31. And G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port
Arthur Texas this assume “medicalbusiness” operation and office location is
“Actually” a “vacant lot” in Port Arthur Texas
When it was order shut down by the “State of Texas Department of Aging
and Disability Services” on January 7th 2010 until a real HCSSA licensed being
obtain.
After Pro Se Plaintiff “Louis Charles Hamilton II” herein conducted his own
exclusive Cmdr. Blue fin (USN) deep sea in-depth investigation into all described
Defendant and Co-Defendant(s) herein corrupted History being described in
among other things in
Pro Se Plaintiff attached exhibit (L1) Certified Mail:
70031010000368381858
From “State of Texas Departmentof Aging and Disability Services” to G
and G Service Company (Owner) Co-Defendant “Joyce M. Guy” stating among
other things
(42)
“You are in violation of health and safety code chapter 142 by engaging in
home health or personal assistances services which includeshand-on personal
care; by representing to the publicthat it “G and G Service Company” is a
provider of home health, or personal assistance services which includes hands-on
personal care for pay.
“You do not have a valid HCSSAlicense; therefore, you must immediately
cease providing these services or representing to the public thatyou provides these
services.
And described further in Pro Se Plaintiff attached exhibit (L2) herein
“State of Texas Department of Aging and Disability Services” letter to the
Pro Se Plaintiff stating among other things:
We are in receipt of your recent inquiry regarding your complaint made on
September 2nd 2009 regarding GNG Service Company, 5050 East 7th street, Port
Arthur, Texas 77640
32. (43)
Which the Pro Se Plaintiff wish to clearly point out to the “Honorable
Justice” this complaint being made in exhibit (L2) attached herein was executed on
September 2nd 2009 to the “State of Texas Department of Aging and Disability
Services” (exactly) three (3) months
there after the Co-Defendant “JoyceM. Guy and Edward McCray herein
Legally transfer said Property located at 448 DeQueen Blvd. in PortArthur Texas
(Block) 172, (Lot) 1-2 to the “Texas Department of Housing & Community
Affairs” on June 18th 2009 in collusion, conspire fraudulent concert with
Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
For future fraudulent activities of monetary gain in excess of said $76,000
Federal Housing Grant.
As being described in Pro Se Plaintiff exhibit (C) attached herein “Jefferson
County Texas Property Search Index” # 2009022762
And “SWMJ CONSTRUCTIONINC.” now being identified herein filed a
“Mechanics Lien” on June 18th 2009 on the same said Property located at 448
DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2
The said same property being a party to civil suit in common law since 2007
involvement with the Pro Se Plaintiff “Louis Charles Hamilton II herein and
Defendant (Attorney at Law) and the Co-Defendant(s) collectively.
(44)
Notwithstanding Co-Defendant(s) Joyce M. Guy and “Edward McCray”
herein having another business namely
J Can Company 1807 East 7th Street PortArthur Texas (Office) located at
448 DeQueen Blvd. in Port Arthur Texas 77640 being legally owned by the
Defendant(s) “Joyce Guy and Edward McCray”, assumed name filed on April 11th
2008 Jefferson County Clerk records #72594 as described in Pro Se Plaintiff
exhibit (C) attached herein
1807 East 7th street in Port Arthur Texas is actually (Once again) as Pro Se
Plaintiff state before the “Honorable Justice” being a actual “Vacant Lot” which
33. has been on occasions raided by the PAPD Dept. (Police) for engaging in a “illegal
Scrap Industry”
“Moreover” once all “Illegal Scrap Metal” other then used aluminum Cans
being recycle and obtain in the City of Port Arthur Texas city limits by Defendant
“Edward McCray”, by the assume business J Can Company
Being now further introduced as “Scrap Metal” in connection with the
company “Cars and Pieces” business Located in Beaumont Texas (Office) also
located at 448 DeQueen Blvd. in Port Arthur Texas 77640 under the assume name
of Edward McCray Sr. (Owner)
(45)
Making the final “Legal sales” of all “illegal scrap”obtain in the City of Port
Arthur Texas city limits by Co- Defendant “Edward McCray”,
“Moreover” Pro Se Plaintiff Louis Charles Hamilton II herein (Fully) quite
“elementary sure and certain” after prior raids by the (PAPD) Police into “illegal
scraping” business of J Can Company that this “many years of “baffling exchange”
mystery of transfer rate of
“Illegal scrap” from Port Arthur Texas City Limits into now “Clean” legit
able sales of “ScrapeMetal” has been confusing the (PAPD) Police in the
exchange rate form now “legal scrap”derived in “Beaumont Texas” from J Can
Company in Port Arthur Texas “Namely” to wit:
“Cars and Pieces” business in Beaumont Texas being now a major illegal
scrap metal “money laundering” “Earn Income” system for Co- Defendant
(Edward McCray) and Co-Defendant (Joyce M. Guy) herein derived from this
additional (RICO) “criminal endeavor.
(46)
Pro Se Plaintiff further state, affirm and declare before the “Honorable
Justice” prior before raids by the (PAPD) Police into “illegal scraping” business of
J Can Company
34. Pro Se Plaintiff herein was “fully physically present” in the year of 2007
before the “Breach of Contract” affairs occurred and being quite in disbelief fast
shockwhen (PAPD) Police snuck in out of nowhere so super fast upon J Can
Company (PAPD) Police went directly to some “illegal scraping metal material”
Co- Defendant (Edward McCray) herein had hidden in some bushes @ J
Can Company 1807 East 7th Street PortArthur Texas “took” some Pictures,
confiscated said “illegal scraping metal material” and (PAPD) Police disappeared
as fast as they “Snuck in”
(47)
Pro Se Plaintiff further state, affirm and declare before the “Honorable
Justice” prior before raids by the (PAPD) Police into “illegal scraping” business of
J Can Company
Pro Se Plaintiff herein was once again “fully physically present” in the year
of 2007 before the “Breach of Contract” affairs occurred as Co- Defendant
(Edward McCray) herein had hidden “illegal scraping metal material” in the trunk
of his car one scrap material being a old radiator
(48)
The exact moment as Co-Defendant (Edward McCray) feeling safety and
attempted to driving away from the location of obtaining “illegal scraping metal
materials” for the business of J Can Company
(PAPD) Police snuck in out of nowhere so super fast upon J Can Company
co-owner being Co- Defendant (Edward McCray) herein, pulled his car over made
him open the trunk and took more pictures of said “illegal scraping metal material”
in the trunk of his car of the
Co-Defendant (Edward McCray) herein furthermore confiscated said
“illegal scraping metal material” and (PAPD) Police disappeared (Twice) as fast as
they “Snuckin” on his car at this particular point and time
“Goofy”so extra slow to figure out they being (PAPD) Police been
watching him Co- Defendant (Edward McCray) herein the entire time “high tech
style” from quite a distance away, ha ha…Da”
35. Notwithstanding Co- Defendant (Edward McCray) herein, being under they
(PAPD) Police “continual spying eyes” as long as he breathing” for “among other
things”
(49)
Engaging in using said J Can Company located at 1807 East 7th Street in
Port Arthur Texas as a Front for the distribution of “Crack Cocaine Industry” for
an additional (RICO) earn income.
Co-Defendant “Edward McCray” herein in the past had a “earn
income” derived from the sales of “DangerousDrugs” JeffersonCounty Cause
No. 97903 and Cause No. 146302
And upon further information and belief Co-Defendant “Edward
McCray” herein obtaining FederalCharges derived in the performance of
such as found guilty of five violations of the Mann Act and sentenced for a total of
10 years—some of the sentences being consecutive and some concurrent.
No doubt that Co-Defendant “Edward McCray” herein transported the same
woman to various cities over a period of a year for prostitution.
There were five counts, two of which charged transportation in commerce of
the named woman between designated cities for the purposeof prostitution.
Each was an offense under 18 U.S.C. 2421 which provides a fine of $5,000
or five years in prison or both.
Three of the five counts charged that Co-Defendant “Edward McCray”
herein persuaded, induced, enticed, or coerced this same woman 'to go from one
place to another' in interstate commerce for the purposeof prostitution,
Each count charging on offense under 18 U.S.C. 2422 which carries a fine
of $5,000 or five years in prison or both.
As Co-Defendant “EdwardMcCray” herein in the past enjoyed this
continuous prostitution enterprise
Edward McCRAY v. UNITED STATES.
405 U.S. 944 (92 S.Ct. 967, 30 L.Ed.2d 815)
36. Edward McCRAY v. UNITED STATES.
No. 71-5547.
Decided: February 22, 1972
dissent, DOUGLAS
(50)
Pro Se Plaintiff further state, affirm and declare before the “Honorable
Justice” the Co-Defendant “JoyceM. Guy” herein already having a “Live Actual
Bullet” lodge presently in her “Skull” as a result of her own domestic violence
acts and actions of the past.
As Pro Se Plaintiff “Louis Charles Hamilton II” herein further state, affirm
and declare as appearing before “The Honorable Zack Hawthorn United States
Magistrate Judge”,
Pro Se Plaintiff under gone many “hostile suffrage” dealing with “Bonnie
and Clyde” being namely Co-Defendant(s) “Joyce M. Guy and Edward McCray”
herein
Now such a additional furtherance executed (RICO) Fraudulent “Criminal
Enterprise” in June 18th of 2009 wrongfully committed to gaining in excess of
“among other things” $76,000 U.S. Dollars Federal Housing Grant. As this also
involved the Pro Se Plaintiff “Louis Charles Hamilton II” herein since 2007
And the furtherance’s of such a corrupted (RICO) scheme of things executed
against all of the Jefferson County Court House 58th Judicial District court records
and executed against the “Texas Department of Housing & Community Affairs”for
said executed “Actual Fraud”
Of a Federal Housing Grant obtain and derive thereof during the legal affairs
of a civil suit in common law filed in Jefferson County Texas Cause No. A-180805
Such a corrupted additional (RICO)scheme of things executed by and
through Attorney of Record in Texas State Court Cause No. A-180805 being
Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299
herein.
(51)
37. Good and sufficient material facts, acts and event, legal circumstances, and
all subject matter contain herein officially exist and is supported in all of the Pro
Se Plaintiff attached exhibit(s) filed herein for Freezing all of Defendant Antoine L.
Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and
Edward McCray” herein
Business records, banking records, personal banking records, property
deeds, and all assets for all of the above listed Defendant(s) collectively in the
United States of America.
Which is necessary to protect this HonorableUnited States DistrictCourt
for the Eastern District of Texas, Ability to decide fromthe preponderances in
deciding the weight of factual evidence,
With furtheranceallowances in the Honorable United States District Court
for the Eastern District of Texas
Ability in fully applying justawards and compensation for “actual damages”
of all equitable relief for the Pro Se Plaintiff herein Within all assets, moneys and
properties held directly or indirectly by the
Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-
Defendant(s) “JoyceM. Guy and Edward McCray” herein for all of the Pro Se
Plaintiff “Louis Charles Hamilton II”
Direct “Actual damages”, emotional pain and suffrageas described in the
U.S. Complaint of the Pro Se Plaintiff Cause No. 1:2014-CV-592
(52)
Pro Se Plaintiff further state, affirmand declare before the “Honorable
Justice” DefendantAntoine L. Freeman J. D. (Attorney at Law) herein after filing a
Original Denial on December 18th
2007 and forwarding such to the Pro Se Plaintiff
in Cause No. A-180805, fromthatexact moment in time
Pro Se Plaintiff next official officedocument, note, correspondence,
mailing, letter, text, email, court document being received fromDefendant
Antoine L. Freeman J. D. (Attorney at Law) in the capacity of a “Attorney of Law
38. retain for the Co-Defendant(s) collectively herein is being on the exact date of
October 14th
2009
Even there after Pro Se Plaintiff requesting a responsefrom Defendant
“himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299
herein whomalready being in full legal possession, custody, and controlover
discovery documents of
Interrogatories, Requestfor Admission, andRequest for Disclosure in
accordance withthe Texas Rules of Civil Procedures 194.2, 197, and198,
During this time frame of on or about April 2nd
2008 andApril 11th
, 2008
(53)
Pro Se Plaintiff further state, affirm and declare before the “Honorable
Justice” DefendantAntoine L. Freeman J. D. (Attorney at Law) herein “Never”
informed the 58th
Judicial DistrictCourt in cause No. A-180805in official office
document, note, correspondence, mailing, letter, text, email, phone transmitting
cell phone or even a official
“Courtdocument” of wishing to no longer be “retain” Attorney of record
throughoutthe “Time Frame” of December 18th
2007 –November 12th
2009
(54)
Pro Se Plaintiff further state, affirm and declare before the “Honorable
Justice” fully committed to Obstruction of Justice”, Fraud of the 58th Judicial
District Court cause No. A-180805 to:
Scuttle, hide, delete, destroy, concealment, defeat, erase, and obliterate all
records, thereof concerning Pro Se Plaintiff “Material Facts”surrounding events
and circumstances as a result of Hurricanes “Rita”, “Humberto”, and “Ike” at the
locations first and foremost 448Dequeen Blvd. in Port Arthur Texas and the
involvement of the
“Unknown” Keep 100% secret, identity of all Home Owner Insurance
Company(s), all Construction Contractor contracts obtain in process thereof fixing
said needed repairs, banking records of Co-Defendant(s) “Joyce M. Guy” and
“Edward McCray”
(55)
39. As they squander completely all funds from events and circumstances as a
result of Hurricanes “Rita”, “Humberto”, and “Ike” as said “Court Order” require
the Co-Defendant(s) “JoyceM. Guy” and “Edward McCray” to producesuch
(Records)to the Pro Se Plaintiff herein.
Notwithstanding “VIP” same said court order of the 58th Judicial District
Court cause No. A-180805 Pro Se Plaintiff exhibit (B) attached herein
“Require” in full the “actual identity ownership” of said dwelling “Namely”
copies of property deeds that Defendant “himself” Antoine L. Freeman J. D.
(Attorney at Law) Texas Bar No. 24058299 herein
“Actually” made “Physical Evidence” in a ongoing civil suit since 2007
being both first the “propertydeeds” for the dwelling located at 448 DeQueen
Blvd in Port Arthur Texas Block 172 Lot 1-2 being concealment and in a state of
disappearance from the court records
Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar
No. 24058299 herein “Actually” made second being concealment and in a state of
disappearance from the court records “Physically and “entire complete flipping
“structural home” for the dwelling located at 448 DeQueen Blvd in Port Arthur
Texas Block 172 Lot 1-2 in 2007
(56)
A signature “Harry Houdini” Defendant “Attorney at Law” herein
completely “material evidence disappearance act” before the 58th Judicial District
Court records… Destroying this such “Priceless Evidence” on or about after the
dates of June 18th 2009 thereafter Co-Defendant(s) “Joyce M. Guy” and “Edward
McCray”
Then the secret (RICO)Enterprise events and circumstances surrounding in
the production of “reappearance act” of a “Brand New” $76,000.00 U.S. Dollars
“Federal Housing Grant” home for the dwelling located at 448 DeQueen Blvd in
Port Arthur Texas Block 172 Lot 1-2 in 2007 as records described in Pro Se
Plaintiff attached exhibit (C) filed herein “Jefferson County Texas” search Index
40. Pro Se Plaintiff declare, affirm and state before the “Honorable Justice”
pointing out the facts and circumstances that if Defendant “himself” Antoine L.
Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein
“Actually” complied with all of the Texas rules of Civil Procedurein this
civil suit in common law docket No. A-180805 as an “Attorney in Law” in for the
State of Texas is so requires following back in during this time frame of on or
about
April 2nd
2008 andApril 11th
, 2008 as being describedin Pro Se Plaintiff
attachedexhibit (E) 58th Judicial District Court “Ledger Report”for cause No. A-
180805 approximately one (1) year later
On or about “April 2nd 2009 this civil suit would having been so served a
full, final and complete ending before “Justice” of the 58th Judicial District Court
of Jefferson County Texas,
Before the Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward
McCray” herein having and fraudulently attempts to commit to (RICO)enterprise
in the legal “Transfer of said Property”
Located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2
to “Texas Department of Housing & Community Affairs” as Filed in Jefferson
County Clerk Records # 2009022762,
for a $76,000.00 Federal Housing Grant, as being described in Pro Se
Plaintiff attached exhibit (C) herein “Jefferson County Texas Property Search
Index”
Before Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein further
assistances of their collectively (RICO)scheme of things on or about June 18th
2009 as when in time filed a future “fraudulent financing statement” in Jefferson
County Clerk Records instrument # 2009022763 in the connection thereof
For fraud activities engagement of the “Texas Department of Housing &
Community Affairs” for a monetary gain of in excess of said $76,000.00 U.S.
Dollars Federal Housing Grant
41. After the Co-Defendant(s)“Joyce M. Guy and Edward McCray” herein
already squandering all of the Home Owner Insurances funds, FEMA Funds
designated for “actual building repairs” of said Property located at 448 DeQueen
Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2
Being as a result of Hurricanes damages from Hurricanes “Rita”, Humberto,
and “Ike” as described in Pro Se Plaintiff attached exhibit (J) attached herein Pro
Se Complaint Plaintiff Louis Charles Hamilton II being a Party thereof docketNo.
A-180805
(57)
Pro Se Plaintiff declare, affirm and state before the “Honorable Justice”
furthermore a “Mechanics Lien” in April 2nd
2009 andApril 11th
, 2009 being
well enforced and in place in favor of the Pro Se Plaintiff “Louis Charles Hamilton
II” herein by the 58th Judicial District Court of Jefferson County Texas,
As the Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar No. 24058299 herein “legal Choice as described against him was to
commit to “Obstructionof Justice”, Fraud of The Court and complexly
Scuttle, hide, delete, destroying, concealment, defeat, erase, and obliterate
all records thereof being requested in the “productionof a discovery phase” civil
suit A-180805 since November 17th 2007
And the Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law)
Texas Bar No. 24058299 herein signature “Harry Houdini” material evidence
disappearance act of a “Entire Home”
From the “Honorable 58th Judicial District Court of Jefferson County
Texas” court records.
(58)
Pro Se Plaintiff declares, affirm, moves, and state furtherance’s before the
“Honorable Justice” furthermore that Defendant “himself” Antoine L. Freeman J.
D. (Attorney at Law) Texas Bar No. 24058299 “own” a out of controlrubber
“Affidavit Stamp” in processing, many infamous false statements, lie, half
truths, in the assistances to further all (RICO) “Obstructionof Justice”,
42. Fraud upon any “Courtof Law” within the “United States of America” as so
committed to, while Defendant (Attorney at Law) possessingno ethical, or “legal
responsible accountability” for processingDefendant “himself” Antoine L.
Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein “own legal
actions”
As required by “Federal and State Laws” in Defendant (Attorney at Law)
Texas Bar No. 24058299 “ omit”, “refrain”, “shun”, “avoid” and actually fully
renounce “himself “ from such among other things engaging in a (RICO)
enterprising endeavor and all conduct derive thereof,
Not being in the absolutely condemning position of “Obstructionof Justice
before a Honorable Court of Law,
As well “among other thing” not “foolishly” being in the legal professional
fiduciary duty capacity as a “officer of the court” while being in the “illegal”
possession, custodyand control of committing to full acts and actions of
Fraud upon a “Honorable Court of Law” in connection with all (RICO)
activities and events as being described completely herein,
As well as described in all attached exhibit (ABCDEFGHIJKL1, AND L2)
in exhibit, Original Complaint U.S. Docket No. 1:2010-CV-00055
As Pro Se Plaintiff Herein Moves Respectfully in the “Interest” of Justice as
presented in this Original Complaint U.S. Docket No. 1:2014-CV-592
(59)
Pro Se Plaintiff declares, affirm, moves, and state furtherance’s before the
“Honorable Justice” Defendant “himself” Antoine L. Freeman J. D. (Attorney at
Law) Texas Bar No. 24058299 herein be further
“Order to Show Cause” why his “Attorney at Law” License for the State of
Texas being in a state of “suspendedfrom practicing” with the “State of Texas”
In light of all damaging evidence attached herein having actual “Outstanding
physical weight of “Merit” in favor of the Pro Se Plaintiff Louis Charles Hamilton
II herein before the Honorable Court Justice”
43. Warranting such a suspended ofDefendant (Attorney at Law) license herein
is absolutely justifiable and well within the “Interest of Justice” within the “United
States of America” jurisdiction for the above entitled
“Honorable Court Justice” to protectthe “public interest of many others
from falling to suchfaith of among other things (RICO),
“Obstructionof Justice”, processingFraud upon a Court of Law in and for
the State of Texas scheme of things
(60)
With other fraudulent civil activities of Defendant “himself” Antoine L.
Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 as described herein
being fully committed by said Defendant (Attorney at Law) for profit no less.
(62)
Pro Se Plaintiff declares, affirm, moves, and state furtherance’s before the
“Honorable Justice” Defendant “himself” Antoine L. Freeman J. D. (Attorney at
Law) Texas Bar No. 24058299
Warranting a “Order to show cause” why Pro Se Plaintiff Louis Charles
Hamilton II herein not be entitled to enjoy a “Temporary Restraining Order”,
freezing the destruction or alter of all records, and documents set forth herein,
And further “Order to show cause” why Pro Se Plaintiff Louis Charles
Hamilton II herein not be entitled to enjoy to secure all of the
DEFENDANT ANTOINE L. FREEMAN J.D. ATTORNEY AT LAW
HEREIN AND CO-DEFENDANT(S) JOYCE M. GUY AND EDWARD
McCRAY HEREIN, Collective Assets.
Warranting a further “order to showcause”why such a suspended of
Defendant (Attorney at Law) license herein being not enforced by the Honorable
Justice”
Until the full “processing adjudication”, “completion”, “negotiations”, and
or “Jury Trial” being broughtforth on all described complex subjectmatter
jurisdiction
44. As presented before the “HonorableJustice” by the Pro Se Plaintiff Louis
Charles Hamilton II herein.
(63)
Freezing all of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein
and all Co-Defendant(s) “JoyceM. Guy and Edward McCray” herein
Business records, banking records, personalbanking records, property
deeds, court records, phonerecords, computer records, notes, ledgers, diaries,
(IRS) records, Insurancecompanies(s) records, FEMA records, Hurricanes“Rita”,
“Humberto” and “Ike” records thereof,
And all assets for all of the above listed Defendant and Co-Defendant(s)
collectively in the United States of America described as follows:
(64)
Freezing enforcedagainst Defendant AntoineL. FreemanJ. D.
(Attorney at Law) Texas Bar No. 240582999 herein as Follows:
Freezing all records, correspondence, notes, phonerecords, recording,
communications, and other documents concerning or relating to any
correspondenceor communications with Co-Defendant(s) JoyceM. Guy and
Edward McCray fromthe dates of November 17th
2007 throughoutDecember 1st
2015.
(65)
Freezing all records, correspondence, notes, communications, and other
documents that concern or relate to any conversations, discussions,requests for
advice, or any matter relating to the above-captioned case.
(66)
Freezing all records, correspondence, notes, communications, and other
documents concerning or relating to any correspondenceor communications with
any Defendant, or Defendants or with any person or persons initially named as
45. Defendants in this case regarding “Hamilton vs. Freeman et al filed February 2nd
2010 U.S. CauseNo. 1:2010-CV-00055
(67)
Freezing all records, correspondence, notes, communications or other
documents which are relevant to the allegations of this complaint, and any and all
records, correspondence, notes, communications or other documents which may
lead to such relevant evidence.
(68)
Freezing all desk calendars, appointment books, journals, logs, and diaries
which concern or relate to the Defendant, in the performanceof job description,
duties, instructions, assignments, or evaluations of Co- Defendant(s) JoyceM. Guy
and Edward McCray.
(69)
Freezing all records, correspondence, notes, communications, and other
documents concerning or relating to the circumstances under which Defendant
acquired employment fromthe Co-Defendant(s) JoyceM. Guy and Edward
McCray, including, but not limited to,
Defendant job description, duties, his qualifications to performthose
duties, and freezing any and all evaluations prepared by anyoneabout how he
performed those duties for the behalf of the Co-Defendant(s) collectively herein.
(70)
Freezing all records showing theDefendant qualifications to performthose
duties as an “Attorney at Law” in and for the State of Texas.
(71)
Freezing all records, correspondence, notes, communications, and other
documents concerning or relating to any private hire authority working for
Defendant behalf “investigating the circumstances” under which Defendant were
46. retain after acquired employment fromthe Co-Defendant(s) JoyceM. Guy and
Edward McCray.
(72)
Freezing all records, and all Documents of Defendant “Attorney and Law”,
contracts concerning or relating to Monetary retain “Attorney at Law” Payments
of services Defendantreceived fromCo-Defendant(s) JoyceM. Guy and Edward
McCray.
(73)
Freezing all of Defendant“Attorney and Law” Contracts with clients namely
Co-Defendant(s) JoyceM. Guy and Edward McCray in cause No. A-180805.
(74)
Freezing all documents of Defendant“Attorney and Law” related to files,
documents, letters, motions, certificate of mailing services, correspondence,
notes, communications, phone records, being received in causeNo. A-180805
fromPro Se Plaintiff Louis Charles Hamilton II to the Defendant for the behalf of
the Co-Defendant(s) JoyceM. Guy and Edward McCray.
(75)
Freezing all of Defendant“Attorney and Law” Contracts for hire of services
with clients namely Co-Defendant(s) JoyceM. Guy and Edward McCray in U.S.
Cause No. 1:2010-CV-00055
(76)
Freezing all Documents of Defendant“Attorney and Law” entire cause No.
for each and every case load for every client Defendantoffice has legally
representin a civil court of law in and for the State of Texas fromthe exact dates
of December 18th
2007 throughoutDecember 18th
2014
(77)
47. Freezing all Documents Defendant “Attorney and Law” herein related to
files, documents, letters, correspondence, notes, communications, phonerecords,
Defendant contacted another Attorney at Law office to take over in causeNo. A-
180805 or
Defendant staff made such requested and or made such inquiry for the
behalf of the Co-Defendant(s) JoyceM. Guy and Edward McCray.
(78)
Freezing all Documents Defendant “Attorney and Law” herein related to
files, documents, letters, correspondence, notes, communications, phonerecords,
Defendant contacted the 58th
Judicial District Court HonorableJudge Bob
Wortham,
And or his staff requesting to be removed as acting
“Attorney of Record” fromthe causeNo. A-180805on or before the dates
of November 13th
2009 or having another Attorney at Law office to take over in
causeNo. A-180805 as showing Defendant(Attorney atLaw)
Herein made such requested and or made such inquiry for the behalf of the
Co-Defendant(s) JoyceM. Guy and Edward McCray on or beforethe dates of
November 13th
2009.
(79)
Freezing all Documents Defendant “Attorney and Law” herein related to
files, documents, letters, correspondence, notes, communications, phonerecords,
employment for hire Attorney at Law contracts Defendantacquired employment
fromthe Co-Defendant(s) JoyceM. Guy and Edward McCray other then in cause
No. A-180805and U.S. CauseNo. 1:2010-CV-00055
(80)
Freezing all Documents Defendant “Attorney and Law” herein relating to
the exact Identity of each, and all staff member of the Defendant Law Officefrom
48. the dates of November 17th
2007 throughout 2015with each staff member day
time telephone number and correct mailing address.
(81)
Freezing all Documents Defendant “Attorney and Law” herein relating to
the exact monetary paymentand contract thereof the Defendant received from
Co-Defendant(s) in cause No. A-180805 to file a “General Denial” to Pro Se
Plaintiff Complaint.
(82)
Freezing all Documents Defendant “Attorney and Law” herein relating to
the exact monetary paymentand “Attorney/Client contract thereof the
Defendant received fromCo-Defendant(s) in causeNo. A-180805
To appear at a hearing on the dates of August28th
2009 to respond to Pro
Se Plaintiff Complaint and all circumstancefor the legal behalf of the Co-
Defendant(s) JoyceM. Guy and Edward McCray herein on hearing dates of August
28th
2009.
(83)
Freezing all Documents Defendant “Attorney and Law” herein relating to
the exact monetary paymentand Attorney/client contractthereof the Defendant
received fromCo-Defendant(s) in cause No. A-180805to appear at a hearing on
the dates of September 11th
2009
To respond to Pro Se Plaintiff Complaint and all circumstancefor the legal
behalf of the Co-Defendant(s) JoyceM. Guy and Edward McCray herein on
hearing dates of September 11th
2009.
(84)
Freezing all Documents Defendant“Attorney and Law” herein relating to
any of Pro Se Plaintiff “Discovery Request for Interrogatories, Request for
Admission, and Request for Disclosure in accordancewith the Texas Rules of
Civil Procedures 194.2, 197, and 198, in Defendant possession, custodyand legal
49. control from the dates of April 2nd 2008 and April 11, 2008, throughout the dates
of October14th 2009 which Defendant supply some sort of respond during this
time frame of (1) year and (5) months and counting days Defendant not
responding.
(85)
Freezing all Documents Defendant “Attorney and Law” herein relating to
the exact monetary paymentand Attorney/client contractthereof the Defendant
represented the Co-Defendant(s) JoyceM. Guy and Edward McCray herein
McCray herein legal behalf in any criminal/civil cases other then causeNo. A-
180805 and U.S. CauseNo. 1:2010-CV-00055
(86)
Freezing all Documents Defendant“Attorney and Law” herein relating to
the exact ledger of cause No. A-180805 resulting frombusiness transactionsand
principal book keeping and computer filing systemfor all documents, records,
contracts, and banking records.
(87)
Freezing all Documents Defendant “Attorney and Law” herein relating to
the exact “certificate of mailing services” Defendantreceived (Legal Court
Documents) in causeNo. A-180805 fromPro SePlaintiff herein for the behalf of
the Co-Defendant(s) JoyceM. Guy and Edward McCray herein.
(88)
Freezing all Documents Defendant “Attorney and Law” herein relating to
the business transactions, dealings, and or relationship between the Defendant
“Attorney at Law” with the Co-Defendant(s) JoyceM. Guy and Edward McCray
herein other than a Attorney/client relationship between the dates of 1980
throughout2015.
(89)
50. Freezing all Documents Defendant“Attorney and Law” herein relating to
the business transactions, dealings, (IRS) records showing theAnnually Income
received for the Defendant Law Officeherein fromthe dates of November 17th
2007 throughoutDecember 2015.
(90)
Freezing all Documents Defendant “Attorney and Law” herein relating to
the Defendanthaving another “Attorney/Client Relationship other then in cause
No. A-180805showing Defendantdid not actually respond to discovery request
for Interrogatories, Requestfor Admission,
And Request for Disclosure in accordancewith the Texas Rules of Civil
Procedures 194.2, 197, and 198, in Defendant possession, custodyand legal
control for other Clients retain for Defendant “Legal Services” other than the
Co-Defendant(s) JoyceM. Guy and Edward McCray herein.
(91)
Freezing all records showing theDefendant staff qualifications to perform
those duties acting on behalf of Defendant“Attorney at Law” herein Law Offices
in and for the State of Texas fromthe dates of November 17th
2007 - 2015.
(92)
Freezing all of Defendant“Attorney and Law” entire cause No. Ledger
showing for each and every case load for the Defendant“Law office” he has
legally representin a civil courtin a suit in common law in and for the State of
Texas fromthe exact dates of December 18th
2007 throughoutDecember 18th
2014 showing each causeNo.
“The exact Courthousein Texas whereby Defendantrepresented, ledger
showing of each documents and motions received and filed responsethereof per
each cause No., with Production of Documents on all return Defendantcertificate
of mailing services to “opposition counsel or Pro Se (Person or Persons)”.
(93)
51. Freezing all Documents, Birth records, Church records, Hospital(DNA)
records all of Defendant “Attorney and Law” herein having descended froma
common ancestor or constituting a people, clan, tribe, or family, relative or
kinsman with the Co-Defendant(s) JoyceM. Guy and Edward McCray herein.
Freezing “Assets” enforcedagainst Defendant AntoineL. FreemanJ.
D. (Attorney at Law) Texas Bar No. 240582999 herein as Follows:
(94)
Freezing all of Defendant“Attorney and Law” herein entire assets in Law
office located at 3629 ProfessionalDr. PortArthur Texas 77642
(95)
Freezing all of Defendant“Attorney and Law” herein entire assets in Law
office located at 3723 Gulfway Dr. PortArthur Texas 77642
(96)
Freezing all of Defendant“Attorney and Law” herein entire assets in “Deed”
ProfessionalDevelopmentBlock 2 Lot 3 “SBD Keith Marroquin” as being
described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search
Index#2011035793
(97)
Freezing all of Defendant“Attorney and Law” herein entire assets in “Gulf
Employee Credit Union as being described in Pro Se Plaintiff attached exhibit (M)
“Jefferson County Texas” search Index #2002005559
(98)
Freezing all of Defendant“Attorney and Law” herein entire assets in “Port
Arthur Teachers Federal Credit Union as being described in Pro Se Plaintiff
attached exhibit (M) “Jefferson County Texas” search Index#2004004187
52. Freezing all of Defendant“Attorney and Law” herein entire assets as being
described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search
Indexherein all such person and person(s)
As identified having (any) interests in all entities owned, in wholeor in
part, or controlled by, related to, or associated or affiliated with Defendant
Antoine L. Freeman J. D. (Attorney at Law) herein “Namely” “Freeman Antoine,
Freeman Antoine L, Freeman Antoine L Sr., Freeman Antoinette C & EX, Black
James M and Moor Leslie M Jr.
(99)
Freezing all Assets” of Defendant (Attorney at Law) herein there after
providing a “verified written described accounting” and “personalfinancial
statement” of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein as·set
plural noun: assets:
“Deeds”, Banking accounts presently held, Property, Stock, Bonds, (IRA),
Commercial Real estate, Companies, Investments, estates, livestock, cattle,
horses, Rental Property(s), landholding, chattel,
Valuable Art collection, investment banking, (money) to use, by purchase
or expenditure, in something offering potential profitable returns, as interest,
income, gold investment.
(100)
Freezing enforcedagainst Co-Defendant “Joyce M. Guy and
Edward McCray”herein as Follows:
Freezing all records in G and G Service Company P.O. Box 515, 416
DeQueenBlvd. inPort Arthur“ Business records”, banking records, personal
banking records, staff records, (IRS), computer records, insurancerecords,
ledgers, tax records, fromthe dates of 1997-2015
(101)
Freezing all records in J Can Company 1807 East 7thStreet Port Arthur
Texas (Office) locatedat 448 DeQueenBlvd. inPort Arthur Texas 77640 “
53. Business records”, banking records, personalbanking records, staff records, (IRS),
tax records, computer records, insurancerecordsfromthedates of 2008-2015
(102)
Freezing all records in E and J Collectibles locatedat 448 DeQueenBlvd. in
Port Arthur Texas 77640
*note this company not listed onPro Se Plaintiff attachedexhibit (C)
hereinrecords containat “JeffersonCounty Texas SearchIndex”
However it “do exist”onthe Internet as being twocompanies and is in
“physical operation”as Public Advertisement claims opentothe public in
JeffersonCounty Texas contact Co-Defendant “Joyce M. Guy” (409) 330-0485.
Business records”, banking records, personalbanking records, staff records,
(IRS), taxrecords, computer records, insurancerecords, fromthedates of 1997-
2015
(103)
Freezing all records in “Paragon Business Inc.” Lot10 Block 18 (Jefferson)
Chaison ADD
Business records”, banking records, personalbanking records, staff
records, (IRS), taxrecords, computer records, insurancerecords fromthe
dates of 2001-2015
(104)
Freezing all records in “Cars and Pieces” office located in Beaumont Texas
and all records atoffice located at 448 DeQueenBlvd. inPort Arthur Texas
77640
Business records”, banking records, personalbanking records, staff
records, (IRS), taxrecords, computer records, insurancerecords fromthe
dates of 2001-2015
(105)
54. Freezing all records in DSW Homes.
(106)
Freezing all records in SWMJ Construction Inc.
(107)
Freezing all records in “Texas Department of Housing and Community
Affairs”
(108)
Freezing all records in North America Popular Banco Texas
(109)
Freezing all records during “Hurricane “Rita”, “Ike”and “Humberto”
relatedConstructionstormdamages tothe property locatedat 448 DeQueen
Blvdin Port Arthur Texas
Business records”, banking records, personalbanking records, Homeowner
InsuranceRecords, FEMA records, Contractor Construction records, and recovery
repair records.
(110)
Freezing all records during “Hurricane “Rita”, “Ike”and “Humberto”
relatedConstructionstormdamages tothe property locatedat 5050 east 7th
street inPort Arthur Texas
Business records”, banking records, personalbanking records, HomeOwner
InsuranceRecords, FEMA records, Contractor Construction records, recovery
repair records.
(111)
55. Freezing all records during “Hurricane “Rita”, “Ike”and “Humberto”
relatedConstructionstormdamages tothe property locatedat SBD “Lakeview”,
Block 4 Lot 10 JeffersonCounty Texas
Business records”, banking records, personalbanking records, HomeOwner
InsuranceRecords, FEMA records Contractor Construction records, recovery
repair records.
(112)
Freezing “Assets” enforcedagainst Defendant Co-Defendant(s)
Joyce M. Guy and Edward McCray herein as Follows:
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in G and G Service Company P.O. Box 515, 416
DeQueenBlvd. inPort Arthur“77640
(113)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in J Can Company 1807 East 7thStreet Port
Arthur Texas (Office) locatedat 448 DeQueenBlvd. inPort Arthur Texas 77640 “
(114
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in E and J Collectibleslocatedat 448 DeQueen
Blvd. in Port Arthur Texas 77640
(115)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in “Paragon Business Inc.” Lot10 Block 18
(Jefferson) Chaison ADD
(116)
56. Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in “Cars and Pieces”
Officelocated in Beaumont Texas and office located at 448 DeQueenBlvd.
in Port Arthur Texas 77640
(117)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in the property locatedat 5050 east 7th
street
in Port Arthur Texas
(118)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in the property locatedat SBD “Lakeview”,
Block 4 Lot 10 JeffersonCounty Texas
(119)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in the property locatedat 1807 east 7th
street
Port Arthur JeffersonCounty Texas
(120)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in the property locatedSBD Port Arthur City
Block 210, Lot 8 JeffersonCounty Texas
(121)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in the property locatedat SBD Port Arthur City
Block 94, Lot 11 JeffersonCounty Texas
57. (122)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in the property locatedat 416 DeQueenBlvd.
Port Arthur JeffersonCounty Texas
(123)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in the property locatedat 448 DeQueenBlvd.
Block 172 Lot 1-2 in Port Arthur JeffersonCounty Texas
(124)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets in the property locatedat Rev Ransom Howard
Street inPort Arthur JeffersonCounty Texas Property ID #89824 (Commercial
Vacant Lot)
(125)
Freezing all of Co- Defendant Joyce M. Guy and Edward McCray
“collectively” herein entire assets as being described in Pro Se Plaintiff attached
exhibit (C) “Jefferson County Texas” search Index herein all such person and
person(s) to include but not limited to
As identified having (any) interests in all entities owned, in wholeor in
part, or controlled by, related to, or associated or affiliated with Co- Defendant
Joyce M. Guy and Edward McCray “collectively” herein
“Namely” “Willie Jones, Dorothy Cooley, Norma Guy, U Guy Sr., Joyce
Johnson Guy, Sarah D. West, Gladys Carpenter, Janet L. Hart, Edward E. McCray,
Edward McCray, Edward EugeneMcCray Sr., HorseGrant, Allen Guy, Joyce
Johnson Guy.
(126)