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No. A-180805
Louis Charles Hamilton II IN THE DISTRICT COURT
Plaintiff 58TH JUDICIAL DISTRICT
V.
Joyce Guy & Edward McCray ET AL OF JEFFERSON COUNTY, TEXAS
Defendants
Notice of Motion for Contempt of Court
Motion for Contempt of Court and Order to show cause
To: Defendant(s) “Joyce Guy and Edward McCray”
Take Notice: That a Civil Hearing before the Honorable 58th District Court of
Jefferson County Texas is set at 9:00 am February 19th 2015 By the Pro Se Plaintiff
Louis Charles Hamilton II herein
For the “Honorable Court” to view and reach a Judgment, on the following
legal matters:
Notice of Motion and Motion for Contempt of Court and Order to Show Cause;
To: include Pro Se Plaintiff additional civil 58th Judicial Court business
1. PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT
2. Plaintiff Amend “Actual Damages” against the Defendant(s)
3. Writ of Execution
4. Plaintiff Motion for “Writ of Garnishment”
5. PLAINTIFF MOTION FOR SANCTIONS
6. PLAINTIFF MOTION FOR PROPERTY LIEN
Motion for Contempt of Court and Order to show cause
Comes Now Before The Honorable 58th District Court the Pro Se Plaintiff,
Louis Charles Hamilton II, herein files A “Motion FOR CONTEMPT OF COURT”
before the Honorable 58th Judicial District Court, described Defendant(s) “Joyce
Guy and Edward McCray” herein collectively order to show cause why (they)
refusal collectively
After was so Order By This Honorable 58th District Court of Jefferson County
Texas on the 10th day of May 2010 to produce copies of deeds, property deeds or
any other such physical document in Defendants’ possession, custody or control
that shows actual ownership of the property of the dwelling located at 448
DeQueen Blvd., in Port Arthur Texas and fully failing to adhere to an Honorable
Court Order.
Defendant(s) Further Order to be produced by The Court Defendant(s)
“Joyce Guy and Edward McCray” Was so Order By This Honorable 58th District
Court of Jefferson County Texas on the 10th day of May 2010 to produce
Copies of any and all construction estimates for repairs in Defendants’
possession, custody or control in relationship to damage caused by Hurricanes
Rita, Humberto and Ike to the property located at 448 DeQueen Blvd. in Port
Arthur, Texas.
Pro Se Plaintiff, States, Affirm, and Declare before the “Honorable Court”
Defendant(s) “Joyce M. Guy and Edward McCray” as of this undersigned date in
2015 collectively in 100% refusal to comply with all requirements in attached
Honorable 58th Judicial District Court order being Pro Se Plaintiff exhibit (A)
attached herein.
Prayer
Wherefore the Pro Se Plaintiff moves Defendant(s) “Joyce M. Guy and
Edward McCray” be held to show cause why they are collectively in refusal of said
court order in its entirely.
Wherefore the Pro Se Plaintiff moves Defendant(s) “Joyce M. Guy and
Edward McCray” be held in contempt of Court
Wherefore the Pro Se Plaintiff moves, prays the Court, after notice and
hearing, enters judgment Defendant(s) in “Contempt of Court”
Wherefore the Pro Se Plaintiff moves Defendant(s) “Joyce M. Guy and
Edward McCray” having sanction place against then as described in Pro Se
Plaintiff attached “Motion for Sanction” for refusal of said Honorable Court Order
since 10th day of May 2010
Wherefore the Pro Se Plaintiff moves the cost of Court, Pro Se Plaintiff fees,
and such other further relief as Pro Se Plaintiff “Louis Charles Hamilton II may be
entitled to in law or in equity.
Dated this ______ day of _______________, 2015
By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496