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Motion for contempt of court and order to show cause

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Page 1: Motion for contempt of court and order to show cause

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

Page 2: Motion for contempt of court and order to show cause

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.

Page 3: Motion for contempt of court and order to show cause

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