(RICO) Federal complaint Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) (Active) in and for the State of Texas Bar No. 24058299

In The United States District Court

For The Eastern Division of Texas

Beaumont Division

Louis Charles Hamilton II

Pro Se Plaintiff

Vs.

Antoine L. Freeman J. D.

(Attorney at Law) Texas Bar No. 24058299

Defendant

Joyce M. Guy

Edward McCray

Co-Defendant(s)

Civil Complaint

Jury Demand

Comes Now The Pro Se Plaintiff “Louis Charles Hamilton II” Pro Se Plaintiff

files “Complaint” with the above Honorable U.S. District Court and for Just

Cause, Plaintiff herein will show before the “Honorable Court” all facts,

circumstances, detailing among other things (RICO) “Racketeer Influenced and

Corrupt Organizations Act,

Causes of “acts and actions” committed against the Pro Se Plaintiff herein

“Will”, “Civil Rights”, “Peace” and “Dignity”.

“United States of America” Not a Party to this Suit.

1.

Parties.

Pro Se, Louis Charles Hamilton II, African American Male, U.S. Navy

Veteran,

Pro Se Plaintiff , Louis Charles Hamilton II, African American Male,

Permanently Disable Veteran protected under:

(ADA) American with Disability Act;

And also minorities persons cover under Title VII of the Civil Rights Act of 1964;

Domiciliary State of Texas, P.O. Box 17524 Sugar Land, Texas 77496

2.

Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) (Active) in and

for the State of Texas Bar No. 24058299

Has “Two Legal Law Offices” in Port Arthur Texas, 3627 Professional Dr.

Port Arthur Texas 77642 and 3723 Gulfway Dr. Port Arthur Texas 77642

3.

Co-Defendant(s) Joyce M. Guy and Edward McCray (Legally Married) has

(5) business E and J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur

Texas Information about E & J Collectibles E & J Collectibles is in the Used

Merchandise Stores business and this category has 2 companies in Port Arthur

Texas.

J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at

448 DeQueen Blvd. in Port Arthur Texas 77640,

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 and

“Cars and Pieces” Located in Beaumont Texas (Office) also located at 448

DeQueen Blvd. in Port Arthur Texas 77640

4.

Jurisdiction

Jurisdiction is proper before the “Honorable Court” of Eastern District of

Texas in that (Plaintiff) is always a resident of Jefferson County Texas, and all

acts and actions described herein by all the Defendant(s) described herein fully

occurred within the Jurisdiction of Eastern District of Texas

Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.

24058299 is a (Active) “Attorney at Law” for the State of Texas as described

above in paragraph (2)

Further said Defendant Antoine L. Freeman J. D. Attorney at Law Texas

Bar No. 24058299 was acting in his full capacities as an “License Attorney” on

retainer for the legal behalf of (Co)-Defendant(s) “Joyce M. Guy” and “Edward

McCray” in a Civil Action in The District Court 58th Judicial District of Jefferson

County, Texas, Docket No. A-180805

When said Defendant herein in his fiduciary capacities as an “Attorney of

Law” Antoine L. Freeman J. D.) Texas Bar No. 24058299

Committed to “among many other things” (RICO) “Racketeer Influenced

and Corrupt Organizations Act”, Fraud on the Court

“Mail and Wire Fraud”, “Direct Fraud” and “Constructive Fraud” in

connection with Jefferson County Texas 58th District Court Records, and Fraud

of Jefferson County Public Records

5.

To include Defendant(s) and Co-Defendant(s) collectively in concert, and

collaboration in violations of Title 18 U.S.C. § 1341, 1343 and 1349 “Mail and

Wire Fraud”, Violations of Chapter 96 of Title 18, United State Code: (RICO)

Racketeering Influences Corruption Organization, Defendant Antoine L.

Freeman J. D. Attorney at Law Texas Bar No. 24058299

Aiding and abetting to commit to A Criminal Enterprise in “Racketeer

Influenced and Corrupt Organizations Act” in his capacity as a Attorney of Law,

against the rights, peace, and dignity, and civil rights of the Pr Se Plaintiff herein

in suit in common law in Jefferson County Texas 58th Judicial District Court.

"Computer Fraud and Abuse Act (CFAA) 18 U.S.C. § 1030 in connection

with all criminal acts and actions, as described fully herein.

Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No.

24058299 Fully Committed to among other things “Obstruction of Justice” in the

capacity as an “Officer of the Court” and “Attorney of Law” for the State of

Texas To commit and conspire to the same causes of all “acts and actions” in

concert with the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”

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

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

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

6.

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

Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) (Active) in and

for the State of Texas Bar No. 24058299 and in collusion with Co-Defendant(s)

“Joyce M. Guy” and “Edward McCray et al” Conspiracies together to pursue the

same Criminal (RICO) “Racketeer Influenced and Corrupt Organizations Act”,

Fraud on the Court “Mail and Wire Fraud”, “Direct Fraud” and

“Constructive Fraud” of Jefferson County Texas 58th District Court Records,

Fraud of Jefferson County Public Records All “among other things” being done

criminally/civilly against the Pro Se Plaintiff civil rights, peace, will, and dignity,

During an ongoing “Civil Suit” of Common Law in Jefferson County Texas

as described in paragraph 4 and 5 above.

All being wrongfully and fully committed to Within the Jurisdiction The

Eastern Division of Texas United States District Honorable Court.

7.

Subject Matter Jurisdiction

Venue

Pro Se Plaintiff Louis Charles Hamilton II herein States, Affirm, and

Declare Before the “Honorable Justice” Subject Matter Jurisdiction is proper

before this U.S. District Court “primary exclusive many “federal Questions”

involving among other things

Violations of Chapter 96 of Title 18, United State Code: (RICO)

Racketeering Influences Corruption Organization, Section 1341 (relating to mail

fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and

related activity in connection with identification documents), Section

1503(relating to obstruction of justice),

Falsification of “Material facts”, with Conspiracies by all described

Defendant(s) to pursue to the same Criminal Monetary Objective(s) involving

the Pro Se Plaintiff herein,

With mutable counts of constructive fraud activities “hiding behind”

among other things “attorney-client privilege” and all “work-product doctrine”

derive thereof, to include but not limited to all “communications” between an

“Attorney and his client”,

Namely Defendant Antoine L. Freeman J. D. (Attorney at Law) (Active) in

and for the State of Texas Bar No. 24058299 in collusion and conspiracies with

Co-Defendant(s) “Joyce M. Guy” and “Edward McCray et al”

To Commit to Fraudulent acts in all “prepared legal court documents”,

“affidavit(s)”, “interrogatories”, “request for admissions”, sign statements and

all other materials of Jefferson County Court records, document(s) and materials

facts in 58th Judicial District Court of Jefferson County Texas Court Docket No. A-

180805 “To include but not limited” to fraud upon the Honorable Judge Bob

Wortham, and His Court

Fraud in all records of the Jefferson County Clerk Office records involving

financial records of “Insurance Companies”, “Financial Statements” for primary

monetary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and

“Humberto ” scheme of things related Construction storm damages, derive

thereof further involving the Pro Se Plaintiff herein

8.

“To include but not limited to” the ” Actual Fraud”, upon the “Texas

Department of Housing & Community Affairs” of Jefferson County Texas and

“Federal Grants of $76,000 U.S. Dollars” derive thereof

In Violations of Chapter 96 of Title 18, United State Code: (RICO)




1503(relating to obstruction of justice), with “Actual Fraud(s)” Co-Defendant(s)

“Joyce M. Guy” and “Edward McCray” conspiracies of mutable “Insurance

Companies”, for primary fraud and scheme advantages during “Hurricane

“Rita”, “Ike” and “Humberto ” related Construction storm damages, Involving

further The Pro Se Plaintiff herein as a “unwilling blind” party into this cold

calculated fraudulent acts and action(s), and complex scheme of things to

further fraud the “Texas Department of Housing & Community Affairs” of

Jefferson County Texas and a “Federal Grants in excess of $76,000 U.S. Dollars”

derived thereof

9.

“Actual Fraud”, upon the 58th Judicial Court of Jefferson County Texas and

all records derive thereof,

To include but not limited to Actual Fraud of Insurance Companies”,

FEMA for primary monetary fraudulent acts and actions during “Hurricane

“Rita”, “Ike” and “Humberto” related Construction storm damages, involving

the Pro Se Plaintiff Louis Charles Hamilton II herein

All this “Complex Mutable Grand Scheme of Things” committed By the

Name Defendant Antoine L. Freeman J. D. a (Attorney at Law) (Active) in and for

the State of Texas Bar No. 24058299 in collusion and conspiracies with Co-

Defendant(s) “Joyce M. Guy” and “Edward McCray et al” corrupted activities

fully designed prepared with an eye towards the “realistic possibility of

impending litigation” by the Pro Se Plaintiff herein Defendant and Co-

Defendant(s) commit to Grand (RICO) Fraud of The 58th Judicial District Court of

Jefferson County thereof in this civil scheme of things.

And the realistic object by all described Defendant and Co- Defendant(s)

herein to further commit to Fraud for “monetary value gain in excess” of

$87,024.00 U.S. Dollars, against the Pro Se Plaintiff Civil rights, peace, will and

dignity

10.

With further combine conspiracy of fraudulent acts and actions by the

Defendant and Co-Defendant(s) to plan a scheme of things in the Theft of Pro Se

Plaintiff “Personal Property” herein against the Pro Se Plaintiff Louis Charles

Hamilton II “Civil Rights”, “Peace”, and “Dignity” being wrongfully done within

the Jurisdiction of the “Honorable Justice” further causing the Pro Se Plaintiff

herein to suffer “among other things”

Extreme real life hardship, Extreme Intentional Infliction of emotional

distress and mental anguish from all of the combine Defendant and Co-

Defendant(s) among other things conspire in (RICO) “Racketeer Influenced and

Corrupt Organizations Act”,

“Fraud on the Court”, “Mail and Wire Fraud”, “Obstruction of Justice”

“Direct Fraud” and “Constructive Fraud” of Jefferson County Texas 58 th Judicial

District Court Records, Fraud upon the Jefferson County Public Records combine

with all other extreme hostile corrupted wicked cruel civil/criminal acts and

actions being fully described in this complaint herein.

11.

Pro Se Plaintiff herein States, Affirm and Declare before the Honorable

Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No.

24058299 Violations of Chapter 96 of Title 18, United State Code: (RICO)




1503(relating to obstruction of justice), Fraud upon the 58th Judicial District

Court of Jefferson County Texas in connection with

Falsification of “Material facts”, and Numerous Fraudulent Activities in

the Capacity of a “Attorney at Law” cause Pro Se Plaintiff “Louis Charles

Hamilton II” herein to suffer “actual damages” in excess of $336,000.00 U.S.

Dollars and This “actual damages” is ongoing as of this undersigned date of this

Complaint before the Honorable Court since date of injury November 17 th 2007.

12.

Pro Se Plaintiff seeks Actual, accumulative, compensatory, consequential,

continuing, expectation damages, foreseeable, Future, incidental, indeterminate,

reparable, lawful, proximate, prospective, special, speculative, substantial,

Punitive, and Permanent damages; Pro Se Plaintiff seeks Actual Awards for

Intentional Infliction of emotional distress and mental anguish.

13.

Pro Se Plaintiff herein States, Affirm and Declare before the Honorable

Justice” this action was filed before this Honorable Court February 2, 2010 U.S.

Docket No. 1:2010-CV-00055 and at that time frame Pro Se Plaintiff was under

extreme mental stress caused by the many “acts and actions” of the primary

Defendant in the capacity of a “Skilled Attorney of Law” no less a Officer of The

State of Texas Court System and Co-Defendant(s) herein whom collectively

together are responsible for the Pro Se Plaintiff suffrage of among other things

“Mental Illness” and Living on SSI since date of injury… of 2007 as of this

undersigned date.

Pro Se Plaintiff further states, affirm and declare before the Honorable

Justice” also at the time of filing the original complaint against the Described

Defendant(s) herein

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

among others

(Thee) U.S. Attorney Office them self (Proof) already on Filed in this

herein U.S. Federal Court Clerk Office in the matter of Hamilton Vs. United

States of America, U.S. Attorney Eric Holder et al (1:2011-CV-00240)

Plaintiff was also forced into a “State Hospital” for a period of time,

accused of Violent Life Threaten Crimes” never being near of or a party thereof

and Pro Se Plaintiff “mental state” being quite scary indeed in light of all the

legal hostile activities ongoing against the Plaintiff will caused by each

Defendant(s) herein.

14.

Pro Se Plaintiff herein States, Affirm and Declare further before the

“Honorable Justice” this New Improved Complaint made against each

Defendant(s) herein is still criminal/civil corrupted conduct being still quite

“civilly ongoing” against the “legal rights” of the Pro Se Plaintiff “Louis Charles

Hamilton II

As Defendant(s) combine further “Fraudulent activities” continue to cause

the Pro Se Plaintiff to suffrage continually monetary damages in excess of

$48,000.00 U.S. Dollars per year since 2007, as of this undersigned date of this

complaint well into the future year of 2015.

Further causing Pro Se Plaintiff a “limbo state” of extreme hardship,

Intentional Infliction of emotional distress accompanying continue Gross state

of complete “mental anguish” direct at the Defendant(s) from all of the

numerous hostile corrupted acts and actions of the described Defendant(s)

herein as this “Civil Matter” is unresolved before the Jurisdiction of this

Honorable U.S. District Court which has real subject matter jurisdiction over all

detail material facts being complained of respectfully before “Honorable

Justice”

15.

Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable

Justice” that his current “Mental State” is processing a bit better, as these

causes of actions derived from Defendant Antoine L. Freeman J. D. Attorney at

Law Texas Bar No. 24058299 direct criminal/civil illegal, hostile, corrupted

conduct in collusion with Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”

need to be legally address

And Pro Se Plaintiff seeks a just proper legal, lawful respectable

accountable end to this civil matter in which the above Honorable U.S. District

Court has unfetter Judicial Subject matter over.

16.


Justice” the Defendant(s) continue imposed mental suffrage, hardship, and

Major Monetary losses caused by the described Defendant(s) collectively herein

as Pro Se Plaintiff “Mental State” has improved slightly as of this undersigned

date to uncover all of the real in life cruel intentions scheme, facts and

fraudulent circumstances of each described Defendant(s) acts and actions

herein direct against the rights, will, peace and dignity of The Pro Se Plaintiff

notably being on a Grand scale corrupted involvement

To the point the once (crafty hidden) “Racketeer Influenced and Corrupt

Organizations Act”, “Obstruction of Justice”

“Fraud on the Court”, “Mail and Wire Fraud”, “Direct Fraud” and

“Constructive Fraud” of Jefferson County Texas 58th District Court Records,

Committed fully by Defendant Antoine L. Freeman J. D. Attorney at Law Texas

Bar No. 24058299 And precise fraud upon the 58th Judicial Court of Jefferson

County Texas to now as of this undersigned date

Being official new discovery in Jefferson County Texas Public records,

quite correct and respectable evidence being complained of before the

Honorable Justice”

Now identified is this complaint in precise, sound proof calculations into

each responsible direct “acts and actions” of each Defendant(s) exacts

responsible & accountable “federal jurisdiction” conduct giving rise for a cause

of “Justice” Before this “Honorable Justice” United States of America Court .

17.

Factual Background

Co-Defendant(s) “Joyce Guy and Edward McCray” living at the dwelling

(Blk. 172 Lt. 1-2) being located at 448 DeQueen Blvd. in Port Arthur Texas

77640 knowingly collectively did enter into a Contract for the Amount of

$10,850.00 for Construction following Hurricane Humberto damages.

18.

Co-Defendant(s) “Joyce Guy and Edward McCray” already received funds

for repairs from the “Home Owner Insurance Company” in excess of $7000.00

U.S. Dollars and unknown to the (Plaintiff) Co-Defendant(s) simply squander all

of these funds on them self and their quite “selfish needs other than making the

repairs to the already seriously damaged home as required by the first

installment Insurance Funds proceeds.

At this point Co-Defendant(s) “Joyce Guy and Edward McCray” devised a

financial “wicked plan” to fraudulently involving the Pro Se Plaintiff “Louis

Charles Hamilton II” herein and his Construction contract $10,800.00 U.S.

Dollars for Hurricane Damages in a continue “scheme of things” to obtain

additional Funds from the same “Insurance Company”.

19.

Co-Defendant(s) “Joyce Guy and Edward McCray” Breach the Contract of

the Pro Se Plaintiff on November 17, 2007 for the same scheme of things as

being described in paragraph (18) above in addition Co-Defendant(s) collectively

took possession, custody and complete control over all of the Plaintiff property

Namely (Construction Tools) in excess of $3093.00 being Pro Se Plaintiff entire

“Construction Business of tools”...!

Wrongfully abducted and obtain in this “hostile takeover” to include Pro

Se Plaintiff herein being “physically assaulted” by Co-Defendant “Edward

McCray” while this same ongoing “criminal scheme of things” is in effect fully

committed and directed, and orchestrate by Co-Defendant(s) “Joyce Guy and

Edward McCray for the absolutely purpose to Fraud further of The “insurances

companies “Repair Moneys” for Co-Defendant(s) collectively “personal

monetary gain” other than making needed repairs

As all described in paragraph (18 & 19) above involving The Pro Se

Plaintiff Louis Charles Hamilton II and a Construction contract drafted by Pro Se

Plaintiff for Co-Defendant(s) “Joyce Guy and Edward McCray” collective behalf

for “monetary relief” by said “Insurance Companies” to cover dwelling located

at 448 DeQueen Blvd. in Port Arthur Texas home structural repairs cost for

Hurricane Humberto related storm damages.

20.

Co-Defendant(s) “Joyce Guy and Edward McCray” for their combine

corrupted conduct direct against the Plaintiff civil rights, peace, and dignity

within Jefferson County Texas as being described in paragraph (17, 18, and 19)

above

Pro Se Plaintiff filed civil action in Jefferson County Texas 58 th Judicial

District Court, before the “Honorable Judge” Bob Wortham.

Complaint Docket No. A-180805 filed on November 26th 2007 with the

Jefferson County Clerk of Court office. And Co- Defendant(s) “Joyce Guy and

Edward McCray” retain the Professional legal services of Defendant Antoine L.

Freeman J. D. “Attorney at Law” Texas Bar No. 24058299

Having “Two Legal Law Offices” in Port Arthur Texas, 3627 Professional

Dr. Port Arthur Texas 77642 and 3723 Gulfway Dr. Port Arthur Texas 77642

21.


Justice” because of the continue chief corrupted effects of Defendant Antoine L.

Freeman J. D. Attorney at Law Texas Bar No. 24058299 Skilled Crafty Criminal

Mutable Complex

Violations of Chapter 96 of Title 18, United State Code: (RICO)




1503(relating to obstruction of justice),

Falsification of “Material facts”, among other things committed by this

Defendant with Fraud upon the 58th Judicial District Jefferson County Court and

such Conspiracies involving the Pro Se Plaintiff herein,

The Civil action filed on November, 26th 2007 in 58th Judicial Court of

Jefferson County Texas remain complexly ongoing well into December 17 th 2014

next court hearing, fully

“Live” as of this undersigned date for a period well exceeding over (7)

years and counting ongoing in the 58th Judicial District Court of Jefferson County

Texas for a suit in “Common Law”.

22.


24058299 filed an original answer on behalf of the Co-Defendant(s) and then

later making false discovery procedure claiming to the Honorable Judge Bob

Wortham on or about 11th day of September 2009 in a reply motion for sanction

against said “Attorney” for violations of Texas Rules of Civil Procedure 193.1 by

failing to respond to Pro Se Plaintiff’s Discovery Request

” Defendant Antoine L. Freeman J. D. Attorney at Law Texas further

making factual material claims in court filed documents and before the

Honorable Court in a hearing his only “Legal obligation” was to provide Co-

Defendant(s) “Joyce Guy and Edward McCray” involving in this civil case A-

180805 in Jefferson County Texas was to draft a (Simple) General denial on behalf

of the described “Co-Defendants” behalf being filed on December 18th 2007 in

Jefferson County Clerk of Court records in order Co-Defendant(s) collectively do

not be filed for a default Judgment against them for the Civil Complaint.

23.



24058299 told a bald face “Lie” to “Judge Bob Wortham” to avoid “monetary

sanctions” against him for his (Indeed) violate of Rule 193.1

Defendant in his capacities as a “Attorney of Law” no less “kept secretly”

in his possession, custody and Control for a period of over (3) years while being

actual the “Attorney of Record” in this civil matter safely Hidden from the

“Honorable 58th Judicial Court” proceeding

All of Pro Se Plaintiff first round of Chief Discovery request document(s)

Request for Disclosure and “Request for Admissions” pursuant to Rule 198 of

the Texas Rules of Civil Procedure to include Pro Se Plaintiff First set of

Interrogatories” pursuant to 197 of the Texas Rules of Civil Procedure at which

Defendant Antoine L. Freeman J. D. “Attorney at Law” Texas Bar No. 24058299

finally admitted to the Pro Se Plaintiff (alone)

The “actual physical existences” after 3 years and counting Defendant

“Attorney at Law” omitted of being in such possession, custody and control while

keeping such discovery request of the Pro Se Plaintiff secretly hidden from the

“Court Proceedings” Moreover” especially Hidden From “Judge Bob Wortham”

Judicial studying of the civil case at hand before his Honorable Court proceeding

At which Defendant Antoine L. Freeman J. D. “Attorney at Law” providing

proof of all discovery document and material facts derive thereof and their now

existences being dated proof on or about October 14, 2009 when these discovery

document(s) “Request for Admissions and “Interrogatories” among other legal

documents was finally being place in the U.S. mail and forwarded back to the

Pro Se Plaintiff herein who made the discovery request over 2 and ½ years ago.

24.



24058299 cleverly crafty abusing his “attorney/client privileges, all work

doctrine documents derive thereof;

And all known communications between “Attorney and Client”

Namely Defendant Antoine L. Freeman J. D. and Co-Defendant(s) “Joyce

Guy and Edward McCray” herein to “Grand style” deceive the “Honorable

Court” from having any “Legal Knowledge Via Pro Se Plaintiff herein “direct

discovery request” and “Investigation” fully focus on among other things Co-

Defendant(s) “Joyce Guy and Edward McCray”

Collectively in the past did in fact submit numerous Hurricane relief

damages claims being in the form of construction contractor’s estimates to their

“Insurance Companies” and possibly FEMA for relief of damages caused by

Hurricanes Rita, Humberto, and Ike for the property located at 448 DeQueen blvd.

in Port Arthur, Texas.

To include Property located at 5050 east 7th Street in Port Arthur Texas, and

Property Located at Blk 4 Lot. 10 Lake View in Jefferson County Texas all own and

in the possession, custody, and control of the Co-Defendant(s)

As Pro Se Plaintiff making claims before the 58th Judicial District Honorable

Court of Co-Defendant(s) “Joyce Guy and Edward McCray” past fraudulent

“practice and patterns” thereof after the corrupted hostile “acts and actions”

directed at the Pro Se Plaintiff herein as being described in paragraph (17-24)

above.

25.



24058299 having full prior knowledge that existence of a “property lien” was

enforced by SWMJ Construction Inc. filed on June 18th 2009 in Jefferson County

Clerk Office

Being against Co-Defendant(s) “Joyce Guy and Edward McCray” as it was

relating to “among other things” “Material Evidence” Pro Se Plaintiff sought

history showing Co-Defendant(s) making other Fraudulently scheme of things

involving monetary relief of damages caused by Hurricanes Rita, Humberto, and

Ike for the property located at 448 DeQueen blvd. in Port Arthur, Texas. There

after already ripping off the Pro Se Plaintiff in 2007 storm season.

26.



24058299 having a Profession eye on the civil damages this discovery would

affect Defendant(s) presumed innocent standing before the Honorable Judge

Bob Wortham conspire with “obstruction of Justice” to continue to commit to

conceal this “material evidence” from the Plaintiff when it was required to be

produce in Pro Se Plaintiff Discovery Request devise.

27.



24058299 also having “insider information and communications” with Co-

Defendant(s) “Joyce Guy and Edward McCray” conspire further with

“obstruction of Justice” to continue to commit to conceal this “material

evidence” that Co-Defendant(s) “Joyce Guy and Edward McCray” was in fact in

the legal process of having the old Home torn down while the ongoing civil

actions was still pending before the 58th District Court of Jefferson County Texas

to include Co-Defendant(s) “Joyce Guy and Edward McCray”

Collectively having a “New Home” secretly being built at the cost of

$76,000.00 U.S. Dollars on a “Federal Grant” kept 100% secret from the Pro Se

Plaintiff Discovery and The State Court while this Civil Suit in common Law had

commence in 2007 as was well ongoing out of control at this point under (RICO).

As Defendant himself Antoine L. Freeman J. D. Attorney at Law Texas Bar

No. 24058299 confirm and described in Pro Se Plaintiff First Set of

“Interrogatories” the “Texas Department of Housing & Community Affairs”

issuance of a “Housing Grant” in favor for the Co- Defendant(s) “Joyce Guy and

Edward McCray” all of which in fact fraudulently obtain being in fact a “Federal

Housing Grant” on the behalf of “Texas Department of Housing & Community

Affairs”

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the

“Honorable Justice” Co-Defendant(s) herein making further fraudulent claims

before said “Texas Department of Housing & Community Affairs” that Pro Se

Plaintiff was the primary cause of damages to the old home derive thereof for Co-

Defendant(s) “Joyce Guy and Edward McCray” needing a “New Home” based

upon poor, Unsatisfactory contractor “workmanships” and “craftsmanship” being

committed by Pro Se Plaintiff Louis Charles Hamilton II herein for the $10,800.00

U.S. Dollars Contract already sub-mitted to previous “Insurance Company” by Co-

Defendant(s) in regards to Hurricane Humberto storm related damages.

28.


“Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas

Bar No. 24058299 having a Profession legal eye on the “civil damages” this Pro

Se Plaintiff discovery request would affect Co- Defendant(s) “Joyce Guy and

Edward McCray

Presumed innocent standing before the Honorable Judge Bob Wortham

clear back in 2008 long before Co-Defendant(s) “Joyce Guy and Edward McCray

further fraudulently obtain a “New Home” secretly being built at the cost of

$76,000.00 on a Federal Grant Defendant Antoine L. Freeman J. D. Attorney at

Law conspire further with “obstruction of Justice” to conceal the destruction of

the old home And the new home being built

Defendant Antoine L. Freeman J. D. Attorney at Law further conspire and

work in concert to assure no delays ever being a factor in the construction of the

New Home” Located at 448 DeQueen Blvd. in Port Arthur Texas would be

primary cause if the “Honorable Judge” Bob Wortham, of 58th Judicial District

Court of Jefferson County Texas would in all facts and circumstances reach Pro

Se Plaintiff discovery document(s) containing “Material Facts” of among other

things while this ongoing civil suit still pending a “Property Lien” already

previously in Forced against Co-Defendant(s) collectively as described in

paragraph (25) above

To include a “New Home” secretly being built under the noise of the Pro Se

Plaintiff herein and the “Honorable Judge” Bob Wortham, during this pending

civil action Docket No. A-180805 at the cost of $76,000.00 on a “Federal Grant”

as the secretly destruction of the older home took place once being

“Official Dwelling” to this ongoing Civil Suit involving the dwelling in 2007

located at 448 DeQueen Blvd. in Port Arthur Texas, Now secretly destroyed in

2009 before the Honorable 58th Judicial District Court of Jefferson County, Texas

ongoing civil court case.

29.


“Honorable Justice” Co-Defendant “Joyce Guy and Edward McCray” secretly

filed on June 18th 2009 transfer of property over to the “Texas Department of

Housing & Community Affairs” at the Jefferson County Clerk Office File

#2009022762 during this ongoing civil action with the Defendant collusion to

keep all of this absolutely secretly claiming under

“Attorney/Client Privileges”, Product of Work Doctrine and

Communications made between Attorney and Client absent the fact this is very

material facts in a ongoing civil suit against the Co-Defendant(s) collectively

under the legal defense of Attorney at Law criminally withhold such discovery as

request to release such favorable Document, Material facts, and circumstances.

30.


“Honorable Justice” Co-Defendant “Joyce Guy and Edward McCray” secretly

filed on June 18th 2009 Fraudulent “Financing Statement” at the Jefferson

County Clerk Office File #2009022763 to obtain from “Texas Department of

Housing & Community Affairs” $76,000.00 on a “Federal Grant” as the secretly

destruction of the older home took place during this ongoing “Civil Suit”

31.



Bar No. 24058299 having full knowledge of all this transfer of the Home, and the

destruction of the older one and all circumstance involved thereof being

secretly conspire further fraudulently in the capacitates of a “Attorney at Law”

with the Co-Defendant(s)

To achieve the same fraudulently monetary objective(s) gain being

$76,000.00 “New Home” on a “Federal Grant” shamefully submitted Before the

“Texas Department of Housing & Community Affairs” by Co-Defendant(s) after

already “Greedy Squandering” all of the Numerous Insurance Funding” from

each previously Hurricane “Rita”, “Humberto”, and “IKE” related storm damages

on the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas.



Bar No. 24058299 had a duty to disclose all material facts as described herein

and regardless of his “Attorney/Client defense of the Co-Defendant(s)


24058299 was obligated to conform with the Texas Rules of Civil procedures in

Discovery phase of a Civil Suit in common law within the State of Texas

Regardless of it criminal/civil fall out affect being properly in placement

upon the Co-Defendant numerous fraudulent acts and actions discovery of a

shocking further investigation involving “among other things” the actual

designed “Fraud of Contractors” related to “Insurance Company” Scams and

scheme of things the Co-Defendant(s) monetary calculated and concocted.

32.



Bar No. 24058299 at no time did the Defendant file any notice with the court

from the time frame of December 18th of 2007 throughout December 11th 2009

request for “Motion For Withdrawal of Counsel” exactly 7 days shy of two years


24058299 was retain to commit to numerous fraudulent acts and actions

involving withholding all discovery material during this entire (2) year time

frame and shield all of Co-Defendant(s) mutable fraudulent indiscretions of

Corrupted Illegal (RICO) Business dealing within Jefferson County Texas being

instituted by the Co-Defendant(s) .

33.


“Honorable Justice” Pro Se Plaintiff herein because of the many “hostile” acts

and actions direct at the Pro Se Plaintiff civil rights, peace and dignity by the Co-

Defendant(s) herein

Pro Se Plaintiff conducted a Special Exclusive in-depth Investigation into

the Co- Defendant(s) “Joyce Guy and Edward McCray” to provide the Honorable

58th Judicial Court of Jefferson County Texas”,

Solid proof of the Co-Defendant(s) collective History of corrupted

“pattern and practices” involving “fraudulent monetary scheme of things

Nature” to” legally discovery” all of the following ongoing corrupted in design

acts and in one primary case being a actual “Illegal Medical Enterprise” for the

elderly disable senior citizens within in Jefferson County Texas

34.

Co- Defendant(s) “Joyce Guy and Edward McCray” mutable business E and

J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur Texas, J Can

Company 1807 East 7th Street Port Arthur Texas, G and G Service Company P.O.

Box 515, 416 DeQueen Blvd. in Port Arthur Texas and, “Cars and Pieces” Located

in Beaumont Texas (Office) also located at 448 DeQueen Blvd. in Port Arthur

Texas 77640

Are all in fact legally owned by the Co-Defendant(s) collectively herein as

records do in fact “indicate” and on file with the “Jefferson County clerk”

35.


“Honorable Justice” the Co-Defendant(s) “Joyce Guy and Edward McCray”, filed

with the Jefferson County Clerk #2009022763 “Financing statement” to obtain

the “Texas Department of Housing & Community Affairs” $76,000.00 on a “New

Home Federal Grant”

“However” Co-Defendant(s) “Joyce M. Guy” omitted and refused to provide

correctly all factual income detail in this “Financing Statement” of the Assumed

Name Business G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port

Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640

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

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

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

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

36.

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

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

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

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

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

37.


“Honorable Justice” Special Exclusive in-depth Investigation into the Co-

Defendant(s) “Joyce Guy and Edward McCray” further reveal J Can Company

1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen Blvd. in

Port Arthur Texas 77640 being owned by the Defendant(s) “Joyce Guy and

Edward McCray”, assumed name filed on April 11th 2008 Jefferson County Clerk

records #72594

1807 East 7th street in Port Arthur Texas is actually a “Vacant Lot” which

has been raided by the PAPD Dept. (Police) several times for engaging in “illegal

Scrap Industry”

“Moreover” once all “Illegal Scrap Metal” other then used Cans being

recycle and obtain in the City of Port Arthur Texas city limits by Defendant

“Edward McCray”, by the business J Can Company being now introduced as

“Scrap Metal” in connection with “Cars and Pieces” business Located in

Beaumont Texas (Office) also located at 448 DeQueen Blvd. in Port Arthur Texas

77640

Making the final “Legal sales” of all “illegal scrap” obtain in the City of

Port Arthur Texas city limits by Defendant “Edward McCray”,

“Moreover” Pro Se Plaintiff Louis Charles Hamilton II herein (Fully) quite

“elementary sure and certain” after prior raid by the (PAPD) Police into “illegal

scrap” of J Can Company that this “many years of “baffling exchange” transfer

rate of

“Illegal scrap” from Port Arthur Texas City Limits has been confusing the

(PAPD) Police in the exchange rate form now “legal scrap” derived in

“Beaumont Texas” from J Can Company “Namely”, “Cars and Pieces” business in

Beaumont Texas being now major illegal scrap metal “money laundering” “Earn

Income” system for Co-Defendant (Edward McCray) derived from this “criminal

endeavor.

To include but not limited to, upon information, belief and personally

witness Co-Defendant “Edward McCray” usage of “Vacant Lot” being J Can

Company to secretly continue engaging in the sales of a “Crack Cocaine

Industry”.

38.


“Honorable Justice” Defendants Antoine L. Freeman, J.D. “Attorney at Law” at

the very start clearly in December of 2007 was engaging in Professional Skills of a

Attorney at Law” in a “Legal” ongoing court room obligations to defend this civil

case A-180805 against Pro Se Plaintiff

Defendant made Fraud upon the 58th Judicial Court claiming in a document

filed by defendant his only legal job was to draft a (Simple) General denial on

behalf of the Defendants filed on December 18th 2007, as such to avoid a default

on behalf of Co-Defendant(s) by filing his original Answer and at that point his

“Fiduciary Duty” to his clients and before the Court ended on that date December

18th 2007 and was legally completely over,

Which this is not the case as Defendant (Attorney at Law) Fully scuttles all

discovery materials received from Plaintiff in this civil matter from December 18th

2007- November 13th 2009 being the official day while in possession of Plaintiff

request to disclose Pursuant to Rule 194 during the entire year of 2008-2009

Defendant Antoine L. Freeman, J.D. “Attorney at Law fail well within (30) days of

this request, for the information or material described in Rule 194.2: by a period

of over (2) years past the (30) days requirement to answer not only Pro Se

Plaintiff “Request to Disclose” Pursuant to Rule 194,

Defendant (Attorney at Law) was also served Pursuant to Rule 198 of the

Texas Rules of Civil Procedure Plaintiff Request for Admission(s) and Pursuant to

Rule 197 of the Texas Rules of Civil Procedure Pro Se Plaintiff Set of

Interrogatories all of which required a reply within (30) days of these request as

Defendant a skilled (Attorney at Law) having full knowledge that a discovery

phase process had commence in this civil legal matter refuse to submit any

“response or reply” to all being described in paragraph (38) herein for a period of

(1) year and (11) Months and Pro Se Plaintiff Filed “Motion for sanctions” against

said Defendant (Attorney at Law) in violation of Rule 193.1 of the Texas Rules of

Civil Procedure.

39.

Defendant (Attorney at Law) in his defense of Plaintiff motion for Sanctions

committed to the Following Fraudulent activities upon the 58th Judicial District

Court of Jefferson County Texas and all court records derive thereof.

a. Engage in having Co-Defendant “Joyce M. Guy” Subscribed and Sworn a

Affidavit in Support of Defendant (Attorney at Law) dated September

11, 2009

b. File a Response to Plaintiff’s Motion For Sanctions also committed to the

same act of having this document “Subscribed and Sworn on the 11th

day of September 2009

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

40.


“Honorable Justice” Affidavit of Co-Defendant “Joyce M. Guy” admit Defendant

(Attorney at Law) informed Co-Defendant between April 2nd, 2008 and April

11th, 2008 about Pro Se Plaintiff “Discovery Request” providing proof that

Defendant (Attorney at Law) was in fact in possession, custody, and control of

said discovery request while representing to the “Honorable Court” this was not

the case.

41.

Defendant (Attorney at Law) herein did not file any notice with the Pro Se

Plaintiff or the District Court of Jefferson County Texas that he was not

representing the legal interest of the Co-Defendant(s) “Joyce Guy and Edward

McCray”, there after filing “the original answer” with the District Court back in

December 18th of 2007 when Defendant (Attorney at Law) herein in fact stating

having Pro Se Plaintiff Discovery in Defendant own Affidavit being in his

possession as of April 2nd, 2008.

42.


“Honorable Justice” Defendant (Attorney at Law) herein stated to the

Honorable 58th Judicial District Court also, that his only duty was to file a

original general denial (only) and this was what his “Legal” services as a

Attorney in this matter was only retain for in his defense for Sanctions against

him as described herein this complaint.,”

“However” Pro Se Plaintiff States”, “Affirm” and “Declare” and further

maintain that Defendant Antoine L. Freeman J. D. “Attorney at Law” Texas Bar

No. 24058299 did in fact make a court appearance in a hearing the Pro Se “set”

before the Honorable 58th District Court

Pro Se Plaintiff also filed a (TRO) “Temporary Restraining Order” in this

same civil matter A-180805 against Co-Defendant “Joyce M. Guy” to protect her

own “Mother” Norma Guy, and the resident living in that dwelling whom Co-

Defendant (Guy) having “Power of Attorney” Over her Mother Legal Affairs,

filed in Jefferson County #2010042042 at which during this same time frame Co-

Defendant having process the same scheme and scam of things regarding

Insurance and FEMA fraud of the property of 5050 East 7th street in Port Arthur

Texas being Norma Guy Home Mother of the Co-Defendant (Guy).

43.

Defendant (Attorney at Law) made another court appearance and argued

this issue of a (TRO) alone before the Honorable Judge Bob Wortham, and at no

time was Defendant not acting in the capacity as “Attorney of Record” from the

time of filing his notice of counsel until Defendant (Attorney at Law) filed

Motion to withdraw as Attorney of Record.


“Honorable Justice” Defendant (Attorney at Law) herein sat on Pro Se Plaintiff

entire Discovery Request in excess of 16 Months and refuse to file a reply, file

any type notice with the court during this 16 Months time period while Texas

Rules of Civil Procedure require

Defendant a professional Attorney at Law Adhere to local rules of the

Court System and reply within (30) days not on a time table of (16) later after

service of Said Discovery request by Pro Se Plaintiff Louis Charles Hamilton II.

44.


“Honorable Justice” Defendant (Attorney at Law) herein, further state

Defendant then took a even bolder set in “Obstruction of Justice” in that after

(16) of scuttling Pro Se Plaintiff Discovery request to further Hide all of the

corruption going on at present time in the destruction of the old home and the

new one being built, during this ongoing Civil Suit and all of the inquiries being

made by the Pro Se Plaintiff regarding Fraud relating to Insurance Companies

Former Contractors, and Hurricane “Rita”, “Ike” and “Humberto”.

Defendant (Attorney at Law) herein provided further Fraud upon the

Court in Fraudulent Information in the Interrogatories, and Never Investigated

the circumstances of the questions being raised surrounding the “Theft” of The

Pro Se Plaintiff Construction Tools by the Co-Defendant(s) “Joyce M. Guy” and

“Edward McCray”,

Defendant (Attorney at Law) completely cover up the Co-Defendant(s)

collective wrong doings from the Honorable Court per Pro Se Plaintiff Discovery

Request being scuttled for (16) months time frame as being described in

paragraph (43) above.

45.

Defendant (Attorney at Law) made as if no Construction tools where ever

on the property of the Pro Se Plaintiff being complain of

To include Defendant (Attorney at Law) supply false answer(s) in the

same Interrogatories that the Co-Defendant “Edward McCray” never even

meeting the Pro Se Plaintiff Step Father (Lewis Garza) whom actually help

delivery all of Pro Se Plaintiff said in excess of $3000.00 U.S. Dollars in

construction tools to the dwelling in his Truck to the Home of The Co-

Defendant(s) “Joyce M. Guy” and “Edward McCray” on November 16th 2007.

Defendant (Attorney at Law) did not Investigate any of these facts nor was he

ever even concern to attempt to investigate into the issues of the were about of

Pro Se Plaintiff Construction tools.

45.


“Honorable Justice” after Defendant (Attorney at Law) was officially no longer

“Attorney of record” of the Civil action in Texas State Court from the time frame

of December 18th 2007 – filing General Denial to November 13th 2009 when

Defendant (Attorney at Law) filed with the Clerk of Court of Jefferson County

Texas a Motion for Withdrawal of Counsel

The Co-Defendant “Joyce M. Guy and Edward McCray” continue to refuse

to turn over said “Discovery Request” of the Pro Se Plaintiff

To the point a Court Order of the 58th Judicial District Court was obtain

and enforced as Follows:

46.

Ordered that Co-Defendants “Joyce Guy and Edward McCray” shall

produce copies of deeds, property deeds or any other such physical document in

Defendants possession, custody or control that shows actual ownership of the

property of the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas

47.

Ordered that Co-Defendants “Joyce Guy and Edward McCray” shall

produce copies of any and all construction estimates for repairs in Defendants’

possession, custody or control in relationship to the damages caused by

Hurricanes Rita, Humberto and Ike to the Property located at 448 DeQueen

Blvd. in Port Arthur, Texas.

As so Ordered on the 10th day of May 2010 by the 58th Judicial District

Court of Jefferson County Texas filed at 11:46 am.

48.


“Honorable Justice” that Co-Defendants “Joyce Guy and Edward McCray”

remain in Hostile abscond scuttle refusal of the Honorable Court Order as of the

undersigned date in the Month of November 2014 of this Complaint being

refilled in U.S. District Court.

49.


“Honorable Justice” because of Defendant Antoine L. Freeman J. D. Attorney at

Law Texas Bar No. 24058299 acting in his skilled profession to fraud the court

and belittle the Pro Se Plaintiff and his discovery request for a period in excess

of 16 months in possession thereof

To include Defendant (Attorney at Law) herein unethical commitment to

conspire further under the disguise of “Attorney/Client” privileges. Work

Product doctrine, and all Communications thereof being secrete between the

Defendant (Attorney at Law) and the Co-Defendant(s) “Joyce Guy and Edward

McCray”

To the point such Fraud commits by the Defendant (Attorney at Law) on

the Jefferson County 58th Judicial District Court completely forced the Pro Se

Plaintiff to be at an extreme “civil disadvantage” in the ongoing court

proceeding in the time frame of 2007-2009 and present in 2014 throughout

2015

Based solely upon Defendant (Attorney at Law) Rouge (RICO) “obstruction

of Justice” among other things being fully professional hire “Legal Gun”

knowledge thereof to scuttle, omit, delay and fraudulently mishandling required

duties to supply a honest, required respond to all of Pro Se Plaintiff discovery

request in a timely fashion, within the (16) months being in possession, custody

and control of said Pro Se Plaintiff Discovery request.

50.



Bar No. 24058299 retainer fees was solely paid to keep the Co-Defendant(s)

numerous discover fraud by the Pro Se Plaintiff absolutely 100% top secret from

the 58th Judicial Court”

while the other newer $76,000.00 U.S. Dollars “scheme of things” being in

current play and process to now a ongoing (RICO) fraud the Co-Defendant(s)

concocted involving Fraud (Now) The “Texas Department of Housing &

Community Affairs” issuance of a “Housing Grant” in favor for the Co-

Defendant(s) “Joyce Guy and Edward McCray”

All of which in fact being fraudulently obtain from “Federal Housing

Grant” on the behalf of “Texas Department of Housing & Community Affairs”

while the civil suit is “Live” and pending” which Co-Defendant(s) conspire to

keep this under wraps from any financial setback glitches being fully caused by

The Pro Se Plaintiff bring this additional Fraudulent activities before The

Honorable Court well deserved attention.

51.



Bar No. 24058299 in his History of being a Skilled “Attorney at Law” in and for

the State of Texas “Never” once scuttle, hide and thereof flat out being in

refusal in the filing of a “timely Discovery request” for a period exceeding over

(30) days against any Attorney, Law Firm or other Pro Se (Litigant)

In comparison to the double dealing, 100% skilled rouge super late filing

reply to Pro Se Plaintiff numerous Discovery request being late in excess of (19)

months and absolutely 100% in full violation of Texas Rules of Civil Procedures

193.1 All of which Pro Se Plaintiff herein “States”, “Affirm” and “Declare”

further before the “Honorable Justice” solely done by Defendant (Attorney at

Law) (Only) to conspire in the illegal (RICO) aid to hide all of the Co-Defendant(s)

“Joy M. Guy” and “Edward McCray” many corrupted Business Enterprises

endeavors,

Mutable Counts of Fraudulent activities involving Hurricane “Rita”, “Ike”

and Humberto” Monetary rip off scams against FEMA, Building Contractors

estimate and invoices and Home Owner Insurances Companies repair funds

Couple with the (Now) live ongoing new 2009 fraud activities of the Co-

Defendant(s) “Joy M. Guy” and “Edward McCray” involving “Federal Housing

Grant” on the behalf of “Texas Department of Housing & Community Affairs” in

excess of $76,000.00 U.S. Dollars

52.

Defendant (Attorney at Law) herein known lying with a consciousness

mind and disregard for the consequences for his actions in the “capacity as an

Attorney of Law”, Antoine L. Freeman J. D. conspire to continue to use his legal

lawyer skills” in the full “aid and abetting”, and commitment to “Obstruction of

Justice” in the capacity of a Attorney at Law forthwith in providing his own

numerous Attorney fraud legal commitment upon the 58th Judicial District of

Court of Jefferson County Texas, the Court records thereof as being fully

described in this U.S. District Court Complaint.

And being in full criminal (RICO) concert, collusion, corruption and

conspiracies thereof for all monetary fraudulent assets gains of the Co-

Defendant(s) “Joy M. Guy” and “Edward McCray”

Both being “ill-gotten pirate loot” from the “past” Hurricanes Seasons

“Rita”, Ike” and “Humberto” and “present” pirate loot” “Federal Housing Grant”

on the behalf of “Texas Department of Housing & Community Affairs” in excess

of $76,000.00 U.S. Dollars of the Co-Defendant(s) “Joy M. Guy” and “Edward

McCray”

53.

Fully affecting the Pro Se Plaintiff (Life) with “among other things” cause

of action for “actual damages” being in excess of $336,000.00 U.S. Dollars in

“lost wages” from 2007 – 2014 and “actual damages” in excess of “3093.00 U.S.

Dollars in all of the Pro Se Plaintiff Construction tools causing the Plaintiff undue

unwanted extreme hardship, infliction of emotional distress and anguish in the

“Theft of Pro Se Construction Profession” for a ongoing time frame over (7)

years and still counting well into 2015 The Texas State Civil Suit is “Live” and

ongoing due in large part to Defendant (Attorney at Law) herein

Numerous (RICO) “acts and activities” to commit “among other things” a

,complete assault of “Obstruction of Justice” and “Fraud upon a Court” in the

58th Judicial District Court of Jefferson County Texas

In a Suit in “Common Law” for the rouge disgrace benefit of his skilled

profession as a “Attorney of Law” to skillfully cover up a Co-Defendant(s) “Joy

M. Guy” and “Edward McCray” clients “Long Bogus Quite Profitable Crooked

Road of “Fraudulent History” being described fully herein and direct against The

civil rights, peace and dignity of the Pro Se Plaintiff herein.

54.



Bar No. 24058299 herein used his skills as a “Attorney of Law” to commit fully to

“Obstruction of Justice” for (16) months in refusal to reply to Pro Se Plaintiff

Discovery Request to “facilitate”, and “conceal” Co-Defendant(s) “Joyce M. Guy

and Edward McCray” by provide (Attorney in Law) Professional Legal efforts to

evade the 58th Judicial District Court of Jefferson County Texas proper

administration of Justice in the complaint A-180805 against all of the Fraud

activities already being described in said complaint against said Co-Defendant(s)

herein.

Furthermore Defendant (Attorney at Law) keeping the “Honorable Court”

and The Pro Se Plaintiff isolated in 2008 while the ongoing (RICO) racket scheme

of things currently ongoing fraudulent activities involving the secrete

destruction of the old home located at 448 DeQueen Blvd. in Port Arthur Texas

in exchange for a new one at the same location all of which being secretly done

while the “older home” still being a civil issue of Fraud as described by the Pro

Se Plaintiff before the “Honorable Court”.

55.



Bar No. 24058299 herein “facilitate” all of his own “Fraudulent Activities” upon

the Pro Se Plaintiff and fraud of the 58th Judicial District Court of Jefferson

County Texas for the full benefit of hiding the Co-Defendant(s) “Joyce M. Guy”

and “Edward McCray” numerous corruption activities with the usage of the

“United States Mailing System” to further long this fraudulent “scheme of

things” before a “Honorable Court of Law” within the State of Texas and further

long this “civil scheme” against the Pro Se Plaintiff as being described herein this

complaint.

56.



Bar No. 24058299 herein “facilitate” all of the Co-Defendant(s) “Joyce M. Guy”

and “Edward McCray” described corruption(s) and fraudulent activities with the

usage of the “United States Mailing System” to further long this fraudulent

“scheme of things” before a “Honorable Court of Law” within the State of Texas

and further long this “civil scheme” against the Pro Se Plaintiff as being

described herein this complaint.

57.



Bar No. 24058299 herein “facilitate” all of his own “Fraudulent Activities” and

that he further conspire to and did in all facts and circumstances “facilitate”

provide concealment, evade Justice for all of the Co-Defendant(s) “Joyce M.

Guy” and “Edward McCray” described corruption(s) and “fraudulent activities”

with the usage of the Jefferson County “Clerk of Court” Office Computer System,

electronic records, and filing system thereof to further long this fraudulent

“scheme of things”

Before an “Honorable Court of Law” within the State of Texas and further

long this “civil scheme” against the Pro Se Plaintiff as being described herein this

complaint.

58.



Bar No. 24058299 herein “facilitate” and engage further in the usage of Extrinsic

Fraud and tactics in the position as opposition counsel for the legal interest of

Co-Defendant(s) “Edward McCray and Joyce M. Guy” to stop, conceal and

hinder Pro Se Plaintiff from rightfully being involved in said discovery request,

so Pro Se Plaintiff not being able to obtaining favorable evidence to use as a

advantage to prosecute civilly against the Co-Defendant(s) “Joyce M. Guy” and

“Edward McCray” in the civil suit in State Court.

59.


“Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray”

committed to defamation of the Pro Se Plaintiff as being a dishonest, unskilled,

substandard Construction Contractor and Pro Se Plaintiff is the reasoning for the

older home located at 448 DeQueen Blvd. in Port Arthur Texas being

demolished for providing faulty contractor structural work and repairs being

unskillfully provided by Pro Se Plaintiff herein.

60.


“Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” used

the defamation of the Pro Se Plaintiff substandard construction performance

tactics with their previously Home Owner Insurance Company to satisfied any

suspicion concerning the $10,800.00 dollars already wrongfully squander by said

Co-Defendant(s) herein.

To include Co –Defendant(s) “Joyce M. Guy and Edward McCray” herein

used the same defamation of the Pro Se Plaintiff character against the “Texas

Department of Housing & Community Affairs” claiming further Pro Se Plaintiff

being a substandard contractor in construction performance by providing faulty

contractor structural work and repairs skills to the dwelling of 448 DeQueen and

Pro se Plaintiff being directly responsible for the need of destruction of the old

dwelling thereof in Port Arthur Texas

in order through this same wrongful scheme of defamation of the Pro Se

Plaintiff contractor skills to obtain further a New Home with this scheme of

things through the “Texas Department of Housing & Community Affairs” other

than the Co-Defendant(s) own numerous actual fraudulent activities in engaging

in squandering all of the funds paid out for actual repairs as a result of

Hurricane “Rita”, “Ike” and “Humberto” being done to said home.

61.



Bar No. 24058299 herein “facilitate” the same defamation of the Pro Se Plaintiff

as being a dishonest, unskilled, substandard Construction Contractor and Pro Se

Plaintiff is the reasoning for the older home located at 448 DeQueen Blvd. in

Port Arthur Texas being torn down and a new one being built. As described in

paragraph (59 and 60) above.

62.


“Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” on or

about the dates of April 2nd 2008 and or April 11th 2008 Co-Defendant(s)

admitted collectively of the involvement to “Entice”, “Induce”, “Allure”, and

“Ensnare” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No.

24058299 herein in his “Legal Capacities” as a “Attorney at Law”

To commit to “Actual Fraud” of the 58th Judicial Court” of Jefferson

County Texas For the (RICO) purpose of “delays”, “concealment”, “omitting”

and “hindering” all material facts, accounts, material circumstances both being

past and present of the Co-Defendant(s) “corrupted enterprise activates”

The Pro Se Plaintiff herein made numerous complaints thereof in Court

filing records “Docket No. A-180805 and Before the State of Texas Investigation

Services into the elderly

As well as all “discovery investigations” Pro Se Plaintiff was pursuing

presently during said State Court Civil Complaint involving Co –Defendant(s)

“Joyce M. Guy and Edward McCray” herein

In which further on or about April 2nd 2008 and or April 11th 2008 Co –

Defendant(s) “Joyce M. Guy and Edward McCray” herein Fully Conspire,

maneuver, pilot, manipulated, scheme and monetary paid and financially secure

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

herein in his “Legal Capacities” as a “Attorney at Law” throughout the dates of

November 13th 2009 of his “paid in full legal services” for a total of (19) months

to absolutely Violate Rule 193.1 Texas Civil Procedure in replying to the Pro Se

Plaintiff Discovery request

In order to fully engage in the covering up (RICO) collective scheme of

things of Co-Defendant(s) “Joyce M. Guy and Edward McCray” having

committed against The Pro Se Plaintiff,

58th Judicial District Court, Insurances Companies, State of Texas, and The

United States of America’, in a long criminal corrupted enterprise of “Fraud for

Monetary Gain” of said Co-Defendant(s) collectively “rip off” activities being

described herein now Before The above entitled “Honorable” United State

Federal Court having subject jurisdiction matter over the” Defendant and Co-

Defendant(s)”.

63.


“Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” on or

about the dates of April 2nd 2008 and or April 11th 2008 throughout the present

date of this U.S. Civil Complaint being made in the year of 2014 (November)

Said Co-Defendant(s) Collectively Promoted, Pilot, Scheme, Induce,

Engaged, and fully Conspire with Defendant Antoine L. Freeman J. D. Attorney

at Law Texas Bar No. 24058299 herein to obtain in his “Legal Capacities” as a

“Attorney at Law” in concert Violations of Chapter 96 of Title 18, United State

Code: (RICO) Racketeering Influences Corruption Organization, Section 1341

(relating to mail fraud), section 1343 (relating to wire fraud), section

1028(relating to fraud and related activity in connection with identification

documents), Section 1503(relating to obstruction of justice), Falsification of

“Material facts”,

Fraud upon the 58th Judicial District Jefferson County Court, Fraud on The

State of Texas, and The United States of America in such “Monetary

Conspiracies involving the Pro Se Plaintiff herein, and Hurricane “Rita”,

Humberto” and “Ike” related storm damages with the usage of such numerous

corrupted Fraudulent tooling maneuvers, and manipulated complex activities

involving among other things

All Jefferson County Clerk of Office records, 58th Judicial Court documents,

electronic court filing transmission, court transcripts, and The United States

Mailing System to promote, secure, and continue maintaining such (RICO)

activities against the Pro Se Plaintiff Louis Charles Hamilton II herein

With Co-Defendant(s) collectively Racketeering Influences Corruption

Organization activities being described both past and present now in a further

racketeering scheme of things involving a “Rouge Attorney” activities through

Co-Defendant(s) “Joyce M. Guy and Edward McCray” paid for hire “legal expert

services” of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No.

24058299 herein.

64.


“Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray”

promoted, conspire and secure (RICO) “Obstruction of Justice” activities of


herein against 58th Judicial District Court complaint made thereof

For a Period of (19) months between on or about April 2nd 2008 and or

April 11th 2008 throughout November 13th 2009 to continue well into 2015 such

(RICO) activities having continual legal affects as being described herein this U.S.

Civil Complaint against the Pro Se Plaintiff civil rights, peace, and dignity.

65.

Cause of Actions


“Honorable Justice” a Cause of Actions exist against Defendant Antoine L.

Freeman J. D. Attorney at Law Texas Bar No. 24058299 And Co-Defendant(s)

“Joyce M. Guy and Edward McCray”

Collectively for each Violations of Chapter 96 of Title 18, United State

Code: (RICO) Racketeering Influences Corruption Organization, Section 1341

(relating to mail fraud), section 1343 (relating to wire fraud), section

1028(relating to fraud and related activity in connection with identification

documents), Section 1503(relating to obstruction of justice),

(RICO) activities upon the 58th Judicial District Court of Jefferson County

Texas, and all court records, court documents electronic transmission, court

transcripts, to include but not limited to “(RICO)” activities committed against

“The Honorable Bob Wortham” himself being presiding Judge of Docket No. A-

180805 filed in Jefferson County Texas, (RICO) against Insurances Companies,

State of Texas, and the United States of America FEMA and Federal Housing

Grant agencies

To include but not limited to (RICO) activities disguised in a

Attorney/Client Privileges, work doctrine, and all communications derived

thereof

All (RICO) involvements being wrongfully committed against the civil

rights, peace, and dignity of the Pro Se Plaintiff Louis Charles Hamilton II herein

before a civil suit in common law within the State of Texas.

66.

Cause of Actions



Freeman J. D. Attorney at Law Texas Bar No. 24058299 And Co-Defendant(s)

“Joyce M. Guy and Edward McCray”

Collectively for “Actual Fraud” and the performance thereof in the

capacity of a “Attorney of Law” to include constructive fraud, fraudulent intent,

fraudulent pretense, fraudulent concealment, fraudulent misrepresentation,

fraudulent conveyance, Extrinsic Fraud, Fraud in fact and Fraud in law, fraud in

the execution of Plaintiff construction contract by Co-Defendant(s) “Joyce M.

Guy and Edward McCray” for purpose to fraud “Insurance Company”

To include collectively Fraud on the Court involving fraudulent activities

upon the 58th Judicial District Court of Jefferson County Texas, and all court

records, court documents, electronic transmission, court transcripts, and

document thereof

Fraud against Insurances Companies, State of Texas, and the United

States of America FEMA and Federal Housing Grant agencies involving Past

Hurricane storm related damages all of which being described in paragraph (66)

herein involving the Pro Se Plaintiff herein being past, present, and future

thereof to commit monetary Fraud gain in among other things Fraud of

Insurances Companies, State of Texas, and the United States of America FEMA

and Federal Housing Grant agencies involving the dwelling located at 448

DeQueen Blvd. In Port Arthur Texas

Committed against the civil rights, peace, and dignity of the Pro Se

Plaintiff Louis Charles Hamilton II herein before a civil suit in common law

within the State of Texas.

67.

Cause of Actions


“Honorable Justice” a Cause of Actions exist against Co-Defendant(s) “Joyce M.

Guy and Edward McCray” for Defamation of The Pro Se Plaintiff reputation and

his Profession in construction in connection with Co-Defendant(s) collectively

fraudulently activities to obtain a New Home

And Co-Defendant(s) collectively maintain such defamation acts to secure

a 76,000.00 U.S. Dollars Federal Housing grant in that the Pro Se Plaintiff “Louis

Charles Hamilton II” herein is the “direct cause” of the dwelling located at 448 in

DeQueen Blvd. in Port Arthur Texas being un-inhabitable for human living

conditions due primary for substandard faulty structural construction repairs of

said dwelling being committed by Pro Se Plaintiff herein

Whom never even made any such repairs on said home just (Pro Se

Plaintiff) construction contract being executed and used to continue fraud the

Insurance company for more monetary wrongful gain of “insurance Company

repair funds

other than Co-Defendant(s) actually fixing Hurricane Humberto storm

dames to dwelling located at 448 DeQueen Blvd. in Port Arthur Texas as

described in this complaint Co-Defendant(s) ) “Joyce M. Guy and Edward

McCray” Committed against the civil rights, peace, and dignity of the Pro Se

Plaintiff Louis Charles Hamilton II, herein.

68.

Cause of Actions



Freeman J. D. Attorney at Law Texas Bar No. 24058299 for “Actual Damages”

In this (RICO) and Fraudulent numerous conspiracy corrupted scheme of

things and corrupted activities in concert, and full collusion being also brought

and paid for to “expert cooking the “legal court books” of a Honorable 58th

Judicial Court of Jefferson County Texas in Favor of the corrupted (RICO)

described Co-Defendant(s) herein

To further along promote and fully cover up all (RICO) activities, Fraud of

Insurances companies, FEMA and Federal Housing Grants both being “past and

present” mutable fraudulent activities of the Co- Defendant(s) “Joyce M. Guy

and Edward McCray” herein involving the Pro Se Plaintiff Louis Charles Hamilton

II “Among others” being fully described herein to include but not limited to

69.


24058299 (RICO) and Fraudulent numerous conspiracy corrupted scheme of

things activities in concert, and full collusion in the capacity of a “Attorney of

Law” against the Pro Se Plaintiff personal property namely “Construction tools”

in excess of #3000.00 U.S. Dollars and lost wages at a minimums of $48,000.00

U.S. dollars per year “lost wages” since date of injury of November 2007

And Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No.

24058299 to “continue depriving” the Pro Plaintiff of his entire “Construction

Trade” and “Profession” in such a complex illegal rooted (RICO) conspirer and

fraud of the court system “scheme of things” being attached to the “Actual

theft” of all of the Pro Plaintiff Construction tools and profession trade thereof

for a period now exceed (7) years and counting well into 2015

As “Defendant and Co-Defendant” collectively enjoys and having

monetary gain collectively thereof from such wrongful ongoing (7) years “civil

victory” and corrupted (RICO) Fraudulent advantages, corrupted acts, and

actions over the Pro Se Plaintiff civil rights, peace and dignity, and fairness to

the Texas Civil Rules of Civil Procedures in a “civil suit” in “common law” as

being described herein this complaint

70.

Further being described once before the same U.S. District Court of

Eastern District of Texas when (Pro Se Plaintiff) filed his first original (RICO)

complaint being legally made thereof and now no question beyond any doubt

ever being so “crystal clear” in 2014 (November) the Pro Se Plaintiff confident in

being precise, and having a “well understanding” into this well twisted,

calculated, future plotted, manipulated, (RICO) mutable Fraudulent count

enterprising “scheming activities” derive thereof and its involvement with


herein for

“Actual Damages” exceeding (7) years conspire collectively with Co-

Defendant(s) herein to depriving the Pro Se Plaintiff of his “personal property”

namely “Construction tools” in excess of $3000.00 U.S. Dollars and “lost wages”

at a minimums of $48,000.00 U.S. Dollars

Pro Se Plaintiff being an “Independent Construction Contractor” suffrage

“lost wages” per (7) year since date of injury of November 2007 in the “Actual

Theft” of Said Construction tools. With 6% interest incurred since date of injury

being November 2007 into the future of 2015 as this Complaint being “examine

and entertain” before the “Honorable Justice” of such “Actual Damages”

71.


24058299 herein so did in all facts, court records, and real life circumstances

commit to, designed further to caused the Pro Se Plaintiff herein to suffer

extreme “monetary hardship” in such lost of “Actual Damage” in excess of

$336,000.00 U.S. Dollars in (7) years of “Lost wages” and counting into 2015

This (RICO) scheme of things in still enforced, ongoing and very live

against the Pro Se Plaintiff Louis Charles Hamilton II

As Defendant (Attorney at Law) herein (RICO) activities with the Co-

Defendant(s) same (RICO) activities commit his (Attorney at Law) profession to

commit to fraud of the Court “while” being in possession, custody, and control

as a “Officer of said 58th Judicial District Court of Jefferson County Texas

Further Defendant (Attorney at Law) herein (RICO) activities acts and

actions fully continue to depriving both past and present causing the Pro

Plaintiff to continue suffrage “Actual Damages” in excess of $3000.00 U.S.

Dollars in Lost of said “Construction tools” and the “Profession Trade” thereof

since November 2007 well into the future of 2015.

72.

Pro Se Plaintiff seeks same such “Actual Damages” exceeding (7) years Co-

Defendant(s) “Edward McCray and Joyce M. Guy” herein depriving the Pro Se

Plaintiff of his “personal property” namely “Construction tools” in excess of

$3000.00 U.S. Dollars and “lost wages” at a minimums of $48,000.00 U.S. Dollars

being a Independent Construction Contractor “lost wages” per (7) year ongoing

lost since date of injury of November 2007 in the “Actual Theft” of Said

Construction tools.

With 6% interest incurred since date of injury being November 2007 being

lost as being described in paragraph (68) herein Defendant (Attorney at Law)

conspire (RICO) with the Co-Defendant(s) “Edward McCray and Joyce M. Guy”

In the ongoing Civil Action suit in Texas State Court Docket No. A-180805 before

the 58th Judicial District Court of Jefferson County Texas

Pro Se Plaintiff seeks such actual damages in a “Summary Judgment

motion” just filed in November of 2014 and being heard “oral and argue” before

the “Honorable 58th Judicial District Court of Jefferson County Texas on

December 17th 2014 at 8:30 am as this “Honorable 58th Judicial Court

Having full ongoing expert “subject matter jurisdiction” over the Co-

Defendant(s) “Joyce M. Guy” and “Edward McCray” and all “actual damages”

Pro Se Plaintiff seeks therein “State Court”

73.

Other than Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”

Collectively ongoing (RICO) Fraudulent activities among other “Federal Subject

matter jurisdiction” wrongful “acts and actions” being committed in concert,

collusion, and enjoyed manipulation and monetary gain derived thereof with

Defendant as the Pro Se Plaintiff herein “Federal Questions” being raised before

the “Honorable Justice” as to the Defendant and Co-Defendant(s) collective

criminal/civil corrupted scheming uncivil behavior being committed

Against the Pro Se Plaintiff civil rights, peace, will, and dignity in a Civil

Suit in common Law in connection with the Defendant Antoine L. Freeman J. D.

Attorney at Law Texas Bar No. 24058299 defense thereof.

which this “United States Eastern District Court of Texas having full expert

“Honorable Justice” Subject Matter” over such among other things (RICO)

activities described herein full

And the further full knowledge Defendant (Attorney at Law) executed in

full wrongful conspire involvement being of a “Legal expert” to commit to

among other things “obstruction of justice”, corrupted, misleading,

manipulation” and fraud commitment upon the 58th Judicial District Court of

Jefferson County Texas in the public professional trade “among all things”

The “fiduciary capacity” of a legal “Attorney at Law” and “Officer of the

Court” in and For the State of Texas.

74.

Cause of Actions


“Honorable Justice” a Cause of Actions exist for “Intentional Infliction of

Emotional Distress” against Defendant Antoine L. Freeman J. D. Attorney at Law

Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward

McCray”.

Pro Se Plaintiff herein Incorporated and state all Defendant (Attorney at

Law) and Co-Defendant(s) herein enjoyed collectively their “Intent” scheming

fraudulent manufactory purpose in wanting the Pro Se Plaintiff herein to suffer,

extreme agony, heartache, distraint, Accompany substantially massive

monetary loss of “tools and services” in the Construction profession,

75.

Humiliation, Defamation, and crushing legal defeat to inflict “excessive

mental anguish” as a result of their combine craft complex ongoing conspire

(RICO) elements, and fraud on the court to execute the same (RICO) objective

All of which being past, present, and further derive thereof Pro Se Plaintiff

suffrage such future (7) years of ongoing “mental intent contempt” of the

Defendant and Co-Defendant(s) enforced legal corrupted strong hold over the

“common law” rights of the Pro Se Plaintiff


24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray”.

Civilly accomplish with strong corrupted concealment motive not to be

“confused or construed” with a simple attorney mistake by Defendant (Attorney

at Law) a combine collective “cause of action” before the “Honorable Justice”

for continual past, present, and future “Intentional Infliction of Emotional

Distress”.

76.

Cause of Actions


“Honorable Justice” a Cause of Actions exist for “Declaratory Judgment” of the

Honorable Court against Defendant Antoine L. Freeman J. D. Attorney at Law

Texas Bar No. 24058299 and against Co-Defendant(s) “Joyce M. Guy and Edward

McCray” as to all of the “material subject matter” fully declared past, present

and future Before the Honorable Justice herein

Of the Defendant and Co-Defendant(s) Collective conclusive, conspire,

concert, agreements, engagement, and execution, pilot, maneuver,

manipulated, scheme upon (RICO) actions and dealing,

Among other extreme behavior in fraudulent Corruption of The 58th

Judicial District Court System to induce, and perpetrate such Fraud upon the

Court for a period in excess of (19) Months as each so stated, affirm, and

declared statement of “material facts”, “events” and “circumstances” described

fully herein this Complaint

77.

Put an end to a doubt as to the “gross civil intention” of “Antoine L.

Freeman J. D. An “Attorney”, direct at the Pro Se Plaintiff “Civil Liberties” for a

cause of action for “Declaratory Judgment” is made enter into the “Honorable

Justice” decision, and final announcement of the Court Records against said

Defendant.

78.

Put an end to a doubt as to the “gross civil intention” of “Joyce M. Guy”

and “Edward McCray” and their extreme scheming corrupted fraudulent

behavior in “patter and practices” of Mutable (RICO) Fraudulent Scheming

Enterprising Endeavors

Co-Defendant(s) Collective conclusive conspire agreements, engagement,

and execution, pilot, maneuver, manipulated, scheme upon (RICO) actions and

mutable fraudulent underhanded dealing(s),

Among other extreme outrageous behavior in fraudulent Corruption of

“among others” The 58th Judicial District Court System to induce, and perpetrate

such Fraud upon the Court for a period in excess of (19) Months

As each so stated, affirm, and declared statement of “material facts”,

“events” and “circumstances” described fully herein this Complaint direct at the

Pro Se Plaintiff “Civil Liberties” a cause of action for “Declaratory Judgment” is

made enter into the “Honorable Justice” decision, and final announcement of

the Court Records against said Co-Defendant(s) Collectively.

79.


“Honorable Justice” a Cause of Actions exist for ‘Treble Damages” made enter

into the “Honorable Justice” decision, and final announcement of the Court

Records against said Defendant

Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-

Defendant(s) “Joyce M. Guy” and Edward McCray” Collectively for their

combine “wicked”, monstrous, appalling, atrocious, disgraceful, corrupted

behavior direct at the Pro Se Plaintiff “Civil Liberties” .

80.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves

the Honorable Court Justice, to Award to the Pro Se Plaintiff “Declaratory

Judgment” against Antoine L. Freeman J. D. Attorney at Law Texas Bar No.

24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray”

Collectively in favor of the Pro Se Plaintiff.

81.


the Honorable Court Justice, to Award to the Pro Se Plaintiff “Actual Damages”

against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 for

fraudulent conspire against Pro Se Plaintiff “personal property” namely

“Construction Tools” Pro Se Plaintiff Personal property Lost in tool(s) is in excess

of $3093.00 dollars

Award further with full 6% interest rate incurred since date of injury from

November 16th 2007 continual on into 2015 in excess of at a rate of (7) years and

continual counting in favor of the Pro Se Plaintiff 6% interest incurring.

82.


the “Honorable Court Justice”, to Award to the Pro Se Plaintiff “Actual

Damages” against Antoine L. Freeman J. D. Attorney at Law Texas Bar No.

24058299 for fraudulently conspire against Pro Se Plaintiff as described herein

this complaint for “Actual Damages” of “Lost wages” and “Loss of earning

capacity” incurred in the “Continual Actual Theft” and “further executed

fraudulent conspirers activities

Derive thereof” and fully committed, manipulated, scheme against by


herein in the “expert legal professional capacity” as a “Attorney of Law”

Civilly in a Suit in “common Law” against the Pro Se Plaintiff “personal

property” namely “Construction tools”, involving Pro Se Plaintiff Special Trade,

Skill and Profession thereof, in excess of $48,000.00 U.S. Dollars per year in lost

wages Being a accumulated rate now in excess of $336,000.00 U.S. Dollars for

the past (7) years “Lost wages” and “Lost earning capacity” Pro Se Plaintiff

endure suffrage thereof.

“Award” further with full 6% interest rate incurred since date of injury

from November 16th 2007 continual on into 2015 in excess of at a rate of (7)

years past and continual counting in favor of the Pro Se Plaintiff 6% interest

incurring.

83.


the “Honorable Court Justice” for damages in the amount of the Honorable

Court Justice for the Plaintiff suffrage of “Intentional Infliction of Emotional

Distress” and “Mental Anguish” in Excess of the Jurisdictional amount of

$75,000.00 U.S. Dollars against Antoine L. Freeman J. D. Attorney at Law Texas

Bar No. 24058299 in Favor of the Pro Se Plaintiff.

84.



Court Justice for the Plaintiff suffrage of “Intentional Infliction of Emotional

Distress” and “Mental Anguish” in Excess of the Jurisdictional amount of

$75,000.00 U.S. Dollars against Co-Defendant(s) “Joyce M. Guy” and Edward

McCray” in favor of the Pro Se Plaintiff.

85.


the “Honorable Court Justice” for Award of “Treble Exemplary Damages” Statue

of the “Honorable Court Justice” against Defendant Antoine L. Freeman J. D.

Attorney at Law Texas Bar No. 24058299 in favor of the Pro Se Plaintiff.

86.


the “Honorable Court Justice” for Award of “Treble Exemplary Damages” Statue

of the “Honorable Court Justice” against Co-Defendant “Joyce M. Guy” and

Edward McCray” Collectively in favor of the Pro Se Plaintiff.

87.



Court Justice for the Plaintiff suffrage of Defamation of the Pro Se Plaintiff

Construction Reputation in Excess of the Jurisdictional amount of $75,000.00

U.S. Dollars against Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”

collectively in favor of the Pro Se Plaintiff.

88.


the “Honorable Court Justice” for accumulative, compensatory, consequential,

continuing, expectation damages, foreseeable, Future, incidental,

indeterminate, reparable, lawful, proximate, prospective, special, speculative,

substantial, Awards in Excess of the Jurisdictional amount of $75,000.00 U.S.

Dollars against Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”

collectively in favor of the Pro Se Plaintiff for (RICO).

89.


the “Honorable Court Justice” for accumulative, compensatory, consequential,

continuing, expectation damages, foreseeable, Future, incidental,

indeterminate, reparable, lawful, proximate, prospective, special, speculative,

substantial,

Awards in Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars

against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No.

24058299 in favor of the Pro Se Plaintiff for (RICO).

90.


the “Honorable Court Justice” for a Order the Defendant and Co-Defendant(s)

collectively pay all court cost of this U.S. Civil Court Action.

91


and Request the “Honorable Court Justice” for any further, Just, proper,

Damages, Orders, and Awards The “Honorable Court Justice” Deems favorable

for the behalf of Pro Se Plaintiff “Louis Charles Hamilton II” herein.

By, _______________________________

Louis Charles Hamilton II

Pro Se Plaintiff

P.O. Box 17524

Sugar Land Texas 77496