MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al...

In The United States District Court

For The Eastern Division of Texas

Beaumont Division

Louis Charles Hamilton II

Pro Se Plaintiff

Vs. Cause No. 1:14-CV-592

Antoine L. Freeman J. D.

Defendant

Joyce M. Guy

Edward McCray

Co-Defendant(s)

PLAINTIFF'S (TRO) MOTION TO FREEZE DOCUMENTS, RECORDS, AND ASSETS OF DEFENDANT ANTOINE L. FREEMAN J.D.

ATTORNEY AT LAW AND CO-DEFENDANT(S) JOYCE M. GUY AND EDWARD McCRAY

Comes Now the Pro Se Plaintiff Louis Charles Hamilton II herein, files the above entitled motion, with attached brief and exhibit(s) in support of Plaintiff

Order

DEFENDANT ANTOINE L. FREEMAN J.D. ATTORNEY AT LAW AND CO-DEFENDANT(S) JOYCE M. GUY AND EDWARD McCRAY,

To a order to show cause why Pro Se Plaintiff Louis Charles Hamilton II

herein enjoy a “Temporary Restraining Order”, freezing the destruction or alter of all records, and documents set forth herein,

And to secure all of the DEFENDANT ANTOINE L. FREEMAN J.D. ATTORNEY AT LAW HEREIN AND CO-DEFENDANT(S) JOYCE M. GUY AND EDWARD McCRAY

HEREIN, Collective Assets. And for just cause the Pro Se Plaintiff Louis Charles Hamilton II will show as

follows:

(1)

On the Emergency application of the Plaintiff (The “Applicant”) for and Order Defendant Antoine L. Freeman J. D. (Attorney at Law) and all Co-Defendant(s) listed as: “Joyce M. Guy and Edward McCray” collectively defendant(s) to an

Order”, Directing Defendant Antoine L. Freeman J. D. (Attorney at Law) and all Co-

Defendant(s) “Joyce M. Guy and Edward McCray” to show why an order should not be entered, pending a final disposition of this civil action U.S. Cause No. 1:14-CV-592 Preliminary enjoining

Defendant Antoine L. Freeman J. D. (Attorney at Law) and all Co-

Defendant(s) “Joyce M. Guy and Edward McCray” from further violating the United States Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization,

1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1503 (relating to obstruction of Justice), with other Federal and State charges being levy in connection thereof.

(2)

With further Honorable Court requirement(s) directing Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein to provide a verified accounting immediately, including, but not limited to,

A verified written accounting of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein interests in all entities owned, in whole or in part, or controlled by, related to, or associated or affiliated with Defendant Antoine L. Freeman J. D.

(Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” in the United States of America.

(3)

Freezing all of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein business

records, banking records, personal banking records, property deeds, and all assets for all of the above listed Defendant(s) collectively in the United States of America which is necessary to protect this Honorable United States District Court for the

Eastern District of Texas

Ability to decide from the preponderances in deciding the weight of factual evidence, with furtherance allowances in the Honorable United States District Court for the Eastern District of Texas ability in fully applying just awards and

compensation for “actual damages” of all equitable relief

Within all assets, moneys and properties held directly or indirectly by the Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-

Defendant(s) “Joyce M. Guy and Edward McCray” herein for all of the Pro Se Plaintiff “Louis Charles Hamilton II” Direct Actual damages, emotional pain and

suffrage

(4) Wherefore the Pro Se Plaintiff herein respectfully seeks and Order directing

collectively Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

Prohibiting from the destruction, concealment or alteration of all book

keeping records, court documents, banking records, computer records, Insurance records, Business records

Prohibiting from sales, destruction, concealment and or alteration of all

Assets, and Property Deeds

Or by others for the Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein direct and indirect beneficial interest which is necessary to effectuate and ensure compliance with the freeze imposed on the

Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-

Defendant(s) “Joyce M. Guy and Edward McCray” herein, Assets, preserve the books, banking records and all business documents

and records of Defendant(s) Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein until this Honorable United States District Court for the Eastern District of Texas having the ability to determine

The extent to which the freeze should be lifted as to certain records,

documents, and assets in the custody, possession, and legal control of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein.

(5) Preliminarily enjoying Defendant Antoine L. Freeman J. D. (Attorney at Law)

herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein And their partners, owners, agents, employees, attorneys, or other Professional, anyone acting in concert with them, and any third party from

filing a bankruptcy proceeding for the Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein.

Without filing a motion on at least three (3) day’s notice to the Pro Se

Plaintiff “Louis Charles Hamilton II” herein and approval of this Honorable United States District Court for the Eastern District of Texas after hearing; and pending final adjudication, arbitration, negotiation, mediation, settlement of this U.S. District Court Civil Cause No. 1:14-CV-592

(6)

Plaintiff enjoyment of an Order “Temporary Restraining” Defendant

Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein from further violating the United States Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, section 1503 (relating to obstruction of Justice),

Relating to the destruction, concealment or alteration of all book keeping records, court documents, banking records, computer records, Insurance records, Business records as described in the complaint on file with the United States Clerk of Court office herein

Namely all book keeping records, court documents, banking records,

computer records, Insurance records, Business records being further set forth herein

Plaintiff enjoyment of an Order “Temporary Restraining” Defendant

Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein prohibit from sales, destruction, concealment and or alteration of all Assets, and Property Deeds with other Federal and State charges being levy in connection thereof.

Is very beneficial Pro Se Plaintiff herein enjoyment of an expedited Order

“Temporary Restraining” the main Defendant Antoine L. Freeman J. D. (Attorney at Law) herein in Light of the factual circumstances Defendant Antoine L. Freeman J. D. herein is an actual (Attorney at Law) with the “Legal Law Degrees & Special Trade Skills” in among other things

Defendant herein is a actual “Attorney at Law” for hire” in Fraud Litigation,

and Insurance Litigation both of which Defendant Antoine L. Freeman J. D. (Attorney at Law) herein so did in a all factual circumstances and events from the time frame of December 18, 2007 throughout December 18, 2014 abused his legal “Attorney at Law skills” and fully committed to actual “Obstruction of Justice” of a civil suit in common law filed cause No. A-180805

In deal with the designed “Obstruction of Justice” tactic in covering up

“Direct Fraud”, and “Insurance Fraud” committed along with many, many,

numerous other civil/criminal acts and actions of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

Notwithstanding Defendant himself Antoine L. Freeman J. D. (Attorney at

Law) herein criminal aid and conspire to further commit to a future (RICO) and Actual Fraud acts and actions on behalf of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” against the Pro Se Plaintiff herein

Namely Defendant conspire in among other things in the concealment of

the actual property deeds and transfer of said Property to the Texas Department of Housing & Community Affairs

On or before the dates of June 18th 2009 for the dwelling located at 448

DeQueen Blvd. in Port Arthur Texas 77640 being in the possession, custody and control of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein which said dwelling is the main subject matter in Texas State Court docket No. A-180805.

Pro Se Plaintiff

(Brief) (7)

“Good and sufficient cause and reasoning exist why procedure other then notice of motion is necessary, for a Order to show cause, Temporary Restraining Order, Order to Secure Relating to the destruction, concealment or alteration of all book keeping records, court documents,

Banking records, computer records, Insurance records, Business records as

described in the complaint on file with the United States Clerk of Court office herein


computer records, Insurance records, Business records being further set forth

herein from the dates of November 17th 2007 throughout December 18th 2014 for

the Defendant Antoine L. Freeman J. D. (Attorney at Law) herein in his extreme

and outrageous representation of

Co-Defendant(s) “Joyce M. Guy and Edward McCray” against the Pro Se

Plaintiff herein civil suit in common law filed cause No. A-180805 with Pro Se

Plaintiff Motion for Production of Document(s) to Defendant Antoine L. Freeman

J. D. (Attorney at Law) Texas Bar No. 24058299

Attached herein as Pro Se Plaintiff Exhibit (A) filed herein before this

Honorable United States District Court For The Eastern Division of Texas

Beaumont Division appearing before “The Honorable Zack Hawthorn Magistrate

Judge” as being the exact evidentiary records Pro Se Plaintiff request brought

forth before Justice.

(8)

“Good and sufficient cause and reasoning exist why procedure other then notice of motion is necessary, for a Order to show cause, Temporary Restraining Order, Order to Secure evidence Relating to the destruction, concealment or alteration of all book keeping records, court documents, banking records, computer records, Insurance records, Business records as described in the complaint on file with the United States Clerk of Court office herein


computer records, Insurance records, Business records, construction estimates,

FEMA, Property lien records, property deeds records and all records in

relationship to the exact time frame damages caused by

Hurricanes “Rita”, “Humberto” and “Ike” to the property located at 448

DeQueen Blvd. in Port Arthur, Texas being further set forth herein prohibiting any

further attempts at the destruction, concealment or alteration by the Co-

Defendant(s) “Joyce M. Guy and Edward McCray” herein being “chief”

defendant(s) in a civil suit in common law filed cause No. A-180805

*Pro Se Plaintiff “Louis Charles Hamilton II” herein move quite extra

respectfully as requesting the “Honorable Justice Zack Hawthorn Magistrate

Judge” having crystal clear examination of Pro Se Plaintiff Exhibit (B)

Order of the 58th Judicial District Court of Jefferson County Texas filed on

May 10th 2010 at 11:46 am

Ordered that Co-Defendant(s) “Joyce M. Guy and Edward McCray” shall

produce all records and construction estimates for damages caused as a result of

Hurricanes “Rita”, “Humberto” and “Ike” to the property located at 448 DeQueen

Blvd. in Port Arthur, Texas and as of December 18th 2014 well into the year of

2015

Co-Defendant(s) “Joyce M. Guy and Edward McCray” are in complete

refusal to submit of said exhibit (B) Order of the 58th Judicial District Court of

Jefferson County Texas filed on May 10th 2010 at 11:46 am to produce said

documents, records, and construction estimates as described in exhibit (B)

Notwithstanding Co-Defendant(s) “Joyce M. Guy and Edward McCray” are

in complete 100% refusal also to submit to said exhibit (B) Order of the 58th

Judicial District Court of Jefferson County Texas filed on May 10th 2010 at 11:46

am

To produce copies of deeds, property deeds or any other such physical

document in Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

collective possession, custody and control that shows actual ownership of the

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

(Block) 172, Lot 1-2

With Pro Se Plaintiff “Louis Charles Hamilton II” Exhibit (B) filed herein

before this Honorable United States District Court for the Eastern Division of

Texas Beaumont Division

Appearing before “The Honorable Zack Hawthorn Magistrate Judge” as

being the exact evidentiary records Pro Se Plaintiff request brought forth before

Justice.

(9)

Pro Se Plaintiff, declare, affirm, and state before the “Honorable Justice”

Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein were “monetary retain” to file a General Denial on December 18th 2007 and then Defendant Antoine L. Freeman J. D.

Claims that he was legally retained once again at some point as acting

Attorney of Record (Attorney at Law) Texas Bar. No. 24058299 to prepare and be ready to attended (2) court hearing before the 58th Judicial District Court in Jefferson County Texas for the legal behalf of Co-Defendant(s) Joyce. M. Guy and Edward McCray herein cause No. A-180805 on the dates of “August 28th 2009 and September 11th 2009

While Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein having full possession, custody and legal control over discovery request of Interrogatories, Request for Admission, and Request for Disclosure Pro Se Plaintiff mailed to him on the dates of April 2nd 2008 and April 11, 2008,

And Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein did not respond to any of said discovery request until on or about October 14th 2009.

Some (1) year and (6) months plus days later as Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein was requested to complying with Texas rules of Civil Procedures, 194.2., 197, and 198. Request of Interrogatories, Request of Admission, and Request for Disclosure for civil cause No. A-180805

However at some point Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein did in Facts and Circumstances file a “Motion for Withdrawal” as Attorney of record for the behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein on

November 13th 2009 @ 10:22 AM in the Judicial District “Clerk of Court Office” of Jefferson County Texas. Being filed as Pro Se Plaintiff Exhibit (F) attached herein

(10)

Pro Se Plaintiff, declares, affirm, and state further before the “Honorable Justice” Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein legally was acting “Attorney of Record from December 18, 2007 throughout November 13th 2009 @ 10:22 AM for cause No. A-180805

As being described in Pro Se Plaintiff exhibit (C) herein Defendant Antoine L. Freeman J. D. (Attorney at Law) Motion to withdrawal as Counsel for the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

(11)

Pro Se Plaintiff, declares, affirm, and state further before the “Honorable Justice” Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein legally was acting as “Attorney of Record on or about the dates of August 28th 2009 and September 11th 2009

“However Legally Underhanded” during the same “time frame” of

Defendant Antoine L. Freeman J. D. (Attorney at Law) representation of civil suit No. A-180805 on or about June 18th 2009

Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively by

and throughout their “Attorney of Record” being Defendant (Attorney at Law) herein himself conspire together with the additional ongoing fraudulent activities of

Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein whom now

had conspire, executed and commence further (RICO) Fraud Activities and engage in the actual concealment of the “identifying property deeds” being a party to a Breach of Construction Contract with the

Pro Se Plaintiff Louis Charles Hamilton II herein being filed in Texas State

Court Complaint docket No. A180805 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” during their ongoing Legal Retain Hire Top Gun Representation with Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

Transfer of said Property located at 448 DeQueen Blvd. in Port Arthur Texas

(Block) 172, (Lot) 1-2 to “Texas Department of Housing & Community Affairs” as

Filed in Jefferson County Clerk Records # 2009022762, for a $76,000.00 Federal Housing Grant, as being described in Pro Se Plaintiff attached exhibit (C) herein “Jefferson County Texas Property Search Index”

(12) Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein further on June

18th 2009 while involved in this (RICO) activities as being described in paragraph (13) above filed a “fraudulent financing statement” in Jefferson County Clerk Records instrument # 2009022763

In the connection thereof for fraud activities engagement of the “Texas

Department of Housing & Community Affairs” for a monetary gain of in excess of said $76,000.00 U.S. Dollars Federal Housing Grant

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

already squandering all of the Home Owner Insurances funds, FEMA Funds designated for “actual building repairs” of said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2

Being as a result of Hurricanes damages from Hurricanes “Rita”, Humberto,

and “Ike” as described in Pro Se Plaintiff attached exhibit (B) herein 58th Judicial District Court of Jefferson County Texas “Court Order” and the Pro Se Plaintiff Louis Charles Hamilton II being a Party thereof docket No. A-180805

During this entire discovery phase time frame of the Defendant Antoine L.

Freeman J. D. (Attorney at Law) which commenced on or about April 2nd 2008 and April 11, 2008 in all factual circumstances and events

Leading up to a required Court Order being filed by the 58th Judicial District

Court of Jefferson County Texas and enforced as described in Pro Se Plaintiff exhibit (B) attached herein

Was fully required after a year plus dates for Co-Defendant(s) “Joyce M.

Guy and Edward McCray” herein to produce such “Property Deeds” to said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2

well into 2015 still no compliance from Defendant and Co-Defendant(s) collectively.

(13) As they Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein already

having been so served a “Motion for Production of Document” for copies of said “Property Deeds” showing actual ownership of dwelling located at 448 DeQueen Blvd. in Port Arthur Texas by and through said

“Attorney of Record” being Defendant Antoine L. Freeman J. D. (Attorney at

Law) herein on August 12th 2009 to produce such copies of Property Deeds to the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas Meanwhile the said “Attorney of Record”

”The Main Defendant” Antoine L. Freeman J. D. (Attorney at Law) actually

physically appear in his dated (RICO) “Attorney at Law” presentation on the behalf of Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein on or about the dates of first August 28th hearing before the Honorable 58th Judicial District Court of Jefferson County Texas

As being fully described in Pro Se Plaintiff attached Exhibit (D) filed herein

The 58th Judicial District Court of Jefferson County Texas Docket report Civil Cause No. A-180805

While said Defendant Antoine L. Freeman J. D. (Attorney at Law) already in

legal possession, custody, and control over said discovery documents of Interrogatories, Request for Admission, and Request for Disclosure mailed

in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, during this time frame of on or about April 2nd 2008 and April 11, 2008 request (30) days thereafter for a respond of some sorts which this “Obstruction of Justice” (RICO) scheme of things

Went clearly unobstructed throughout the dates of on or about June 18th

2009 before the 58th Judicial District Court of Jefferson County Texas whereby the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein legally transfer said

Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 to the “Texas Department of Housing & Community Affairs” for said $76,000 Federal Housing grant.

(14) Notwithstanding “SWMJ CONSTRUCTION INC.” filed a “Mechanics Lien” on

June 18th 2009 on said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 said property being a party to civil suit in common law since 2007

With the Pro Se Plaintiff herein as filed into Jefferson County Texas Clerk records instrument #2009022761

As this “Mechanics Lien” further being respectfully described in Pro Se

Plaintiff Louis Charles Hamilton II attached exhibit (D) herein before the “Honorable Justice”.

(15)

Meanwhile the said “Attorney of Record” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 still (Stupidity) conspiring to boldly cutting his very own “legal brake lines” carrying on in his none stop (RICO)

furtherance’s activities by continue engaging ongoing well into the time frame

there after the official dates of June 18th 2009

When the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

legally transfer said Property located at 448 DeQueen Blvd. in Port Arthur Texas

(Block) 172, (Lot) 1-2 to the “Texas Department of Housing & Community Affairs”

for future fraudulent activities of said $76,000 Federal Housing grant.

And “SWMJ CONSTRUCTION INC.” now being identified herein filed a

“Mechanics Lien” on June 18th 2009 on said Property located at 448 DeQueen

Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 the said same property being a party to civil suit in common law since 2007 involvement with the Pro Se Plaintiff “Louis Charles Hamilton II herein.

(16)

Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar.

No 24058299 herein on September 11th 2009 there after the 9/11 World Trade Center Memorial was conducted in front of the Jefferson County Texas

Courthouse,

Made his grand (RICO) resurfacing reappearance (Attorney at Law) act II for the hearing on 9/11/2009 as being described in Pro Se Plaintiff exhibit (D)

herein (2) months and exactly 20 some odd days later thereafter when Co-Defendant(s) Joyce M. Guy and Edward McCray herein

Legally transfer said Property located at 448 DeQueen Blvd. in Port Arthur

Texas (Block) 172, (Lot) 1-2 to the “Texas Department of Housing & Community Affairs” for said Fraud of $76,000 Federal Housing grant.

Thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein already in legal possession, custody, and control of discovery documents of Interrogatories, Request for Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,

During this time frame of on or about April 2nd 2008 and April 11th , 2008 throughout the dates of on or about (Now) in the “new time frame of” September 11th 2009 when Defendant Antoine L. Freeman J. D.(Attorney at Law) herein now commencing as acting presently as “Attorney of Record”

On this 9/11/2009 “Live Hearing Court Date” before the 58th Judicial District

Court of Jefferson County Texas as being described in Pro Se Plaintiff attached exhibit (C) herein The 58th Judicial District Court of Jefferson County Texas Docket Report

(17) Notwithstanding simple “material facts and circumstances” Defendant

“himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein and Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively already being furtherance in conspire (RICO)

“Obstruction of Justice” fraudulent activates namely in the concealment and refusal to comply with all of said discovery request

For the entire year time frame of April of 2008 throughout April of 2009 and finally submitted and responding to the Pro Se Plaintiff discovery request well into the New Year of November 13th 2009 this addition of “Obstruction of Justice” is being provided as Proof before the Honorable Justice”

By and through the legal representation of on again and off again slipping in

and out of a “legal coma of some sorts” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 in his extreme outrageous (RICO) conspire representation of the entire civil suit Docket No. A-180805 in full concert, collusion, and corruption assistance with the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

Resurface as on again acting “Attorney of Record” at this time frame of

September 11th 2009 Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) herein as proof being described in Pro Se Plaintiff exhibit (E) attached herein “Namely” The 58th Judicial District Court of Jefferson County “Ledger report” for

Civil Suit in Common Law Docket No. A-180805

As Pr Se Plaintiff Louis Charles Hamilton II herein attached exhibit (E) 100% sound “Meat-n-Potatoes” legal proof being submitted for a showing before

the “Honorable Justice” the actual entire legal status of the “Attorney of Record” acts and rogue actions directed at the

Pro Se Plaintiff herein from the starting dates of December 18th 2007 and his

(Attorney at Law) continue wrongful “Obstruction of Justice” type engagement in this (RICO) corrupted conspire activities affairs of some sort in concert with the

Co-Defendant(s) collectively

Some additional (2) months and exactly 20 some odd days later thereafter

when Co-Defendant(s) Joyce M. Guy and Edward McCray herein already legally

transfer said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block)

172, (Lot) 1-2 to the “Texas Department of Housing & Community Affairs” for said

$76,000 Federal Housing grant on June 18th 2009.

(18)

To include but not limited to the factual hostile and bold circumstance and

legal events thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein during the time frame of “August 28th 2009

already being in legal possession, custody, and control over Pro Se Plaintiff Motion for Production of Documents

For Production of said “Property Deeds” which is a party to the Texas State Civil Court action in Common Law Cause No. A-180805 and both “Defendant and

Co-Defendant(s)” collectively flat out refusal to Produce such “Property Deeds” well into 2015 after a Court order was even obtain on May 10th 2010 for the production of said Property Deeds.

To include but not limited to the factual hostile and bold circumstance and

legal events thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein during the time frame of “April 2nd 2008 and

April 11, 2008 well into November 13th 2009 when “Defendant and Co-Defendant(s)” collectively

Already enjoying many (RICO) “Obstruction of Justice” tactics and engage

furtherance in “pilferage and plundering” the “Texas Department of Housing & Community Affairs” for said in excess of the $76,000 Federal Housing grant.

Thereafter Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law)

Texas Bar. No 24058299 herein executed, and used the United States of America “innocent mailing system”

And all court records and computer systems derive thereof in this (RICO)

Fraud and “Obstruction of Justice” scheme of things.

To include Defendant (Attorney at Law) herein execute even furtherance this fraudulent “Skilled at Fraud Law” to his advantages corrupted “scheme of

things” for the legal behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein

Collection to obtain all ill-gotten Pirate monetary gains as fully described in Texas States Court before the 58th Judicial District Court of Jefferson County Texas and before The “Honorable United States Justice”

“The Honorable Zack Hawthorn United States Magistrate Judge”

Present entertainment and examination herein now in “Justice” against

among others the “Civil Rights”, “Peace”, “Dignity” of the Pro Se Plaintiff “Louis

Charles Hamilton II herein a legal citizen and United States Naval Veteran within the “State of Texas” and “The United States of America”.

“To include but not limited to” adding “insult to injury” actual damages being inflicted wrongfully to the earning capacity of the Pro Se Plaintiff “Louis

Charles Hamilton II herein

Being legally represented as an “Independent Construction Contractor” in this ongoing 2015 (RICO) scheme of things corrupted heist since November of

2007 of the Defendant and Co-Defendant(s) collectively herein

(19)

In addition to include but not limited to “Actual damages” in excess of $3085.00 U.S. Dollars of the Pro Se Plaintiff Entire Independent Contractor

Company Construction tools being in a state of “Theft of Property” in this

“Breach of Construction Contract” civil action in first filed in Texas State Court now such loss continue (RICO) style under the direction of the hands of the

Defendant for the legal wrong behalf of the Co-Defendant(s) ) Joyce M. Guy and Edward McCray collectively described correctly herein in this now infamous

ongoing into 2015

(RICO) fashionable complex scheme of things involved with the Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively conspire with

the leadership of “Retain for Hire” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein

Being quite “fraudulently skillful, and legally in the professional

capacity as an “Attorney at Law” dealing with among other things Specialist in “Fraud & Insurance litigation”

(20)

Being crafty apply against the Pro Se Plaintiff Louis Charles Hamilton

II herein in a civil suit in common law within Texas State Court thus now Pro Se Plaintiff respectfully providing all such (RICO) and “Obstruction of

Justice”

Ongoing activities since 2007 subject matter now to the official handling Jurisdiction before the “Honorable Justice” of the entitled above United

States District Court for the Eastern District of Texas namely “the “Honorable Zack Hawthorn United States Magistrate Judge”

A endless ongoing (RICO) “Court Room Drama sorts of scheme of things since activated in November 17th 2007 with continue (RICO) acts and

actions of activities involving among other things, past

Hurricanes “Rita, “Humberto” and “Ike” the Co-Defendant(s) causing among other things to the Pro Se Plaintiff herein “Direct Loss” of all tools and

of lost wages in excess of $48,000.00 U.S. dollars for a time frame exceeding now seven (7) years and counting into 2015 in collusion, concert and

guidance’s with Defendant (Attorney at Law) herein

With this extreme “buck legal wild” cruel inflicted, unwanted financial coup, and hardship being (RICO) fashion nicely imposed by “Commander in

Attorney at Law Chief”

The Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 himself herein

And for the “Legal financial wrongful benefit and “Civil behalf” of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein collectively in a Civil Suit

in Common Law within the State of Texas Jefferson County Docket No. A-180805.

(21)

Pro Se Plaintiff, declares, affirm, and state further before the “Honorable Justice” Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein legally continue to commit to “Actual Fraud” upon the 58th Judicial District Court of Jefferson County Texas

In this connection of (RICO) “Obstruction of Justice” in that on or about the same 9/11/2009 “time frame” filed before 58th Judicial District Court Judge

“Bob Wortham” A Response to Pro Se Plaintiff Motion for Sanctions against

Defendant Antoine L. Freeman J. D. (Attorney at Law) herein containing in all factual legal circumstances

“The Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 Public recorded “Affidavit” attached being signed and dated

September 11th 2009 be Defendant “Attorney at Law” herein

Subscribed and Sworn “Statement” admitting among other things

Defendant, Joyce Guy, retained the services of Antoine L. Freeman J. D. (Attorney at Law): “For the purpose of writing a general denial so as to avoid a default judgment being rendered against her.

Dated September 11th 2009 while Pro Se Plaintiff “Louis Charles Hamilton II herein attached exhibit (D) 58th Judicial District Court “Docket Report” for cause No. A-180805 and attached exhibit (E) 58th Judicial District Court “Ledger Report” for cause No. A-180805

(22) Clearly showing before the “Honorable Justice” the Defendant Antoine L.

Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 engaging in mutable “retained” services to include attendance to court hearing dates of August 28 th 2009 and then again on September 11th 2009

While Defendant (Attorney at Law) herein being in full possession, custody

and legal control over discovery documents of Interrogatories, Request for Admission, and Request for Disclosure mail in the

“United States Mailing System in accordance with the Texas Rules of Civil

Procedures 194.2, 197, and 198,

During this time frame of on or about April 2nd 2008 and April 11th,

2008 as being described in Pro Se Plaintiff attached exhibit (E) 58th Judicial District Court “Ledger Report” for cause No. A-180805

(23)

Clearly showing before the “Honorable Justice” the Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 engaging received

possession, custody, and legal control from Pro Se Plaintiff “Louis Charles Hamilton II” herein a

“Motion for Production of Document(s) dated August 12 th 2009” on the certificate of mailing services for the same cause No. A-180805 filed in the

Jefferson County Texas Courthouse

Said Motion for Production of Document(s) requested “among other

things” copies of the “Property Deeds” showing actual ownership of the dwelling of 448 DeQueen Blvd. in Port Arthur Texas that’s being in the possession, custody and legal control of the Co-Defendant(s) “Joyce M. Guy

and Edward McCray” herein

(24)

When the said Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

in all factual circumstances and events conspire and retain Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 in a (RICO) scheme of things in December of 2007 and

Legally transfer said Property located at 448 DeQueen Blvd. in Port Arthur

Texas (Block) 172, (Lot) 1-2 to the “Texas Department of Housing & Community Affairs” on June 18th 2009 having “Defendant (Attorney at Law) herein

For future fraudulent activities of said $76,000 Federal Housing Grant. As being described in Pro Se Plaintiff exhibit (C) attached herein “Jefferson County

Texas Property Search Index” # 2009022762

And “SWMJ CONSTRUCTION INC.” now being identified herein filed a

“Mechanics Lien” on June 18th 2009 on the same said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2

The said same property being a party to civil suit in common law since 2007

involvement with the Pro Se Plaintiff “Louis Charles Hamilton II herein and Defendant (Attorney at Law) and the Co-Defendant(s) collectively.

As being described in Pro Se Plaintiff exhibit (C) attached herein “Jefferson County Texas Property Search Index” # 2009022761 for a Civil Suit that was conducted and executed on the month of November of 2007.

(25)

Response to Pro Se Plaintiff Motion for Sanctions against Defendant

Antoine L. Freeman J. D. (Attorney at Law) with attached “Affidavit” herein filed

as Pro Se Plaintiff attached exhibit (G) herein before the “Honorable Justice” sealing the (RICO) “Obstruction of Justice”,

Fraud upon the Court combine conspiring involvement activities of Defendant (Attorney at Law) “legal defense” in an Honorable Court of Law for the civil legal behalf of the Co-Defendant(s) collectively against the Pro Se Plaintiff in

a civil suit in common law.

(26)

Pro Se Plaintiff, declares, affirm, and state further before the “Honorable Justice” Pro Se Plaintiff attached exhibit (H) herein before the “Honorable Justice” Attached Affidavit of Co-Defendant Joyce M. Guy sealing the (RICO) conspiring involvement activities of Co-Defendant(s) collectively consciousness corrupted mutable count fraudulent “pattern and practices”

While in all legal factual acts and circumstances executed “among other things” actually fraudulently appearing from the very start before a Honorable Court of Law for the civil legal behalf of the Co-Defendant(s) own legal interest

collectively against the Pro Se Plaintiff in a civil suit in common law in 2007 and continue to pilferage and plunder in 2009 during a “Live” ongoing docket No A-

180805

To commit to Fraud of the 58th Judicial District Court of Jefferson county

Texas by and throughout their retain “Attorney at Law” being Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 to wrongfully gaining

in excess of $76,000 U.S. Dollars Federal Housing grant.

And the furtherance’s of such (RICO) scheme of things against all of the

Jefferson County Court House 58th Judicial District court records and against the

“Texas Department of Housing & Community Affairs” for said executed Actual

Fraud thereof.

(26)

Pro Se Plaintiff, declares, affirm, and state further before the “Honorable Justice” The Honorable United States District Court of Texas Beaumont Division

Presiding Judge: Marcia A. Crone

Referring Judge: Keith F. Giblin

Pro Se Plaintiff attached exhibit (I) herein before the “Honorable Justice” Defendants Original Answer to U.S. Docket No. 1:2010-CV-00055 Hamilton vs. Freeman et al.

As Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein honestly “first foolish” (RICO) fraudulent mistake within “Federal Jurisdiction Court of Law” was to Proceed as a Defendant being an “Attorney at Law” representing himself before

“Honorable Justice” "a lawyer who represents himself has a fool for a client"

*Especially against this particular Pro Se Plaintiff herein on a Federal Level.

(27)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein honestly “second foolish” (RICO) fraudulent mistake within a “Federal Jurisdiction Court of Law”

Was to proceeding in once again “retain Top Gun for Hire “Attorney at Law” fashion” in the quite foolish (RICO) further “legal representation” attempt of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

While “retain Top Gun for Hire “Attorney at Law” in April 30th 2010 being

Defendant (Attorney at Law) herein being negative in the past full possession, custody and legal control over discovery documents of

Interrogatories, Request for Admission, and Request for Disclosure mail in

the “United States Mailing System in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198,

During this time frame of on or about April 2nd 2008 and April 11th,

2008 as being described in Pro Se Plaintiff attached exhibit (E) 58th Judicial District Court “Ledger Report” for cause No. A-180805.

(28)

While “retain Top Gun for Hire “Attorney at Law” in April 30th 2010

appearing before a Federal Court of Law now *Especially against this particular Pro Se Plaintiff herein being a Defendant (Attorney at Law) herein bring forthwith

all of his past (RICO) “Obstruction of Justice” concealment negative activities as

related in the past Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

Being quite fully crafty sketchy & precise skill in a ongoing functional fraudulent “legal objectives” in the concealment possession, custody and legal

control over discovery documents of a “Motion for Production of Document(s)” dated August 12th 2009” on the certificate of mailing services for the same

cause No. A-180805 filed in the Jefferson County Texas Courthouse

Said Motion for Production of Document(s) requested “among other things” copies of the “Property Deeds” showing actual ownership of the dwelling of 448 DeQueen Blvd. in Port Arthur Texas that’s being in the possession, custody and legal control of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

Transferring of said Property located at 448 DeQueen Blvd. in Port Arthur

Texas (Block) 172, (Lot) 1-2 to “Texas Department of Housing & Community Affairs” as Filed in Jefferson County Clerk Records # 2009022762, for a $76,000.00 Federal Housing Grant,

As being described in Pro Se Plaintiff attached exhibit (C) herein “Jefferson County Texas Property Search Index” while under the “retained guidance’s services of Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

(29) Being now a (Rogue) “Attorney at Law” directly engaging to continue with

this ongoing (RICO) “buck wild” Top Gun “Attorney at Law” fashionable “scheme of things” involving “first and foremost” the complete fraudulent “court records” of the 58th Judicial District Court of Jefferson County Texas

Before the Honorable Justice Presiding United States Judge Marcia A. Crone

and referring Honorable Magistrate Judge Keith F. Giblin

(30)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein honestly “thirdly foolish” (RICO) fraudulent mistake within a “Federal Jurisdiction Court of Law”

*Especially against this particular Pro Se Plaintiff herein on a Federal Level was to proceeding stating in Pro Se Plaintiff exhibit (I)

“Defendant denies each and every allegation of Plaintiff’s Original

Petition, and Demands strict proof thereof as required by the Texas Rules of Civil Procedure. (OK)

(31)

Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein past history of on again and off again slipping in and out of a self

induced “legal coma of some sorts” for the civil legal behalf and civil interest of

the Co-Defendant(s) Joyce M. Guy and Edward McCray collectively

Against the Pro Se Plaintiff in a civil suit in common law Docket No. A-180805 with “Actual Damages in excess of $340,000.00 U.S. Dollars since date of

injury November 17th 2007 with 6 % interest incurred since date of Injury

Being now a Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 in U.S. Cause No. 1:14-CV-592 demands in the past before a

Subject Matter “Federal Jurisdiction” boldly claiming “among other things”

Pro Se Plaintiff herein must fully adhere to “Texas Rules of Civil Procedure” and provide the strictest proof thereof before The United States District

Court of Eastern Texas “Beaumont Division

While Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 fully now in 2010 having executed his “Attorney at Law” future (RICO)

fashionable acts and actions status of completed among other things the outstanding

“Obstruction of Justice” Fraud upon a Texas Court of Law fraudulent concealment of “Property Deeds”, and being a party to the absolutely destruction

of physical court evidence being said dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2

(32)

Notwithstanding now in April 30th 2010 appearing before a Honorable Court of Law on a Federal Level no less Defendant Antoine L. Freeman J. D.

(Attorney at Law) Texas Bar No. 24058299 herein completely already “legally molestation” and having his “rogue wayward relationship”

In enjoyment of “butt screwing” the Pro Se Plaintiff herein” since December

18th 2007 well into the new year of our Lord 2015 before this “Honorable Justice”.

By legal commitments “among other things” (RICO) “Obstruction of Justice, Fraud of a Texas State Court and denying the Pro Se Plaintiff “Louis

Charles Hamilton II herein appearing as acting “Attorney of record” in a Pro Se fashion before a Civil Court of Law in a suit in common law in and For the State of

Texas Docket No. A-180805

Whereby Pro Se Plaintiff having the full weight and legal enjoyment, & same required respect of said “Texas Rules of Civil Procedure” as the Defendant

Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein so fully enjoyed to the complete destructive disadvantage over the Pro Se Plaintiff

“Louis Charles Hamilton II” herein civil rights, peace and dignity

(33)

And justly bringing forth such introduced well legally documented (RICO) criminal history of a corrupted “Attorney at Law” among other things

And his foolish legal “shenanigans” once again brought forth in April 30th

2010 before the Honorable Justice Presiding United States Judge “Marcia A. Crone” and referring Honorable Magistrate “Judge Keith F. Giblin” and

“Justice so served stupidity invited thereby their own (RICO) criminal past,

present, and future scheme of things “acts and activities of their on making of Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

And Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” collectively herein into the Federal Jurisdiction Level as being described this undersigned dated herein in Pro Se Plaintiff exhibit (I).

(34) Pro Se Plaintiff declares, affirm, and state further before the “Honorable

Justice” Co-Defendant(s) “Joyce M. Guy” the moment “she” & Husband Co-Defendant “Edward McCray”, herein committed to among other things “Physical Assault & “Theft of Property” Namely all Construction Company Tools as identified in The Pro Se Plaintiff attached exhibit (J) herein

“Original Complaint” filed in the 58th Judicial District Court of Jefferson

County Texas Cause No. A-180805. As showing the Construction Tools Listed as follows: a. Brand New Hitachi Air Compressor #2700009 $680.00 b. Bosch Drill M# Brute S# NV $345.00 c. “Portacable Skill saw $137.00 d. Dewalt Sawall $97 e. “Hitachi Nail Gun (Framing) $327.00 f. “Hitachi Roofing Nailer $315.00 g. Gas Power Generator $300.00 h. Extension ladder $127.00 i. 100 ft. of air hose $95. j. 50ft. of air hose $42. k. 100ft. electric cord $70 l. 50ft. electric cord $38 m. (4) Framing hammers $37. (each) n. “Pro Se Plaintiff “Personal Hammer” $48. o. “Leather tool belt” $50. p. Kobalt Razor Knife $17. q. Swanson pencil set & refills $22. r. “Black tool box & Respiratory $138.00 s. “Extreme Safety Face Shield” $30 t. Ear plugs (2) pack $16. u. (4) Normal face respirators with strap $12. v. Small assortment pliers set $35.

w. (2) Tuck pointers $24. x. (1) Square mouth shovels $18. y. (1) set of blueprints $1200.00 z. Gas container 15. aa. Masonry trowel $18. bb. “Fatmax 35ft. tape measure $30. cc. Catspaw nail puller $12. dd. Speed square $8. ee. Contractor Calculator $34. ff. Crowbar $17. gg. Utility knife (3) $9. (Each) hh. Nail Punch $8. ii. Maxx Gloves $34. jj. Canvas Tarp 95ft. X 180ft. $100.00 kk. Roofing shovels (2) $48. (Each) ll. Saw blades with drill bits $24. mm. (2) Speed square (Plastic) $5. (Each) nn. 25ft. “Fatmaxx tape measure $19.00 oo. 3-way air hose fitting set $38. pp. Case of Gatorade $12. qq. Residential framing book $21. rr. (2) Paint brushes $14. (Each) ss. (1) Paint scraper $14. tt. (1) Paint scraper wire handle $10.

(35)

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

24058299 herein fully conspire, and direct his (RICO) Obstruction of Justice”,

Fraud of the 58th Judicial Court of Jefferson County Texas

Among other fraudulent devices concocted by said Defendant for the

Wrongful Civil Benefit and behalf of the Co-Defendant(s) “Joyce M. Guy” and

“Edward McCray” herein against the Pro Se Plaintiff

To deprive the Pro Se Plaintiff in addition to the “Breach of Construction

Contract to fix said dwelling which Insurances money(s) in excess of $10,800.00

U.S. Dollars had been designated for said damages repairs as a result of

Hurricanes “Humberto”

Defendant (Attorney at Law) fully aware of the complaint and all discovery

requests therein from December 18th 2007- April 30th 2010 and attached

“Himself” to deprive the Pro Se Plaintiff of his entire Construction Company tools

as being described above in paragraph (34) above and further illustrated in Pro Se

Plaintiff attached exhibit (J) herein

(36)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable

Justice” such Construction Company tools do in fact did exist and is fully described

and fully supported in Pro Se Plaintiff attached exhibit (K) herein “Copy” of Lewis

Garza “Affidavit” original being filed in the Jefferson County Texas Courthouse

Docket No A-180805

Subscribed and Sworn” Affidavit of “Lewis Garza”

Stating: On November 17th, 2007 I took my stepson to 448 DeQueen Blvd. in Port

Arthur Texas. To do work on a house. He had a few thousand dollars in tools.

The Owner of the home kept all of the tools and refused to return them.

Ladders, generator, Nail guns, & numerous hand tools.

Lewis Garza

Subscribed and Sworn on the 14th day of November 2014

“Kendra Monk” Notary Public, State of Texas

(37)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable Justice” as a result of Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 (RICO),

“Obstruction of Justice”, Fraud of the 58th Judicial Court of Jefferson County Texas among other acts and actions Defendant (Attorney at Law) herein

“Foolishly” directed, being in concert, collusion, “Attorney at Law” concealment of records and legally engaging collectively with the Co-Defendant

“Joyce M. Guy and Edward McCray herein the “absolutely destruction” of “physical evidence” …

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

(Block) 172, (Lot) 1-2 while being in an ongoing civil action in November of 2007

Pro Se Plaintiff declares, affirm, and state furtherance before the “Honorable Justice” added into this equation in 2009 Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 (RICO) in concert,

collusion, concealment and legally engaging collectively

With the Co-Defendant “Joyce M. Guy and Edward McCray herein in the further fraudulent plunder for more “Pirate Loot” there after already in the past of

scheming, plotting twisted robbery,

And actual heist thereof of “Private Insurances Companies repair funds and FEMA repair Funds, for the following Hurricanes “Rita”, Humberto, and “Ike” on

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

(38)

To include but not limited to the Co-Defendant “Joyce M. Guy and Edward

McCray herein scheming, plotting twisted robbery, and actual heist thereof of “Private Insurances Companies repair funds and FEMA repair Funds, for the

following Hurricanes “Rita”, Humberto, and “Ike” on the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas

Scheming, plotting twisted robbery, and actual heist thereof of “Private

Insurances Companies repair funds and FEMA repair Funds, for the following Hurricanes “Rita”, Humberto, and “Ike” on the dwelling located at SBD Lake

View block 4 Lot 10

which said Co-Defendant “Joyce M. Guy” having enjoyment over her Mother Legal Affairs as described in the “Power of Attorney” on filed and attached

herein Pro Se Plaintiff exhibit (C) “Jefferson County Search Index Instrument # 2010042042

As this additional property also located at SBD Lake View block 4 Lot 10 being in the possession, custody, and legal control of Co-Defendant “Joyce M.

Guy” herein having also a “”Mechanics Lien”

Filed against this property on November 16th 2010 on file and attached

herein Pro Se Plaintiff exhibit (C) “Jefferson County Search Index Instrument #2010042043

(39)

Notwithstanding Co-Defendant “Joyce M. Guy” herein Scheming, plotting

twisted robbery, and actual heist thereof of “Private Insurances Companies repair funds and FEMA repair Funds, for the following Hurricanes

“Rita”, Humberto, and “Ike” on the dwelling located at 5050 east 7th street in

Port Arthur Texas (Being) Norma Guy home (Mother)

(40)

Notwithstanding Co-Defendant “Joyce M. Guy herein scheming, plotting

her twisted robbery, and actual heist thereof against the “Aging, and Disability

Elderly Citizens within Jefferson County Texas from

the start time frame of May 7th 1997 the company called G and G Service

Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas (Office) located

at 448 DeQueen Blvd. in Port Arthur Texas 77640 identified herein also under Pro

Se Plaintiff attached exhibit (C) as Instrument # 49894

In which this company called G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas is “Actually” an illegal medical business designed for the disable elderly senior citizens of Jefferson County Texas

On going from the dates of May 5th1997 throughout January 7th 2010 for a period of 13 years of “Earn Income” with cash being paid to all “employees” no taxes being paid ever to the “State of Texas or (IRS) for the United States of

America

(41)

And G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas this assume “medical business” operation and office location is

“Actually” a “vacant lot” in Port Arthur Texas

When it was order shut down by the “State of Texas Department of Aging

and Disability Services” on January 7th 2010 until a real HCSSA licensed being obtain.

After Pro Se Plaintiff “Louis Charles Hamilton II” herein conducted his own

exclusive Cmdr. Blue fin (USN) deep sea in-depth investigation into all described Defendant and Co-Defendant(s) herein corrupted History being described in

among other things in

Pro Se Plaintiff attached exhibit (L1) Certified Mail: 70031010000368381858

From “State of Texas Department of Aging and Disability Services” to G

and G Service Company (Owner) Co-Defendant “Joyce M. Guy” stating among other things

(42)

“You are in violation of health and safety code chapter 142 by engaging in

home health or personal assistances services which includes hand-on personal

care; by representing to the public that it “G and G Service Company” is a

provider of home health, or personal assistance services which includes hands-on

personal care for pay.

“You do not have a valid HCSSA license; therefore, you must immediately

cease providing these services or representing to the public that you provides these

services.

And described further in Pro Se Plaintiff attached exhibit (L2) herein

“State of Texas Department of Aging and Disability Services” letter to the

Pro Se Plaintiff stating among other things:

We are in receipt of your recent inquiry regarding your complaint made on September 2nd 2009 regarding GNG Service Company, 5050 East 7th street, Port

Arthur, Texas 77640

(43)

Which the Pro Se Plaintiff wish to clearly point out to the “Honorable

Justice” this complaint being made in exhibit (L2) attached herein was executed on September 2nd 2009 to the “State of Texas Department of Aging and Disability

Services” (exactly) three (3) months

there after the Co-Defendant “Joyce M. Guy and Edward McCray herein Legally transfer said Property located at 448 DeQueen Blvd. in Port Arthur Texas

(Block) 172, (Lot) 1-2 to the “Texas Department of Housing & Community Affairs” on June 18th 2009 in collusion, conspire fraudulent concert with

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

For future fraudulent activities of monetary gain in excess of said $76,000 Federal Housing Grant.

As being described in Pro Se Plaintiff exhibit (C) attached herein “Jefferson

County Texas Property Search Index” # 2009022762

And “SWMJ CONSTRUCTION INC.” now being identified herein filed a “Mechanics Lien” on June 18th 2009 on the same said Property located at 448

DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2

The said same property being a party to civil suit in common law since 2007 involvement with the Pro Se Plaintiff “Louis Charles Hamilton II herein and

Defendant (Attorney at Law) and the Co-Defendant(s) collectively.

(44)

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

herein having another business namely

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

448 DeQueen Blvd. in Port Arthur Texas 77640 being legally owned by the

Defendant(s) “Joyce Guy and Edward McCray”, assumed name filed on April 11th

2008 Jefferson County Clerk records #72594 as described in Pro Se Plaintiff

exhibit (C) attached herein

1807 East 7th street in Port Arthur Texas is actually (Once again) as Pro Se

Plaintiff state before the “Honorable Justice” being a actual “Vacant Lot” which

has been on occasions raided by the PAPD Dept. (Police) for engaging in a “illegal

Scrap Industry”

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

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

“Edward McCray”, by the assume business J Can Company

Being now further introduced as “Scrap Metal” in connection with the

company “Cars and Pieces” business Located in Beaumont Texas (Office) also

located at 448 DeQueen Blvd. in Port Arthur Texas 77640 under the assume name

of Edward McCray Sr. (Owner)

(45)

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

Arthur Texas city limits by Co- Defendant “Edward McCray”,

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

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

scraping” business of J Can Company that this “many years of “baffling exchange”

mystery of transfer rate of

“Illegal scrap” from Port Arthur Texas City Limits into now “Clean” legit

able sales of “Scrape Metal” has been confusing the (PAPD) Police in the

exchange rate form now “legal scrap” derived in “Beaumont Texas” from J Can

Company in Port Arthur Texas “Namely” to wit:

“Cars and Pieces” business in Beaumont Texas being now a major illegal

scrap metal “money laundering” “Earn Income” system for Co- Defendant

(Edward McCray) and Co-Defendant (Joyce M. Guy) herein derived from this

additional (RICO) “criminal endeavor.

(46)

Pro Se Plaintiff further state, affirm and declare before the “Honorable

Justice” prior before raids by the (PAPD) Police into “illegal scraping” business of J Can Company

Pro Se Plaintiff herein was “fully physically present” in the year of 2007 before the “Breach of Contract” affairs occurred and being quite in disbelief fast

shock when (PAPD) Police snuck in out of nowhere so super fast upon J Can Company (PAPD) Police went directly to some “illegal scraping metal material”

Co- Defendant (Edward McCray) herein had hidden in some bushes @ J Can Company 1807 East 7th Street Port Arthur Texas “took” some Pictures, confiscated said “illegal scraping metal material” and (PAPD) Police disappeared

as fast as they “Snuck in”

(47)


Justice” prior before raids by the (PAPD) Police into “illegal scraping” business of J Can Company

Pro Se Plaintiff herein was once again “fully physically present” in the year

of 2007 before the “Breach of Contract” affairs occurred as Co- Defendant (Edward McCray) herein had hidden “illegal scraping metal material” in the trunk

of his car one scrap material being a old radiator

(48)

The exact moment as Co- Defendant (Edward McCray) feeling safety and attempted to driving away from the location of obtaining “illegal scraping metal

materials” for the business of J Can Company

(PAPD) Police snuck in out of nowhere so super fast upon J Can Company co-owner being Co- Defendant (Edward McCray) herein, pulled his car over made

him open the trunk and took more pictures of said “illegal scraping metal material” in the trunk of his car of the

Co- Defendant (Edward McCray) herein furthermore confiscated said

“illegal scraping metal material” and (PAPD) Police disappeared (Twice) as fast as they “Snuck in” on his car at this particular point and time

“Goofy” so extra slow to figure out they being (PAPD) Police been watching him Co- Defendant (Edward McCray) herein the entire time “high tech style” from quite a distance away, ha ha…Da”

Notwithstanding Co- Defendant (Edward McCray) herein, being under they (PAPD) Police “continual spying eyes” as long as he breathing” for “among other things”

(49)

Engaging in using said J Can Company located at 1807 East 7th Street in Port Arthur Texas as a Front for the distribution of “Crack Cocaine Industry” for

an additional (RICO) earn income.

Co-Defendant “Edward McCray” herein in the past had a “earn income” derived from the sales of “Dangerous Drugs” Jefferson County Cause

No. 97903 and Cause No. 146302

And upon further information and belief Co-Defendant “Edward McCray” herein obtaining Federal Charges derived in the performance of

such as found guilty of five violations of the Mann Act and sentenced for a total of 10 years—some of the sentences being consecutive and some concurrent.

No doubt that Co-Defendant “Edward McCray” herein transported the same

woman to various cities over a period of a year for prostitution.

There were five counts, two of which charged transportation in commerce of

the named woman between designated cities for the purpose of prostitution.

Each was an offense under 18 U.S.C. 2421 which provides a fine of $5,000 or five years in prison or both.

Three of the five counts charged that Co-Defendant “Edward McCray” herein persuaded, induced, enticed, or coerced this same woman 'to go from one

place to another' in interstate commerce for the purpose of prostitution,

Each count charging on offense under 18 U.S.C. 2422 which carries a fine of $5,000 or five years in prison or both.

As Co-Defendant “Edward McCray” herein in the past enjoyed this

continuous prostitution enterprise

Edward McCRAY v. UNITED STATES.

405 U.S. 944 (92 S.Ct. 967, 30 L.Ed.2d 815)

http://www.law.cornell.edu/uscode/text/18/2421

http://www.law.cornell.edu/uscode/text/18/2422

Edward McCRAY v. UNITED STATES.

No. 71-5547.

Decided: February 22, 1972

dissent, DOUGLAS

(50)


Justice” the Co-Defendant “Joyce M. Guy” herein already having a “Live Actual Bullet” lodge presently in her “Skull” as a result of her own domestic violence

acts and actions of the past.

As Pro Se Plaintiff “Louis Charles Hamilton II” herein further state, affirm and declare as appearing before “The Honorable Zack Hawthorn United States

Magistrate Judge”,

Pro Se Plaintiff under gone many “hostile suffrage” dealing with “Bonnie and Clyde” being namely Co-Defendant(s) “Joyce M. Guy and Edward McCray”

herein

Now such a additional furtherance executed (RICO) Fraudulent “Criminal Enterprise” in June 18th of 2009 wrongfully committed to gaining in excess of

“among other things” $76,000 U.S. Dollars Federal Housing Grant. As this also involved the Pro Se Plaintiff “Louis Charles Hamilton II” herein since 2007

And the furtherance’s of such a corrupted (RICO) scheme of things executed

against all of the Jefferson County Court House 58th Judicial District court records

and executed against the “Texas Department of Housing & Community Affairs” for

said executed “Actual Fraud”

Of a Federal Housing Grant obtain and derive thereof during the legal affairs

of a civil suit in common law filed in Jefferson County Texas Cause No. A-180805

Such a corrupted additional (RICO) scheme of things executed by and through Attorney of Record in Texas State Court Cause No. A-180805 being

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

(51)

Good and sufficient material facts, acts and event, legal circumstances, and all subject matter contain herein officially exist and is supported in all of the Pro

Se Plaintiff attached exhibit(s) filed herein for Freezing all of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-Defendant(s) “Joyce M. Guy and

Edward McCray” herein Business records, banking records, personal banking records, property

deeds, and all assets for all of the above listed Defendant(s) collectively in the United States of America.

Which is necessary to protect this Honorable United States District Court

for the Eastern District of Texas, Ability to decide from the preponderances in deciding the weight of factual evidence,

With furtherance allowances in the Honorable United States District Court

for the Eastern District of Texas Ability in fully applying just awards and compensation for “actual damages”

of all equitable relief for the Pro Se Plaintiff herein Within all assets, moneys and properties held directly or indirectly by the

Defendant Antoine L. Freeman J. D. (Attorney at Law) herein and all Co-

Defendant(s) “Joyce M. Guy and Edward McCray” herein for all of the Pro Se Plaintiff “Louis Charles Hamilton II”

Direct “Actual damages”, emotional pain and suffrage as described in the

U.S. Complaint of the Pro Se Plaintiff Cause No. 1:2014-CV-592 (52) Pro Se Plaintiff further state, affirm and declare before the “Honorable

Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) herein after filing a Original Denial on December 18th 2007 and forwarding such to the Pro Se Plaintiff in Cause No. A-180805, from that exact moment in time

Pro Se Plaintiff next official office document, note, correspondence,

mailing, letter, text, email, court document being received from Defendant Antoine L. Freeman J. D. (Attorney at Law) in the capacity of a “Attorney of Law

retain for the Co-Defendant(s) collectively herein is being on the exact date of October 14th 2009

Even there after Pro Se Plaintiff requesting a response from Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar. No 24058299 herein whom already being in full legal possession, custody, and control over discovery documents of

Interrogatories, Request for Admission, and Request for Disclosure in

accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, During this time frame of on or about April 2nd 2008 and April 11th, 2008 (53) Pro Se Plaintiff further state, affirm and declare before the “Honorable

Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) herein “Never” informed the 58th Judicial District Court in cause No. A-180805 in official office document, note, correspondence, mailing, letter, text, email, phone transmitting cell phone or even a official

“Court document” of wishing to no longer be “retain” Attorney of record

throughout the “Time Frame” of December 18th 2007 – November 12th 2009 (54)

Pro Se Plaintiff further state, affirm and declare before the “Honorable Justice” fully committed to Obstruction of Justice”, Fraud of the 58th Judicial

District Court cause No. A-180805 to:

Scuttle, hide, delete, destroy, concealment, defeat, erase, and obliterate all records, thereof concerning Pro Se Plaintiff “Material Facts” surrounding events

and circumstances as a result of Hurricanes “Rita”, “Humberto”, and “Ike” at the locations first and foremost 448Dequeen Blvd. in Port Arthur Texas and the

involvement of the

“Unknown” Keep 100% secret, identity of all Home Owner Insurance Company(s), all Construction Contractor contracts obtain in process thereof fixing

said needed repairs, banking records of Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”

(55)

As they squander completely all funds from events and circumstances as a result of Hurricanes “Rita”, “Humberto”, and “Ike” as said “Court Order” require

the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” to produce such (Records) to the Pro Se Plaintiff herein.

Notwithstanding “VIP” same said court order of the 58th Judicial District Court cause No. A-180805 Pro Se Plaintiff exhibit (B) attached herein

“Require” in full the “actual identity ownership” of said dwelling “Namely”

copies of property deeds that Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein

“Actually” made “Physical Evidence” in a ongoing civil suit since 2007

being both first the “property deeds” for the dwelling located at 448 DeQueen Blvd in Port Arthur Texas Block 172 Lot 1-2 being concealment and in a state of

disappearance from the court records

Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein “Actually” made second being concealment and in a state of

disappearance from the court records “Physically and “entire complete flipping “structural home” for the dwelling located at 448 DeQueen Blvd in Port Arthur

Texas Block 172 Lot 1-2 in 2007

(56)

A signature “Harry Houdini” Defendant “Attorney at Law” herein completely “material evidence disappearance act” before the 58th Judicial District

Court records… Destroying this such “Priceless Evidence” on or about after the dates of June 18th 2009 thereafter Co-Defendant(s) “Joyce M. Guy” and “Edward

McCray”

Then the secret (RICO) Enterprise events and circumstances surrounding in the production of “reappearance act” of a “Brand New” $76,000.00 U.S. Dollars

“Federal Housing Grant” home for the dwelling located at 448 DeQueen Blvd in Port Arthur Texas Block 172 Lot 1-2 in 2007 as records described in Pro Se

Plaintiff attached exhibit (C) filed herein “Jefferson County Texas” search Index

Pro Se Plaintiff declare, affirm and state before the “Honorable Justice” pointing out the facts and circumstances that if Defendant “himself” Antoine L.

Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein

“Actually” complied with all of the Texas rules of Civil Procedure in this

civil suit in common law docket No. A-180805 as an “Attorney in Law” in for the State of Texas is so requires following back in during this time frame of on or about

April 2nd 2008 and April 11th, 2008 as being described in Pro Se Plaintiff attached exhibit (E) 58th Judicial District Court “Ledger Report” for cause No. A-

180805 approximately one (1) year later

On or about “April 2nd 2009 this civil suit would having been so served a full, final and complete ending before “Justice” of the 58th Judicial District Court

of Jefferson County Texas,

Before the Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein having and fraudulently attempts to commit to (RICO) enterprise

in the legal “Transfer of said Property”

Located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2 to “Texas Department of Housing & Community Affairs” as Filed in Jefferson

County Clerk Records # 2009022762, for a $76,000.00 Federal Housing Grant, as being described in Pro Se

Plaintiff attached exhibit (C) herein “Jefferson County Texas Property Search Index”

Before Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein further assistances of their collectively (RICO) scheme of things on or about June 18th 2009 as when in time filed a future “fraudulent financing statement” in Jefferson

County Clerk Records instrument # 2009022763 in the connection thereof

For fraud activities engagement of the “Texas Department of Housing & Community Affairs” for a monetary gain of in excess of said $76,000.00 U.S.

Dollars Federal Housing Grant

After the Co-Defendant(s)“Joyce M. Guy and Edward McCray” herein already squandering all of the Home Owner Insurances funds, FEMA Funds

designated for “actual building repairs” of said Property located at 448 DeQueen Blvd. in Port Arthur Texas (Block) 172, (Lot) 1-2

Being as a result of Hurricanes damages from Hurricanes “Rita”, Humberto,

and “Ike” as described in Pro Se Plaintiff attached exhibit (J) attached herein Pro Se Complaint Plaintiff Louis Charles Hamilton II being a Party thereof docket No.

A-180805

(57)

Pro Se Plaintiff declare, affirm and state before the “Honorable Justice” furthermore a “Mechanics Lien” in April 2nd 2009 and April 11th, 2009 being

well enforced and in place in favor of the Pro Se Plaintiff “Louis Charles Hamilton II” herein by the 58th Judicial District Court of Jefferson County Texas,

As the Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein “legal Choice as described against him was to commit to “Obstruction of Justice”, Fraud of The Court and complexly

Scuttle, hide, delete, destroying, concealment, defeat, erase, and obliterate all records thereof being requested in the “production of a discovery phase” civil suit A-180805 since November 17th 2007

And the Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein signature “Harry Houdini” material evidence

disappearance act of a “Entire Home”

From the “Honorable 58th Judicial District Court of Jefferson County Texas” court records.

(58)

Pro Se Plaintiff declares, affirm, moves, and state furtherance’s before the

“Honorable Justice” furthermore that Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 “own” a out of control rubber

“Affidavit Stamp” in processing, many infamous false statements, lie, half

truths, in the assistances to further all (RICO) “Obstruction of Justice”,

Fraud upon any “Court of Law” within the “United States of America” as so committed to, while Defendant (Attorney at Law) possessing no ethical, or “legal

responsible accountability” for processing Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein “own legal

actions”

As required by “Federal and State Laws” in Defendant (Attorney at Law) Texas Bar No. 24058299 “ omit”, “refrain”, “shun”, “avoid” and actually fully

renounce “himself “ from such among other things engaging in a (RICO) enterprising endeavor and all conduct derive thereof,

Not being in the absolutely condemning position of “Obstruction of Justice before a Honorable Court of Law,

As well “among other thing” not “foolishly” being in the legal professional

fiduciary duty capacity as a “officer of the court” while being in the “illegal” possession, custody and control of committing to full acts and actions of

Fraud upon a “Honorable Court of Law” in connection with all (RICO)

activities and events as being described completely herein,

As well as described in all attached exhibit (ABCDEFGHIJKL1, AND L2) in exhibit, Original Complaint U.S. Docket No. 1:2010-CV-00055

As Pro Se Plaintiff Herein Moves Respectfully in the “Interest” of Justice as

presented in this Original Complaint U.S. Docket No. 1:2014-CV-592

(59)

Pro Se Plaintiff declares, affirm, moves, and state furtherance’s before the

“Honorable Justice” Defendant “himself” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein be further

“Order to Show Cause” why his “Attorney at Law” License for the State of

Texas being in a state of “suspended from practicing” with the “State of Texas”

In light of all damaging evidence attached herein having actual “Outstanding physical weight of “Merit” in favor of the Pro Se Plaintiff Louis Charles Hamilton

II herein before the Honorable Court Justice”

Warranting such a suspended of Defendant (Attorney at Law) license herein is absolutely justifiable and well within the “Interest of Justice” within the “United

States of America” jurisdiction for the above entitled

“Honorable Court Justice” to protect the “public interest of many others

from falling to such faith of among other things (RICO),

“Obstruction of Justice”, processing Fraud upon a Court of Law in and for the State of Texas scheme of things

(60)

With other fraudulent civil activities of Defendant “himself” Antoine L.

Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 as described herein being fully committed by said Defendant (Attorney at Law) for profit no less.

(62)

Pro Se Plaintiff declares, affirm, moves, and state furtherance’s before the “Honorable Justice” Defendant “himself” Antoine L. Freeman J. D. (Attorney at

Law) Texas Bar No. 24058299

Warranting a “Order to show cause” why Pro Se Plaintiff Louis Charles

Hamilton II herein not be entitled to enjoy a “Temporary Restraining Order”, freezing the destruction or alter of all records, and documents set forth herein,

And further “Order to show cause” why Pro Se Plaintiff Louis Charles Hamilton II herein not be entitled to enjoy to secure all of the

DEFENDANT ANTOINE L. FREEMAN J.D. ATTORNEY AT LAW

HEREIN AND CO-DEFENDANT(S) JOYCE M. GUY AND EDWARD McCRAY HEREIN, Collective Assets.

Warranting a further “order to show cause” why such a suspended of Defendant (Attorney at Law) license herein being not enforced by the Honorable Justice”

Until the full “processing adjudication”, “completion”, “negotiations”, and or “Jury Trial” being brought forth on all described complex subject matter jurisdiction

As presented before the “Honorable Justice” by the Pro Se Plaintiff Louis Charles Hamilton II herein.

(63) Freezing all of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein

and all Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein Business records, banking records, personal banking records, property

deeds, court records, phone records, computer records, notes, ledgers, diaries, (IRS) records, Insurance companies(s) records, FEMA records, Hurricanes “Rita”, “Humberto” and “Ike” records thereof,

And all assets for all of the above listed Defendant and Co-Defendant(s)

collectively in the United States of America described as follows: (64)

Freezing enforced against Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 240582999 herein as Follows:

Freezing all records, correspondence, notes, phone records, recording,

communications, and other documents concerning or relating to any

correspondence or communications with Co-Defendant(s) Joyce M. Guy and

Edward McCray from the dates of November 17th 2007 throughout December 1s t

2015.

(65)

Freezing all records, correspondence, notes, communications, and other

documents that concern or relate to any conversations, discussions, requests for

advice, or any matter relating to the above-captioned case.

(66)


documents concerning or relating to any correspondence or communications with

any Defendant, or Defendants or with any person or persons initially named as

Defendants in this case regarding “Hamilton vs. Freeman et al filed February 2nd

2010 U.S. Cause No. 1:2010-CV-00055

(67)

Freezing all records, correspondence, notes, communications or other

documents which are relevant to the allegations of this complaint, and any and all

records, correspondence, notes, communications or other documents which may

lead to such relevant evidence.

(68)

Freezing all desk calendars, appointment books, journals, logs, and diaries

which concern or relate to the Defendant, in the performance of job description,

duties, instructions, assignments, or evaluations of Co- Defendant(s) Joyce M. Guy

and Edward McCray.

(69)


documents concerning or relating to the circumstances under which Defendant

acquired employment from the Co-Defendant(s) Joyce M. Guy and Edward

McCray, including, but not limited to,

Defendant job description, duties, his qualifications to perform those

duties, and freezing any and all evaluations prepared by anyone about how he

performed those duties for the behalf of the Co-Defendant(s) collectively herein.

(70)

Freezing all records showing the Defendant qualifications to perform those

duties as an “Attorney at Law” in and for the State of Texas.

(71)


documents concerning or relating to any private hire authority working for

Defendant behalf “investigating the circumstances” under which Defendant were

retain after acquired employment from the Co-Defendant(s) Joyce M. Guy and

Edward McCray.

(72)

Freezing all records, and all Documents of Defendant “Attorney and Law”,

contracts concerning or relating to Monetary retain “Attorney at Law” Payments

of services Defendant received from Co-Defendant(s) Joyce M. Guy and Edward

McCray.

(73)

Freezing all of Defendant “Attorney and Law” Contracts with clients namely

Co-Defendant(s) Joyce M. Guy and Edward McCray in cause No. A-180805.

(74)

Freezing all documents of Defendant “Attorney and Law” related to files,

documents, letters, motions, certificate of mailing services, correspondence,

notes, communications, phone records, being received in cause No. A-180805

from Pro Se Plaintiff Louis Charles Hamilton II to the Defendant for the behalf of

the Co-Defendant(s) Joyce M. Guy and Edward McCray.

(75)

Freezing all of Defendant “Attorney and Law” Contracts for hire of services

with clients namely Co-Defendant(s) Joyce M. Guy and Edward McCray in U.S.

Cause No. 1:2010-CV-00055

(76)

Freezing all Documents of Defendant “Attorney and Law” entire cause No.

for each and every case load for every client Defendant office has legally

represent in a civil court of law in and for the State of Texas from the exact dates

of December 18th 2007 throughout December 18th 2014

(77)

Freezing all Documents Defendant “Attorney and Law” herein related to

files, documents, letters, correspondence, notes, communications, phone records,

Defendant contacted another Attorney at Law office to take over in cause No. A-

180805 or

Defendant staff made such requested and or made such inquiry for the

behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray.

(78)



Defendant contacted the 58th Judicial District Court Honorable Judge Bob

Wortham,

And or his staff requesting to be removed as acting

“Attorney of Record” from the cause No. A-180805 on or before the dates

of November 13th 2009 or having another Attorney at Law office to take over in

cause No. A-180805 as showing Defendant (Attorney at Law)

Herein made such requested and or made such inquiry for the behalf of the

Co-Defendant(s) Joyce M. Guy and Edward McCray on or before the dates of

November 13th 2009.

(79)



employment for hire Attorney at Law contracts Defendant acquired employment

from the Co-Defendant(s) Joyce M. Guy and Edward McCray other then in cause

No. A-180805 and U.S. Cause No. 1:2010-CV-00055

(80)

Freezing all Documents Defendant “Attorney and Law” herein relating to

the exact Identity of each, and all staff member of the Defendant Law Office from

the dates of November 17th 2007 throughout 2015 with each staff member day

time telephone number and correct mailing address.

(81)


the exact monetary payment and contract thereof the Defendant received from

Co-Defendant(s) in cause No. A-180805 to file a “General Denial” to Pro Se

Plaintiff Complaint.

(82)


the exact monetary payment and “Attorney/Client contract thereof the

Defendant received from Co-Defendant(s) in cause No. A-180805

To appear at a hearing on the dates of August 28th 2009 to respond to Pro

Se Plaintiff Complaint and all circumstance for the legal behalf of the Co-

Defendant(s) Joyce M. Guy and Edward McCray herein on hearing dates of August

28th 2009.

(83)


the exact monetary payment and Attorney/client contract thereof the Defendant

received from Co-Defendant(s) in cause No. A-180805 to appear at a hearing on

the dates of September 11th 2009

To respond to Pro Se Plaintiff Complaint and all circumstance for the legal

behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray herein on

hearing dates of September 11th 2009.

(84)


any of Pro Se Plaintiff “Discovery Request for Interrogatories, Request for

Admission, and Request for Disclosure in accordance with the Texas Rules of

Civil Procedures 194.2, 197, and 198, in Defendant possession, custody and legal

control from the dates of April 2nd 2008 and April 11, 2008, throughout the dates

of October 14th 2009 which Defendant supply some sort of respond during this

time frame of (1) year and (5) months and counting days Defendant not

responding.

(85)


the exact monetary payment and Attorney/client contract thereof the Defendant

represented the Co-Defendant(s) Joyce M. Guy and Edward McCray herein

McCray herein legal behalf in any criminal/civil cases other then cause No. A-

180805 and U.S. Cause No. 1:2010-CV-00055

(86)


the exact ledger of cause No. A-180805 resulting from business transactions and

principal book keeping and computer filing system for all documents, records,

contracts, and banking records.

(87)


the exact “certificate of mailing services” Defendant received (Legal Court

Documents) in cause No. A-180805 from Pro Se Plaintiff herein for the behalf of

the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

(88)


the business transactions, dealings, and or relationship between the Defendant

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

herein other than a Attorney/client relationship between the dates of 1980

throughout 2015.

(89)


the business transactions, dealings, (IRS) records showing the Annually Income

received for the Defendant Law Office herein from the dates of November 17th

2007 throughout December 2015.

(90)


the Defendant having another “Attorney/Client Relationship other then in cause

No. A-180805 showing Defendant did not actually respond to discovery request

for Interrogatories, Request for Admission,

And Request for Disclosure in accordance with the Texas Rules of Civil

Procedures 194.2, 197, and 198, in Defendant possession, custody and legal

control for other Clients retain for Defendant “Legal Services” other than the

Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

(91)

Freezing all records showing the Defendant staff qualifications to perform

those duties acting on behalf of Defendant “Attorney at Law” herein Law Offices

in and for the State of Texas from the dates of November 17th 2007 - 2015.

(92)

Freezing all of Defendant “Attorney and Law” entire cause No. Ledger

showing for each and every case load for the Defendant “Law office” he has

legally represent in a civil court in a suit in common law in and for the State of

Texas from the exact dates of December 18th 2007 throughout December 18th

2014 showing each cause No.

“The exact Courthouse in Texas whereby Defendant represented, ledger

showing of each documents and motions received and filed response thereof per

each cause No., with Production of Documents on all return Defendant certificate

of mailing services to “opposition counsel or Pro Se (Person or Persons)”.

(93)

Freezing all Documents, Birth records, Church records, Hospital (DNA)

records all of Defendant “Attorney and Law” herein having descended from a

common ancestor or constituting a people, clan, tribe, or family, relative or

kinsman with the Co-Defendant(s) Joyce M. Guy and Edward McCray herein.

Freezing “Assets” enforced against Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 240582999 herein as Follows:

(94)

Freezing all of Defendant “Attorney and Law” herein entire assets in Law office located at 3629 Professional Dr. Port Arthur Texas 77642

(95) Freezing all of Defendant “Attorney and Law” herein entire assets in Law

office located at 3723 Gulfway Dr. Port Arthur Texas 77642 (96) Freezing all of Defendant “Attorney and Law” herein entire assets in “Deed”

Professional Development Block 2 Lot 3 “SBD Keith Marroquin” as being described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search Index #2011035793

(97) Freezing all of Defendant “Attorney and Law” herein entire assets in “Gulf

Employee Credit Union as being described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search Index #2002005559

(98) Freezing all of Defendant “Attorney and Law” herein entire assets in “Port

Arthur Teachers Federal Credit Union as being described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search Index #2004004187

Freezing all of Defendant “Attorney and Law” herein entire assets as being described in Pro Se Plaintiff attached exhibit (M) “Jefferson County Texas” search Index herein all such person and person(s)

As identified having (any) interests in all entities owned, in whole or in

part, or controlled by, related to, or associated or affiliated with Defendant Antoine L. Freeman J. D. (Attorney at Law) herein “Namely” “Freeman Antoine, Freeman Antoine L, Freeman Antoine L Sr., Freeman Antoinette C & EX, Black James M and Moor Leslie M Jr.

(99) Freezing all Assets” of Defendant (Attorney at Law) herein there after

providing a “verified written described accounting” and “personal financial statement” of Defendant Antoine L. Freeman J. D. (Attorney at Law) herein as·set

plural noun: assets:

“Deeds”, Banking accounts presently held, Property, Stock, Bonds, (IRA), Commercial Real estate, Companies, Investments, estates, livestock, cattle, horses, Rental Property(s), landholding, chattel,

Valuable Art collection, investment banking, (money) to use, by purchase

or expenditure, in something offering potential profitable returns, as interest, income, gold investment.

(100)

Freezing enforced against Co-Defendant “Joyce M. Guy and Edward McCray” herein as Follows:

Freezing all records in G and G Service Company P.O. Box 515, 416

DeQueen Blvd. in Port Arthur“ Business records”, banking records, personal banking records, staff records, (IRS), computer records, insurance records, ledgers, tax records, from the dates of 1997-2015

(101) Freezing all records in J Can Company 1807 East 7th Street Port Arthur

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

Business records”, banking records, personal banking records, staff records, (IRS), tax records, computer records, insurance records from the dates of 2008-2015

(102) Freezing all records in E and J Collectibles located at 448 DeQueen Blvd. in

Port Arthur Texas 77640 *note this company not listed on Pro Se Plaintiff attached exhibit (C)

herein records contain at “Jefferson County Texas Search Index” However it “do exist” on the Internet as being two companies and is in

“physical operation” as Public Advertisement claims open to the public in Jefferson County Texas contact Co-Defendant “Joyce M. Guy” (409) 330-0485.

Business records”, banking records, personal banking records, staff records,

(IRS), tax records, computer records, insurance records, from the dates of 1997-2015

(103)

Freezing all records in “Paragon Business Inc.” Lot 10 Block 18 (Jefferson) Chaison ADD


(104)

Freezing all records in “Cars and Pieces” office located in Beaumont Texas and all records at office located at 448 DeQueen Blvd. in Port Arthur Texas 77640


(105)

Freezing all records in DSW Homes. (106) Freezing all records in SWMJ Construction Inc. (107) Freezing all records in “Texas Department of Housing and Community Affairs” (108) Freezing all records in North America Popular Banco Texas (109) Freezing all records during “Hurricane “Rita”, “Ike” and “Humberto” related Construction storm damages to the property located at 448 DeQueen Blvd in Port Arthur Texas Business records”, banking records, personal banking records, Home owner Insurance Records, FEMA records, Contractor Construction records, and recovery repair records. (110)

Freezing all records during “Hurricane “Rita”, “Ike” and “Humberto” related Construction storm damages to the property located at 5050 east 7th street in Port Arthur Texas

Business records”, banking records, personal banking records, Home Owner

Insurance Records, FEMA records, Contractor Construction records, recovery repair records. (111)

Freezing all records during “Hurricane “Rita”, “Ike” and “Humberto” related Construction storm damages to the property located at SBD “Lakeview”, Block 4 Lot 10 Jefferson County Texas

Business records”, banking records, personal banking records, Home Owner Insurance Records, FEMA records Contractor Construction records, recovery repair records. (112)

Freezing “Assets” enforced against Defendant Co-Defendant(s) Joyce M. Guy and Edward McCray herein as Follows:

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray

“collectively” herein entire assets in G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur“77640

(113) Freezing all of Co- Defendant Joyce M. Guy and Edward McCray

“collectively” herein entire assets in J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640 “

(114 Freezing all of Co- Defendant Joyce M. Guy and Edward McCray

“collectively” herein entire assets in E and J Collectibles located at 448 DeQueen Blvd. in Port Arthur Texas 77640


“collectively” herein entire assets in “Paragon Business Inc.” Lot 10 Block 18 (Jefferson) Chaison ADD

(116)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein entire assets in “Cars and Pieces”

Office located in Beaumont Texas and office located at 448 DeQueen Blvd.

in Port Arthur Texas 77640


“collectively” herein entire assets in the property located at 5050 east 7th street in Port Arthur Texas


“collectively” herein entire assets in the property located at SBD “Lakeview”, Block 4 Lot 10 Jefferson County Texas


“collectively” herein entire assets in the property located at 1807 east 7th street Port Arthur Jefferson County Texas


“collectively” herein entire assets in the property located SBD Port Arthur City Block 210, Lot 8 Jefferson County Texas


“collectively” herein entire assets in the property located at SBD Port Arthur City Block 94, Lot 11 Jefferson County Texas


“collectively” herein entire assets in the property located at 416 DeQueen Blvd. Port Arthur Jefferson County Texas


“collectively” herein entire assets in the property located at 448 DeQueen Blvd. Block 172 Lot 1-2 in Port Arthur Jefferson County Texas


“collectively” herein entire assets in the property located at Rev Ransom Howard Street in Port Arthur Jefferson County Texas Property ID #89824 (Commercial Vacant Lot)

(125)

Freezing all of Co- Defendant Joyce M. Guy and Edward McCray

“collectively” herein entire assets as being described in Pro Se Plaintiff attached exhibit (C) “Jefferson County Texas” search Index herein all such person and person(s) to include but not limited to

As identified having (any) interests in all entities owned, in whole or in

part, or controlled by, related to, or associated or affiliated with Co- Defendant Joyce M. Guy and Edward McCray “collectively” herein

“Namely” “Willie Jones, Dorothy Cooley, Norma Guy, U Guy Sr., Joyce Johnson Guy, Sarah D. West, Gladys Carpenter, Janet L. Hart, Edward E. McCray, Edward McCray, Edward Eugene McCray Sr., Horse Grant, Allen Guy, Joyce Johnson Guy.

(126)

Freezing all Assets” of Co-Defendant “Joyce M. Guy and Edward McCray”

“collectively” herein there after providing a “verified written described accounting” and “personal financial statement” of Co-Defendant “Joyce M. Guy and Edward McCray”, “collectively” ,herein as·set plural noun: assets: “Deeds”, Banking accounts presently held, Property, Stock, Bonds, (IRA),

Commercial Real estate, Companies, Investments, estates, livestock, cattle, horses, Rental Property(s), landholding, chattel,

Valuable Art collection, investment banking, (money) to use, by purchase

or expenditure, in something offering potential profitable returns, as interest,

income, gold investment.

(127) Conclusion


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

24058299 Was fully “retain” of Legal “Attorney at Law” services, committed, engaged,

skilled instrumental, lead legal advisor, and primary conductor from the exact time frame of December 17th 2007 citation was issued by the “Clerk of Court”, to Co-Defendant(s) Joyce M. Guy and Edward McCray “collectively” herein as described in Pro Se Plaintiff attached exhibit (E) herein legally showing factual evidence

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

24058299 answered and replying on December 28, 2007 on behalf of Co-Defendant Joyce M. Guy and Edward McCray “collectively” herein and notwithstanding forward such a reply in fact in the United States Mail

to the Pro Se Plaintiff “Louis Charles Hamilton II correct mailing address

which at that point in time Pro Se Plaintiff was under the impression the Co-Defendant Joyce M. Guy and Edward McCray “collectively” herein under proper “legal representation” as prescribed with the “Texas Rule of Civil Procedure”


Justice” However from that exact time frame on the exact day of March 14th 2008 as being described in Pro Se Plaintiff exhibit (E) “Jefferson County Texas” 58th Judicial District Court “Case Ledger” A-180805

And precisely there after Defendant (Attorney at Law) enter into the

criminal acts of “among other things” completely committed to with full legal intent “Obstruction of Justice” & “Fraud upon the 58th Judicial District Court of Jefferson County Texas” and all court records, civil discovery derive thereof to actually execute actual

(RICO) “Obstruction of Justice”, Fraud upon a Court of Law”, scheming

among other things” being in full conspire concert, collusion with Co-Defendant(s) Joyce M. Guy and Edward McCray “collectively” herein

To forcibly unjustly fraudulently making the Pro Se Plaintiff herein civil suit

in common law “simply stall out, flat line and disappear”, and all of the acquired damaging (RICO) enterprise “Discovery evidence, proper court records derive thereof,

To include but not limited to the absolutely amazing disappearances of “physical evidence” Namely an entire dwelling, home, structural habitation, residence, abode,

All “Hostile Representation” of the Defendant (Attorney at Law) herein

being in skill design to “legally denying” in all factual “events and circumstances” the Pro Se Plaintiff Louis Charles Hamilton II herein “proper due process of Law, in and for the State of Texas”

As described in Pro Se Plaintiff attached exhibit (E) herein “The Jefferson

County Texas 58th Judicial District Court “Case Ledger” A-180805 (129)

On March 14th 2008 as being described in Pro Se Plaintiff exhibit (E) Pro Se Plaintiff filed “All Discovery request with Defendant Antoine L. Freeman J. D.

(Attorney at Law) Texas Bar No. 24058299 for the following

Pro Se Plaintiff Discovery request for Interrogatories, Request of Admission, and Request for Disclosure in accordance with the Texas Rules of Civil Procedures 194.2, 197, and 198, to Cause No. A-180805 in a civil suit in the 58th Judicial District Court of Jefferson County Texas

(130)

Defendant Antoine L. Freeman J. D. (Attorney at Law) herein made official

court documented “legal claims” that he had no knowledge of Pro Se Plaintiff “discovery request” until on or about April 2nd 2008 and on or about April 11, 2008

As Defendant (Attorney at Law) herein so did state before an “open court” hearing with his attached “Affidavit” in support not to have proper Texas Rule 193.1 sanction “levy” against him as showing in Pro Se Plaintiff attached exhibit (G) response for sanctions and attached exhibit (H) herein

Affidavit of Co-Defendant Joyce M. Guy” collaborating the same April 2nd

2008, and April 11, 2008 date of having knowledgeable legal custody, control and possession of said “discovery request as being described in paragraph (130) above

(131)

Defendant Antoine L. Freeman J. D. (Attorney at Law) herein not only did

he received from the Pro Se Plaintiff On August 12th 2009 as described in Pro Se Plaintiff attached exhibit (E) herein “The Jefferson County Texas 58 th Judicial District Court “Case Ledger” A-180805

A motion for Production of documents for primary copies of the Co-

Defendant(s) “Joyce M. Guy” and Edward McCray custody, possession, and control over “Property” located @ 448 DeQueen Blvd. in Port Arthur Texas

Actual land deeds, and Production of documents all related evidence derive

thereof for Hurricane “Rita”, Humberto, Ike storm damages to said dwelling requiring the Services of The Pro Se Plaintiff in a $10.800.00 U.S. dollar contract.

(132) Defendant Antoine L. Freeman J. D. (Attorney at Law) herein in addition to

what is being described in paragraph (131) above in fact received from the Pro Se Plaintiff two (Motion to show Cause) Injunction, application for (Temp Restraining Order) and (TRO).

(133)

“Yet” Defendant Antoine L. Freeman J. D. (Attorney at Law) herein

furtherance’s (RICO) “Obstruction of Justice”, “Fraud upon the Court the 58th

Judicial District Court of Jefferson County Texas being described herein was to fraudulently assistances in the “illegal Transfer” of “Property” located @ 448 DeQueen Blvd. in Port Arthur Texas to the “Texas Department of Housing &

Community affairs for a $76,000.00 U.S Federal Housing Grant

Keeping said property well legally in a state of “concealment limbo” in a ongoing civil suit in common law to be “free”, and 100% clear of any chances of

the “Pro Se Plaintiff herein filing a legal binding “Mechanics Lien” being enforced by the 58th Judicial District Court as being sought for on august 12th 2008 in Pro Se

Plaintiff “motion for Production of documents of the property deeds.

(134)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) herein directly

assistance in (RICO) “Obstruction of Justice” to further provide a scheme of things

in covering up the monetary fraud scheme of things involving Hurricanes “Rita, Humberto, and Ike of the Co-Defendant(s) against the Pro Se Plaintiff complaint in

civil cause No. A-180805

The Defendant Antoine L. Freeman J. D. (Attorney at Law) herein directly

assistance in (RICO) scheme of things of his very own doing to further provide a

scheme of things in “covering up” the actual acquired a $76,000.00 U.S Federal Housing Grant for Defendant (Attorney at Law) additional attachment to (all)

monetary enterprise Fraudulently activities behalf of Co-Defendant(s) “Joyce M.

Guy” and “Edward McCray” herein collectively continuously (RICO) “pillaging and plundering.

(135)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable Justice” The Defendant Antoine L. Freeman J. D. (Attorney at Law) herein on

August 14th 2009 received directly from the 58th Judicial District Court of Jefferson County Texas two notice “CITATION” in this ‘civil suit’ No. A-180805, on behalf

of the Co-Defendant(s) Collectively

Regarding “among other things” the Pro Se Plaintiff required to be heard before the “Honorable Court” two (Motion to show Cause) Injunction, application

for (Temp Restraining Order) and (TRO) and The Defendant Antoine L. Freeman

J. D. (Attorney at Law) Texas Bar No. 24058299 Made himself no escape clause, no legal honest effort to discharge himself

from any further representation of the Co-Defendant(s) “Joyce M. Guy” and Edward McCray herein and file a required Texas Rules of Civil Procedure”

“Motion for withdrawal” as Defendant (Attorney at Law) herein making

additional (Lie) and false claims his “Only Duties” was to file a general denial” in December 18th 2007

(135)

As such (Lie) and false claims of Defendant (Attorney at Law) showing in

Pro Se Plaintiff attached exhibit (G) Response to Pro Se Plaintiff Motion for

Sanctions against Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas

Bar No. 24058299

(136)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable Justice” The Defendant Antoine L. Freeman J. D. (Attorney at Law) herein in

additional to acts of “Obstruction of Justice” of the 58th Judicial District Court of

Jefferson County Texas in concealment of all of the

Pro Se Plaintiff discovery request Defendant “he” so having in his legal

possession, custody and control, from the exact date of March 14th 2007 as

described in Pro Se Plaintiff attached exhibit (E) herein “The Jefferson County Texas 58th Judicial District Court “Case Ledger” A-180805

Defendant Antoine L. Freeman J. D. (Attorney at Law) herein knowingly

furtherance the acquired continuously (RICO) “pillaging and plundering “Texas

Department of Housing & Community affairs for a $76,000.00 U.S Federal

Housing Grant. Which this scheme was well “Hatch out plotted”, “maneuver”, “calculated out” and “game plan” in

advance of June 18th 2009 being the actual day the (RICO) enterprise legal transfer of said property “events and circumstances” physically took place.


Justice” The Defendant Antoine L. Freeman J. D. (Attorney at Law) herein

“Affidavit” dated 11th day of September 2009 is a fraudulent instrument attached

herein to Pro Se Plaintiff exhibit (G)

Providing standing 100% proof before the “Honorable Justice” in

comparison to Pro Se Plaintiff exhibit (E) herein “The Jefferson County Texas 58th Judicial District Court “Case Ledger” A-

180805 stating by Defendant Antoine L. Freeman J. D. (Attorney at Law) herein is in possession of said discovery request on or about April 2nd 2008 and on or about April 11, 2008 in comparison to the truthful factual date of

March 14th 2008 as described in Pro Se Plaintiff attached exhibit (E) herein

“The Jefferson County Texas 58th Judicial District Court “Case Ledger” A-180805. Supporting Pro Se Plaintiff Louis Charles Hamilton II herein 100%

sound facts of Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar

No. 24058299 (RICO) Intent with “Obstruction of Justice” and Fraud upon the 58th Judicial District Court of

Jefferson County Texas in this particular Defendant (Attorney at Law)

Capabilities in processing numerous “fraudulent instruments” and legal court documents being in the acquired capacity as a “Skilled Attorney of Law” in

and for the State of Texas in a civil suit in common law.

(138)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable Justice” The Defendant Antoine L. Freeman J. D. (Attorney at Law) herein continue on with forward progress in a “Rouge” Attorney at Law fraudulent

“scheme of things” while Co-Defendants

“Joyce M. Guy and Edward McCray herein prosperity (RICO)” enterprise of monetary scheme of things” continue actual $76,000.00 U.S. Dollars dividends

increase

with the Pro Se Plaintiff being a unwilling party to “actual theft of his “personal property” Namely Pro Se Plaintiff herein “Construction Company Entire

Tools”, Now being a party of the Co-Defendants “Joyce M. Guy and Edward

McCray collection of (RICO) enterprise monetary increase “scheme of things”

since 1997

The Co-Defendants “Joyce M. Guy and Edward McCray (RICO) mutable business “past, present, to include but not limited to all current criminal fraudulent

doings in a ongoing “civil suit” no less to

Acquiring actual in excess of $76,000.00 U.S. Dollars as being described in Pro Se Plaintiff attached exhibit (C) herein “Jefferson County Texas Search Index”

As Pro Se Plaintiff furtherance support this proof before the “Honorable

Justice” with Attached exhibit (N) herein namely * Discovery Request Document of Pro Se Plaintiff request respond to Interrogatories Question at:

No. 10

Where is the funding coming from the new home?

Answer: Federal Grant

No. 11

What are the term and conditions of any contract in regards to the new

home? Answer: Federal Government built home free of charge Co-Defendant must

remain in home for at least 3 years. No. 12

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

Answer: $76,000

No. 13 How is the City of Port Arthur Involved?

Answer: Not involved

No. 14 How is the state of Texas Involved?


No. 15 How is the federal government involved?


No. 16How much money did the Co-defendants actually paid for in the new

home construction

Answer: No money paid by Co-defendants (Joyce M. Guy & Edward McCray)

(139)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable Justice” Pro Se Plaintiff attached exhibit (N) herein Defendant(s) and Co-Defendant(s) collective respond to the

“First Set of Interrogatories” of Pro Se Plaintiff Louis Charles Hamilton II

herein provides a “sound (RICO) proof” of a past present and future fraudulent

intent “scheme of things” before the “Honorable Justice” for a monetary value.

To include but not limited to Defendant Antoine L. Freeman J. D. (Attorney

at Law) Texas Bar No. 24058299 (RICO) Intent at further fraudulent instrument namely said exhibit (N) herein Namely * Discovery Request Document of Pro Se

Plaintiff requesting respond to Interrogatories Question(s).

(140)

Pro Se Plaintiff Quite Elementary “Logically”, affirming, and state further before the “Honorable Justice” sound proof in Pro Se Plaintiff attach exhibit (C) herein “Jefferson County Texas” search index physically identifying among other things “Transfer of dwelling

(141) (Block 172 Lot 1-2) that is a party of the State Court civil action (A-180805)

transfer to the “Texas Department of Housing & Community affairs” on June 18th 2009 Instrument # 2009022762

(142) With Instrument # 2009022763 being a “Fraudulent” financing statement

also filed June 18th 2009 with “Texas Department of Housing & Community affairs”

(143)

With Instrument # 2013023794 being a (release) being with “Texas Department of Housing & Community affairs” on July 22nd 2013

(144) With Instrument # 2013023857 being a (termination) being with “Texas

Department of Housing & Community affairs” on July 22nd 2013 (145)

Defendant and Co Defendant(s) collective (RICO) accomplishment “scheme

of things” being legally in the future of the civil suit of (2007) fully secure in the free and clear property “Deed” to the Co-Defendant(s) Joyce M. Guy and Edward

McCray herein from the “Texas Department of Housing & Community affairs” being about a future

(RICO) executed “scheme of things” on April 22nd 2014 as described in Instrument # 2014012455

(146) As this civil suit (A-180805) for a “Breach of Construction Contract”, “theft

of personal Property” namely said entire “Construction Company tools”. Commenced in November 26th 2007 as being “legally” described before the

“Honorable Justice” in Pro Se Plaintiff attached exhibit (E) herein “The Jefferson County Texas 58th Judicial District Court “Case Ledger” A-180805

(147) Defendant and Co-Defendant(s) collectively (RICO) Providing false and

misleading “statements, events and factual circumstances surround the actual proper disposition of $76,000 “U.S. Government Grant” and the conflicting real interest with the “State of Texas”

(148) Just whom being (RICO) pilferage out of the $76,000.000 U.S. Dollars

Housing Grant..? By the Defendant (Attorney at Law) and Co-Defendant(s) collectively herein

(149) Is it the “States of Texas vs. “United States of America” $76,000.000 U.S.

Dollars Housing Grant ..? “?Your “Honorable Justice”..? (150)

As Pro Se Plaintiff Louis Charles Hamilton II smartly presenting attached

exhibit (C) being “Jefferson County Texas search Index Describing among other things a $76,000.000 U.S. Dollars Housing Grant

and its involving of the dwelling (448 DeQueen Jefferson County Texas) with the financial involvement with the “States of Texas” quite (clearly)

(151) But quite scary conflicting concealment bogus facts is (clearly) contained in

Pro Se Plaintiff attached exhibit (N) herein Namely * Discovery Request Document of Pro Se Plaintiff request respond to

Interrogatories Question at number: 10, 11, 12, 13, 14 15, and 16 being

quite contradicting conflicting fraudulent response describing an Interrogatories Question at:

No. 10

Where is the funding coming from the new home?


No. 11

What are the term and conditions of any contract in regards to the new home?

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

No. 12 What is the entire cost of the construction for the new home?

Answer: $76,000

No. 13 How is the City of Port Arthur Involved?


No. 14 How is the state of Texas Involved?


No. 15

How is the federal government involved?


(152)

In comparison to Pro Se Plaintiff attached exhibit (C) describing in “confusing details” now that can it be the $76,000 U.S. Dollars Home Grant

funding belongs too? (153)

Meanwhile factually (Block 172 Lot 1-2) the dwelling that is a party of the State Court civil action (A-180805) since November 26th 2007 was “indeed legally transfer” to the “Texas Department of Housing & Community affairs” on June 18th 2009 Instrument # 2009022762 standing as sound proof of that

(154) With Instrument # 2009022763 being a “Fraudulent” financing statement

also filed June 18th 2009 with “Texas Department of Housing & Community affairs” standing as sound proof of that

(155)

With Instrument # 2013023794 being a (release) being with “Texas Department of Housing & Community affairs” on July 22nd 2013 standing as sound proof of that

(156)

With Instrument # 2013023857 being a (termination) being with “Texas

Department of Housing & Community affairs” on July 22nd 2013 standing as sound proof of that and the 58th Judicial District Civil Court of Jefferson County Texas

ongoing affairs surround the dwelling located at (Block 172 Lot 1-2) 448 DeQueen Blvd. in Port Arthur Texas being a Party to a past, present and future (RICO) enterprise.

(157)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable Justice” The Defendant Antoine L. Freeman J. D. (Attorney at Law) herein at this

point done “Cut His Very on Crooked Dump Truck Attorney at Law Break Lines”

And continue on with further “forward (RICO) progress in a complete cover up “Rouge” Attorney at Law fraudulent “scheme of things” as being described

herein above

To include but not limited to Defendant Antoine L. Freeman J. D. (Attorney

at Law) herein with Co-Defendants “Joyce M Guy” and “Edward McCray” numerous (RICO) enterprise as being described herein

Defendant (Attorney at Law) was fully “functional and knowledgeable”, execution in his trained skilled capacities as a “retain for hire” State of Texas

“Attorney at Law” committing to his (RICO) scheme of thing throughout the future

Hearing September 11th 2009 AM hour as described in Pro Se Plaintiff attached exhibit (D) 58th Judicial District Court “Docket Report”

Appearance before the Honorable 58th Judicial District Court of Jefferson

County Texas after already securing for the Co-Defendant(s) legal behalf in a civil suit in common law (A-180805);

a. Complete Physical Destruction of material evidence in a civil suit in

common law “Namely” the old dwelling located at 448 DeQueen Blvd.

in Port Arthur Texas (Block 172 Lot 1-2) b. $76,000.000 U.S. Dollars Housing for the legal interest of the Co-

Defendant(s) “Joyce M. Guy” and “Edward McCray” herein. c. A $3800.00 + U.S. Dollars collection in construction tools for the Co-

Defendant(s) and lost of Pro Se Plaintiff herein “Professional Contractor earning capacity since date of injury November 17th 2007 well into 2015

d. Absolutely 100% containment & concealment of the “property deeds” for the old dwelling located at 448 DeQueen Blvd. in Port Arthur Texas

(Block 172 Lot 1-2) from the 58th Judicial District Court of Jefferson

County Texas from August 12th 2009 well into 2015 e. A gain of a $10,800.00 Construction Contract involving the Pro Se

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

f. Absolutely providing false Instrument namely “Affidavits, and Interrogatories. Filed as exhibit (s) attached herein to furtherance (RICO)

g. Complete “Obstruction of Justice” and Fraud of The 58th Judicial District Court of Jefferson County Texas, all of its records and file thereof by this

retain “Attorney at Law” skill additional package (RICO) retain dealings in cover up all of the Co-Defendant(s) collective numerous fraudulent business enterprises, and past fraudulent (RICO) activities enterprises

involving Hurricanes “Rita”, Humberto and “Ike’ not only to the old

dwelling located at 448 DeQueen Blvd. in Port Arthur Texas (Block 172 Lot 1-2) but also every property within Co-Defendant(s) possession, custody and legal “Power of Attorney” control as described herein.

(158)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable Justice” The Defendant Antoine L. Freeman J. D. (Attorney at Law)

herein on November 13th 2009 filed a

“Motion to withdrawal as counsel for the Co-Defendant(s) “Joyce M. Guy

and Edward McCray” collectively herein as he (Attorney at Law) herein “undertook” this Civil Action” exactly

December 18th 2007 as being described in Pro Se Plaintiff attached exhibit

(E) herein “The Jefferson County Texas 58th Judicial District Court “Case Ledger” A-180805

When The Defendant Antoine L. Freeman J. D. (Attorney at Law) herein

being (Rouge) retain “counsel of law” to commit to all complex (RICO) scheme of

things well into 2015

As all described (RICO) “acts, events and circumstances” having an actual complete physical package of a long lasting “obstruction of justice” and fraud upon

the court effect within the

State of Texas “civil suit” cause No. A-180805 against the civil rights,

peace and dignity of the Pro Se Plaintiff herein.

(159)

Pro Se Plaintiff declares, affirm, and state further before the “Honorable Justice” Defendant (Attorney at law) 100% concealment, containment, obstruction, destruction of all material “facts and circumstances” as described herein

Did indeed having a direct “legal effect” against the Pro Se Plaintiff proper pursuit of Justice” against the “Texas Rules of Civil Procedures” as Pro Se Plaintiff

attachment exhibit (E) herein “The Jefferson County Texas 58th Judicial District Court “Case Ledger” A-

180805 showing the “Honorable Justice” on November 17th 2014 Pro Se Plaintiff finally filing a motion for a

“Mechanics Lien” as being described in Pro Se Plaintiff attached exhibit (E)

herein “The Jefferson County Texas 58th Judicial District Court “Case Ledger” A-180805

(160)

Notwithstanding Pro Se Plaintiff having made such an actual “legal attempt” to secure the old dwelling located at 448 DeQueen Blvd. in Port Arthur

Texas (Block 172 Lot 1-2) and have all knowledge thereof the property deeds “clearly” back on the time frame of

March 14th 2008 – March 14th 2009 as Defendant Antoine L. Freeman J. D.

(Attorney at Law) Texas Bar No. 24058299 herein

Absolutely in his 100% (Rouge) hostile (RICO) retain “Attorney at Law” skilled in “foolishly refusal” to even simply “reply” or “respond” or make motion

for “withdrawal”, or disengage as acting

“Attorney of Record” in this time frame of Co-Defendant(s) execution of all past, present and future (RICO) enterprise acts, actions and events

(161)

While Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein providing ”retain for hire” 100% “Obstruction of Justice” and 100% “retain

for hire”

Fraud of the 58th Judicial District Court of Jefferson County Texas, as

“Attorney at Law” (RICO) assistances herein being in favor thereof, and beneficial civil disorder for the Co-Defendant “Joyce M. Guy and Edward

McCray” herein behalf to not only” aid and abetting” to defeat the Civil Complaint of the Pro Se Plaintiff in November 26th of 2007 (A-180805)

(162)

But to include but not limited to in this complex (RICO) enterprising

“scheme of things” also gain a “New”(RICO) enterprise $76,000.00 U.S. Dollars

gain of a “New Home” located at the “old dwelling” located at 448 DeQueen Blvd.

in Port Arthur Texas (Block 172 Lot 1-2) In this continuances “civil disorder” ongoing into 2015 (RICO) enterprise of

fraudulent collusion, conspiring, concert, outlandish crooked mutable task of

underhanded corrupted “scheming of things” between the Defendant and Co-Defendant(s) collectively ..!

(163)


Justice” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

herein having the direct “skilled in among other things “Fraud Litigation”

“Attorney at Law” abilities to with intent “continue to commit” to

Furtherance’s skilled (RICO) “acts and actions” in providing 100% further

“obstruction of justice, fraud upon a court of law, actual direct acts and actions in

destroying, concealment, alter, hide, screen, obscure, mask, disguise, demolish,

liquidate, erase, and eliminating all “material evidences”

Supporting all subject matter as described by the Pro Se Plaintiff Louis

Charles Hamilton II herein

Being “Material Evidences” contain by both Defendant and Co-Defendant(s)

collectively in

All “Attorney at Law” book keeping records, court documents, banking

records, personal banking records, computer records, Insurance records, Business

records, construction estimates, FEMA records, Property lien records, property

deeds records, property records, and all factual material records in relationship to

the exact time frame said home damages caused by

(164)

Hurricanes “Rita”, “Humberto” and “Ike” to the property located at 448

DeQueen Blvd. in Port Arthur, Texas in this ongoing (RICO) enterprise “cover up

scheme of things” commenced in the relationship between the Defendant

(Attorney at Law) and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein

if the “Honorable Justice”

Dose not issuances a “Direct Court Order” in Favor of the Pro Se Plaintiff

herein requiring “Chief” Defendant Antoine L. Freeman J. D. (Attorney at Law)

Texas Bar No. 24058299 herein fully being “prohibited”, “banned” and

“forbidden” from furtherance’s acts and actions in

Destroying, conceal, alter, hide, screen, obscure, mask, disguise, demolish,

liquidate, erase, and eliminating all material evidences supporting all subject

matter herein contain in

(165)

All of Defendant and Co-Defendant(s) collective book keeping records,

court documents, banking records, personal banking records, computer records,

Insurance records, Business records, construction estimates, FEMA records,

financing statements, Texas Department of housing & community affairs records,

Property lien records, property deeds records and all material records in

relationship to the exact time frame home damages caused by

Hurricanes “Rita”, “Humberto” and “Ike” to the property located at 448 DeQueen Blvd. in Port Arthur, Texas in this ongoing (RICO) enterprise cover up

scheme of things relationship between the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein.

(166)

In which “Chief” Defendant Antoine L. Freeman J. D. (Attorney at Law)

Texas Bar No. 24058299 herein from the past dates of March 14th 2008 throughout 2015 fully did in all facts, events, and circumstances committed to, engage and executed his (Attorney at Law) skills in

Destroying, concealment, alter, hide, screen, obscure, mask, disguise,

demolish, liquidate, erase, and eliminating all material evidences supporting all subject matter herein.

And the complete disappearance act of “physical evidence” in a civil suit in

common law Docket No. A-180805

Namely an entire dwelling, residences’, and or structural home located at

448 DeQueen Blvd. in Port Arthur Texas (Block 172 Lot 1-2). Said dwelling being a party to Cause No. A-180805 in the 58th Judicial District Court of Jefferson County Texas

Since November 17th 2007 being “actual date of all injuries acquired and

occurred against the Pro Se Plaintiff civil rights, peace, dignity, physical well beings, earning capacities, and personal property, within the jurisdiction of this United States District Court.

(167) Final Conclusion

Pro Se Plaintiff officially smiling at this time frame as being declares, affirm, and state furtherance before the “Honorable Justice”

Pro Se Plaintiff having “little” Knowledge that (RICO) is a “criminal act” and

all material evidence contain in the attached exhibit(s)

A,B,C,D,E,F,G,H,I,J,K,L, M And N attached herein support a factual, events, and circumstances legal finding concerning the federal subject matter as presented before the “Honorable Justice”

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

24058299 and Co Defendant(s) “Joyce M. Guy and Edward McCray herein

Collectively did in all factual civil unjust circumstances 100% willfully engage in a criminal enterprise (RICO) acts and actions beyond meeting the

required “reasonable doubt” standards as legally required in criminal law.

(168)

Pro Se Plaintiff declares, affirm, and state furtherance before the “Honorable Justice” having “little” Knowledge that (RICO) is a criminal act and all material evidence contain in the attached exhibit(s) A,B,C,D,E,F,G,H,I,J,K,L, M And N attached herein

Support a factual, events, and circumstances concerning the subject matter

as presented before the “Honorable Justice” Defendant Antoine L. Freeman J. D.

(Attorney at Law) Texas Bar No. 24058299

And Co Defendant(s) “Joyce M. Guy and Edward McCray collectively

herein did in all factual civil unjust circumstances willfully engage in a criminal enterprise (RICO) acts and actions by a

Preponderance of all “material evidences” contain in the attached exhibit(s) A,B,C,D,E,F,G,H,I,J,K,L, M And N attached herein

As legally required under the standards in civil law, and warranting a

Protective (TRO) order as prescribed by the United States Laws.

(169) Wherefore Pro Se Plaintiff declares, affirms, state, and moves furtherance

before the “Honorable Justice” for a (TRO) and absolutely acts of “Justice” of his “Honorable Justice” in 100% freezing protection in all described collective asset

completely thereof herein Defendant Antoine L. Freeman J. D. (Attorney at Law)

Texas Bar No. 24058299

And Co Defendant(s) “Joyce M. Guy and Edward McCray collectively. (170) Pro Se Plaintiff declares, affirm, and state furtherance before the

“Honorable Justice” his “Honorable Justice” not only dealing with a well skilled, crafty Fraud prevention (RICO) rogue

“Attorney at Law” among other wasteful skilled being executed against the

Pro Se Plaintiff Louis Charles Hamilton II as described directly herein (172) His “Honorable Justice” having now “official direct dealing” with the Elusive

Sinister described Co-Defendant “Edward McCray” herein fully being in the never ending status of “Once a Dog Ass Pimp “

Always a “Dog Ass Pimp” backwoods “Ugly Chicken Thievery Negro”

mentality of Co-Defendant “Edward McCray”. (173) And His “Honorable Justice” now officially involved and having “direct

dealing” with the describe Co-Defendant “Joyce M. Guy” herein and “Actual factual circumstances” surrounding the “Old Spooky Story Book

Mystery Tales that “Live bullets” do not kill “Vampires”. (174) This is a 100% well over due official, final and legal conclusion, just before

“Justice” elementary complete “Pro Se investigation” ending to all events, acts, actions, and circumstances surround “direct actual damages of injuries occurred in the past dates of November 17th 2007 well ongoing into 2015 to the described Plaintiff herein.

(175) All (Legal Parties) described herein their “official capacities” being also a

party to “Cmdr. Bluefin” (USN) “Sherlock Holmes” mystery writer case of: “The Dead Man Who Paid Taxes” before his “Honorable Justice” (176) Dedications to my Sweet Darling “Pinky Rose De Chavez” Dedications of “The Original Hit Song Version” by: “Judy Collins” “Send in the Clowns”

Before his “Honorable Justice Zack Hawthorn”

United States Magistrate Judge.

Execution on this Dated 24th day of December 2014

By, __________________________________ Louis Charles Hamilton II Pro Se Plaintiff U.S. Docket No 1:2014-CV-592 P.O. Box 17524, Sugar Land Texas, 77496

MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al...

Law

Transcript of MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al...