Amend U.S. Civil Complaint Louis Charles Hamilton II vs. Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 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.

(Attorney at Law) Texas Bar No. 24058299

Defendant

Joyce M. Guy

Edward McCray

Co-Defendant(s)

Amend Civil Complaint

Jury Demand

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

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

Just Cause, Pro Se Plaintiff herein will show before the “Honorable U.S. Court”

all facts, circumstances, detailing “among other things”

“Past, present and future (RICO) “Racketeer Influenced and Corrupt

Organizations Acts and actions, to include but not limited to actual Fraud of a 58

Judicial District Civil Court in Jefferson County in Common Law,

And direct “Obstruction of Justice” in connection thereof Civil Court

Docket No. A-180805 being with criminal hostile intent committed against

among others the Pro Se Plaintiff “Louis Charles Hamilton II” herein “Will”, “Civil

Rights”, “Peace” “Personal Property” and “Dignity”.

“United States of America” Not a Party to this U.S. Civil Suit “However” at this present time frame “United States of America” being past, present and future “time frame" being legally a unwilling connected party to all subject matter to which includes

“United States of America” suffrage in “actual monetary losses” in excess of

$127,339.31 U.S. Dollars in connection with Hurricanes, “Rita”,

“Humberto” and Ike” storm damages in connection with the Pro Se Plaintiff Louis Charles Hamilton II herein

Profession as an “Independent Construction Contractor” And the

property(s) located at 5050 east 7th street in Port Arthur Texas and 448 DeQueen Blvd. in Port Arthur Texas

1.

Parties.

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

Veteran,

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

Permanently Disable Veteran protected under:

(ADA) American with Disability Act;

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

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

2.

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

for the State of Texas Bar No. 24058299

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

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

3.

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

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

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

business and this category has 2 companies in Port Arthur Texas.

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

448 DeQueen Blvd. in Port Arthur Texas 77640,

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

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

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

DeQueen Blvd. in Port Arthur Texas 77640

And Paragon Business Inc. (Lot 10 “block 18 Jef Chaison)

4.

Jurisdiction

Jurisdiction is proper before the “Honorable U.S. Court” of The Eastern

District of Texas in that (Pro Plaintiff) is always a resident of Jefferson County

Texas, residing in Fort Bend County and all acts and actions described herein by

all the Defendant and Co-Defendant(s)

(RICO) enterprise endeavor(s) described herein fully occurred within the

Jurisdiction of Eastern District of Texas within the United States which occurred

in Port Arthur Jefferson County Texas.

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

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

above in paragraph (2)

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

Bar No. 24058299 herein was acting in his full capacities as an “License

Attorney” on retainer for the legal behalf of one (Co)-Defendant(s) “Joyce M.

Guy” and “Edward McCray” living at 448 DeQueen blvd. in Port Arthur Texas

77640 in a Civil Action in

The District Court 58th Judicial District of Jefferson County, Texas, Docket

No. A-180805

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

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

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

and Corrupt Organizations Act”, with this racket and Fraud on the 58th Judicial

District Court of Jefferson County Texas, while using also the legal skilled

devices in almost 2 years of “Obstruction of Justice” in connection with

“Mail and Wire Fraud”, “Direct Fraud” on all official court records derive thereof and “Constructive Fraud” in connection with Jefferson County Texas 58 th District Court Records, and

Direct Fraud acts, and actions and scheme of things involved in Jefferson

County Public Records in Connection with (2) “Texas Department of Housing and Community affairs” for Loans in excess of

$127,339.31 U.S. Dollars in connection with Hurricanes, “Rita”,

“Humberto” and Ike” storm damages in connection with the Pro Se Plaintiff Louis Charles Hamilton II herein.

5.

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

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

Wire Fraud”,

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

Racketeering Influences Corruption Organization, Chief Defendant Antoine L.

Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant “Joyce

M. Guy maintained such a enterprise from the years of 2007-2010 to execute

such a (RICO) enterprise “scheme of things”, Notwithstanding

Aiding and abetting to commit to A Criminal Enterprise racket and

monetary retain endeavor in (RICO) “Racketeer Influenced and Corrupt

Organizations Acts” in his Chief Defendant capacity as an acting Attorney of Law

in and for the State of Texas,

Against the rights, peace, dignity, and U.S. Code: Title 28:1343 Violations

of Pro Se Plaintiff Civil Rights herein in “among other things”

“Equal Protection of the law” in a civil suit in common law filed in

Jefferson County Texas 58th Judicial District Court within The United States of

America docket No A-180805.

To include but not limited to Chief 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 in

"Violations against the Computer Fraud and Abuse Act (CFAA) 18 U.S.C. §

1030 in connection with all (RICO) enterprise “criminal acts and actions”, as

legally described fully herein.

6.

Chief 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

Being intertwine in a conspire complex mutable corrupted “scheme of

things” for several years starting from 2007-2010 to include a rouge attorney

engaging in a fraudulent obstruction of justice cover up

“Scheme of thing” for all past, present and future (RICO)racketeering past

enterprises monetary gains

In a half bake (RICO) combine “greedy racket enterprise” scheme of things

that has accumulated gradually past acquisition of hidden (RICO) monetary

earnings cars, possessions and properties estimates in excess of $980,000.00

U.S. dollars

From the time frame of 1997-2015 and to include but not limited to the

Grand (RICO) scheme of things involving the

Pro Plaintiff Louis Charles Hamilton II herein alone in excess $127,339.31

monetary scam of (2) U.S. Federal Housing Grant.

In a half bake (RICO) combine “greedy racket enterprise” scheme of things

that has accumulated gradually past acquisition of hidden (RICO) monetary

earnings cars, possessions and properties estimates in excess of $980,000.00

U.S. dollars net gain

From the exact time frame of 1997-2015 and to include but not limited to

the Grand (RICO) scheme of things involving the Pro Plaintiff Louis Charles

Hamilton II herein alone in excess $127,339.31 monetary scam of (2) U.S.

Federal Housing Grant.

Fully “greedy racket enterprise” scheme of things complete by Co-

Defendant “Joyce M. Guy and Edward McCray herein since 1997 Identified as

follows:

(RICO) “Scheme of things” is involved in concealing, obscuring, masking, cloak and shielding corrupted fraudulent “mutable fraudulent business” enterprise endeavor operations the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” herein concoct and obtaining massive hidden income from over many years described as follows:

A. Assumed name business “G & G Services” a fraudulent Medical

services for obtain (13) years of hidden “monetary payments” from “Senior Aging Handicap Citizens within Jefferson County Texas which “G & G Services” was never even a litigable Licenses medical company with the State of Texas from May 2nd 1997- 2010 as being order shut down as described in Pro Se Plaintiff attached exhibit (F)

on file with the U.S. Clerk from the Texas Department of Aging and Disability Services. *to include but not limited to “Tax Evasion” being directed at both the “State of Texas” and “The United States of America” for a actual time period of (13) plus years in this (RICO) illegal medical business operation fraudulent corrupted “scheme of things”. To include but not limited to upon information and belief “G & G Services” medical services is secretly still in business operation …….Omg (wow)

B. While “G & G Services” income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

C. Assumed name business “E and J Collectibles” 448 DeQueen Blvd. in Port Arthur Texas which is in the Used Merchandise Stores business for a unknown amount of years having (2) companies in Port Arthur Texas “However” these (2) companies is not registries with “Jefferson County Texas, or upon information and belief registries with the “State of Texas” fully engaging in among other things (RICO) enterprise in “Sales Tax Evasion”, *Business is current in operation as identified on the “internet” for a unknown accountability of time.

D. While “E and J Collectibles” income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

E. Assumed Name J Can Company in Port Arthur Texas business operation from April 11th 2008 – 2015 this J Can Company business operation is a “front company” for (RICO) enterprise scheme of things in “among other things” besides hidden sells of “Crack cocaine industry” actually further engaging at this present time frame April 11th 2008 in (RICO) enterprise in “money laundering” in scrap metal materials” in connection scheme of things with assumed name business “Cars and Pieces”.

F. Another “front company” located in Beaumont Texas. To include but not limited to J Can Company business operation and “Cars and Pieces” business operation (RICO) enterprise engaging in State and Federal Tax Evasion.

G. While J Can Company income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

H. Assumed Name “Car and Pieces” in Beaumont Texas business operation from May 10th 1990 while actually engaging in (RICO) enterprise in “money laundering” in scrap metal materials” in connection with assumed name business J Can Company in Port Arthur Texas. As described in paragraph (C) above.

I. While “Car and Pieces” income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

J. Assumed Name Paragon Business Inc. being a unknown company of sorts, current in business operation since May 17 th 2001 while Paragon Business Inc. income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

7.

To include Chief 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 fully being both “directly” and “indirectly “ design

carefully with “conscious intent” to criminally conspire, plotting, scheme, and

execute (2) (RICO) racketing monetary endeavor(s) against the

“United States Housing Grant(s)” being Congress funded with the “State

of Texas Housing” and “Community Affairs Project” in direct violation against 18

U.S.C. § 1001: US Code - Section 1001:

Statements or entries generally:

(a) Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States,

Knowingly and willfully - (1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact;

(2) Makes any materially false, fictitious, or fraudulent statement or representation; or

(3) makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry; in connection

In connection with fraudulent legal device, tactic’s, instruments and

documentations to fraudulent obtain in excess of $127,339.31 scam being

knowingly and willfully conspire, collaborated as such against (2) United States

Federal Housing Grant.

“Namely” on May 28th 2010

7.

“Texas Department of Housing” and “Community Affairs” Loan No. 5866 File No. 1219-2355082 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005

Federally Declared Disaster Funding under Department of Defense

Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)

Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency:

United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year

(Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007 to obtain on May 28th 2010 in excess of $54,839.31 U.S. Dollars “Construction Grant”

As being described in Pro Se Plaintiff exhibit (P) on file with the U.S. Clerk

of Court namely a “Mechanic’s Lien Contract” with DSW Homes 805 S. Hwy. 69, Memorial Fwy, Nederland, TX, 77267

To repair the home located at 5050 east 7th street in Port Arthur Texas after (2) Private Insurances Monies for hurricane damages to said property already being a part of a continue (RICO) “pattern and practice” squander free “scheme of things” committed by Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively

Involving once again the Pro Se Plaintiff Louis Charles Hamilton II herein

as the Construction contractor providing damages estimates with Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 fully in fraudulent

(RICO) legal denial of ever being actually the physically acting “Attorney of record” in this civil suit in common law A-180805 as a part of this cover up scheme of things

While all of this criminal half bake concoct (RICO) enterprise “scheme of

things” being formed and direct against not only the Pro Se Plaintiff, but to include private insurances companies in connection with the Pro Se Plaintiff Construction damages estimates at

(2) Counts and among others parties namely “The United States of

America” for a monetary lost in excess of $54,839.31 U.S. Dollars. For the property located at 5050 east 7th street in Port Arthur Texas 77640

8. To add to Chief Defendant Antoine L. Freeman J. D. (Attorney at Law)

Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collective combine additional

(RICO) enterprise “scheme of things” in a past further fraudulent “scheme of things” in obtaining additionally another monetary (RICO) enterprise shame in excess of $72,500.00 U.S Dollars from “Namely” on June 9th 2009

“Texas Department of Housing and Community affairs” Loan No. 2727 File

No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005

Federally Declared Disaster Funding under Department of Defense Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)


United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007

As being described in Pro Se Plaintiff attached exhibit herein (Q) Namely

“Mechanic’s Lien Contract” SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060

For Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar

No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein In a total (RICO) combine pattern and practice “scheme of things” against

the “United States of America” alone for two properties in monetary ill gotten gain in excess of $127,339.31 U.S. Dollars

9.


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

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

of Texas To commit and conspire to the same

(RICO) criminal enterprise causes in all “acts and actions” in leadership,

direct legal conspire devices, instruments and documentations & fully in

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

McCray” herein from to 2007-2015

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

With “among other things” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Actual Fraud upon the

“Texas Department of Housing & Community Affairs” Jefferson County Texas and Federal Grants derived thereof in Connection with the Pro Se Plaintiff “Louis Charles Hamilton II” herein an “Independent Construction Contractor”.

With “among other things” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Actual Fraud of Private Homeowner Insurance Companies”, for primary fraud during

“Hurricane “Rita”, “Ike” and “Humberto” related to Construction storm damages, in connection with the Pro Se Plaintiff “Louis Charles Hamilton II herein.

10.

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

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

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

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

collectively together to pursue the same Criminal (RICO) “Racketeer Influenced

and Corrupt Organizations Act” monetary objectives,

In first and foremost Execute Fraud on the 58th Judicial District Court of

Jefferson County Texas and the Honorable Bob Wortham with such acts, actions

and events as “Mail and Wire Fraud” in connection thereof, of the “Direct

(RICO) Fraud “scheme of things” to fraud the United States Disaster relief

Homeowner program

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

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

being done criminally/civilly against the Pro Se Plaintiff civil rights, peace, will,

and dignity,

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

All being wrongfully and fully committed to within the Jurisdiction the

Eastern Division of Texas United States District Honorable Court.

11.

Subject Matter Jurisdiction

Venue

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

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

proper before this U.S. District Court primary exclusive with many “federal

Questions” involving “among other things”

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

Racketeering Influences Corruption Organization,

Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud),

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

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

Falsification, obstruction and concealment of “Material facts”, subject

matter before a civil suit in common law proceeding with Conspiracies

committed by all described “Defendant and Co-Defendant(s)” herein collectively

to pursue to the same Criminal Monetary (RICO) enterprise monetary racket

Objective(s) involving against the Pro Se Plaintiff herein will, and personal

property

With mutable counts of constructive fraud activities “hiding behind”

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

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

“Attorney and his client”,

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

(Active) in and for the State of Texas Bar No. 24058299 in collusion and

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

To Commit to each and every Fraudulent acts in among other things all

“prepared legal court documents”, “affidavit(s)”, “interrogatories”, “request for

admissions”, sign statements and all other materials of Jefferson County Court

records, document(s) and materials facts in 58th Judicial District Court of

Jefferson County Texas Court Docket No. A-180805

“To include but not limited” absolute obstruction of Justice to apply the

same (RICO) scheme of things in a fraud attack upon the Honorable Judge Bob

Wortham, and His 58th Judicial Court and all court officers, court transcripts

involved thereof, including Fraud of the entire “Clerk of Court office” records of

Jefferson County Texas docket No. A-180805 to execute the same (RICO)

criminal monetary objectives described legally herein this “Amend Complaint”

of the Pro Se Plaintiff with

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

financial records in connection with “Insurance Companies”, and official

“Financial Statements” for primary monetary fraud and scheme advantages

during “Hurricane “Rita”, “Ike” and “Humberto ” scheme of things related to

Construction storm damages, derive thereof further involving the Pro Se

Plaintiff herein in his private profession as a “Independent Construction

Contractor”.

12.

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

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

“Federal Grants of $72,500 U.S. Dollars” derive thereof and Federal Grants of

$54,839.31 in connection with the Pro Se Plaintiff herein

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

Racketeering Influences Corruption Organization, Section 1341 (relating to mail

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

related activity in connection with identification documents), Section

1503(relating to obstruction of justice), violation of 18 U.S.C. § 1001: US Code -

Section 1001:

To include but not limited to the “Actual Fraud(s)” the Co-Defendant(s)

“Joyce M. Guy” and “Edward McCray” committed and involved in monetary

conspiracies against mutable “Insurance Companies”, for primary fraud and

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

related Construction storm damages, for (2) properties as described herein

Involving further The Pro Se Plaintiff herein as a “unwilling blind” party

into this cold calculated complex fraudulent acts and action(s), and complex

scheme of things to further leading to fraud of the “Texas Department of

Housing” & “Community Affairs” of Jefferson County Texas

And a “Federal Grants in excess of $72,500 U.S. Dollars” derived thereof

and Federal Grants of $54,839.31 derived thereof under the direction,

leadership, and skills of none other than the Chief Defendant Antoine L.

Freeman J. D. a (Attorney at Law) (Active) in and for the State of Texas Bar No.

24058299

13.

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

Texas and all records derive thereof, in this “Grand (RICO) enterprise “scheme of

things” in connection with a fraudulent complex designed scheme of things

against the

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

Texas and (2) “Federal U.S. Grants in excess of $72,500 U.S. Dollars” derived

thereof and Federal U.S. Grants of $54,839.31 derived thereof for a combine

total of $127,339.31

14.

To include but not limited to Actual Fraud of mutable Insurance

Companies”, fraud of FEMA Repair Funds and repair materials for primary

additional monetary fraudulent acts and actions gains during “Hurricane “Rita”,

“Ike” and “Humberto” related Construction storm damages, involving the Pro Se

Plaintiff Louis Charles Hamilton II herein

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

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

and for the State of Texas Bar No. 24058299 in direct collusion, leadership, legal

skilled directions and conspiracies thereof with Co-Defendant(s)

“Joyce M. Guy” and “Edward McCray et al” collectively corrupted

activities, dating back since the year 1997-2015

To include but not limited to being a dated of unpaid “Principal and

Interest” on (1) of the Co-Defendant(s) collectively herein (RICO) monetary

scheme of thing for $72,500 U.S. Dollars housing grant being mature on June 8 th

2012 when it was fraudulently executed on June 9th 2009

And To include but not limited to being a dated of unpaid “Principal and

Interest” on the second scheme of things designed of the Co-Defendant(s)

collectively herein (RICO) monetary scheme of thing for $54,839.31 U.S. Dollars

housing grant being mature sometime in the future year of 2015 when it was

fraudulently executed on May 28th 2010

Fully executed in past, present and future (RICO) enterprise endeavor full

crafty complex designed, prepared plans, legal court records, type mail and wire

fraud “scheme of things”, with an corrupted skilled evil eye towards the

“realistic possibility” of impending “United States Federal Court litigation” by

the Pro Se Plaintiff herein

Against “Defendant and Co-Defendant(s)” collective commitment to

include but not limited to this Grand direct (RICO) Fraudulent monetary

shameful objects and obstruction of justice “scheme of things” being direct

against The will of the 58th Judicial District Court of Jefferson County Texas and

all Court records derive thereof in this civil in common law Docket No A-180805.

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

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

$336,000.00 U.S. Dollars in (7) years of Pro Se Plaintiff “Lost wages” and “actual

theft” thereof Pro Se Plaintiff”Louis Charles Hamilton II” herein construction

Company entire “Construction tools” in excess of $3,800.00 U.S. dollars since

date of injury

November 17th 2007 and counting well into 2015 in this (RICO) enterprise

collective “scheme of things” being still directly enforced, very much ongoing

and very live against the Pro Se Plaintiff Louis Charles Hamilton II herein fully

against the Pro Se Plaintiff “Civil Rights”, “Peace”, “Will” ,“Personal Property”

and “Dignity”, as of this undersigned date of this “Amend Complaint”.

15.

With further combine past, present and future (RICO) enterprise

conspiracy racket “scheme of things” in mutable “fraudulent” acts, actions,

events, and circumstances committed by “both” the Defendant and Co-

Defendant(s) collectively herein to plan a continue future “scheme of things” in

the also continue Theft of Pro Se Plaintiff “Independent Construction Company

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

Being wrongfully added in this (RICO) enterprise criminal conduct being

executed and done within the Jurisdiction of the “Honorable U.S. Justice”

further causing the Pro Se Plaintiff “Louis Charles Hamilton II” herein to suffer

“among other things” actual damages in excess of $336,000.00 U.S. Dollars to

include to impose

Extreme real life hardship, Extreme Intentional Infliction of emotional

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

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

Corrupt Organizations Act”,

“Fraud on the Court”, “Mail and Wire Fraud” in connection with Fraud

upon the Court, “Obstruction of Justice” “Direct Fraud” and “Constructive

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

Fraud upon the Jefferson County Public Records combine with all other

extreme hostile corrupted wicked cruel civil/criminal acts and actions being fully

described in this amend complaint herein.

16.

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

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

24058299 with expert skilled attorney at law powers, fiduciary responsibilities

with “intent willful knowledge of his actions

Knowingly and willfully engage to committed a combine conspiracy with

Co-Defendant(s) “Joyce M. Guy and Edward McCray collectively herein to act in:

Violations of Chapter 96 of Title 18 United State Code:

In that Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas

Bar No. 24058299 (RICO) Racketeering Influences Corruption Organization

Enterprise, engagement endeavor

To include commit (RICO) under Section 1341 (relating to mail fraud),

section 1343 (relating to wire fraud),

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

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

Fraud upon the 58th Judicial District Court of Jefferson County Texas in

connection with

Falsification and concealment and direct destruction of “Material facts”,

namely an entire Home being destroyed while being material evidence during

said civil suit in common law

While adding numerous other Fraudulent Activities in the Capacity of an

“Attorney at Law” to cause Pro Se Plaintiff “Louis Charles Hamilton II” herein to

continue suffers “actual damages” in excess of $336,000.00 U.S. Dollars

And this “actual damages” is ongoing as of this undersigned date in the

year of 2015 of this “Amend Complaint” before the “Honorable Court U.S.

Justice” since date of injury November 17th 2007.

17.

To include mutable (RICO) enterprise in “Falsification of “Material facts” Documents and Records, and Numerous Fraudulent Activities in the Capacity of a “Attorney at Law” In direct connection with Pro Se Plaintiff “Louis Charles Hamilton II” herein and direct fraud against the

“Texas Department of Housing and Community affairs” Loan No. 5866 file






(Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007 to obtain on May 28th 2010 in excess of $54,839.31 U.S. Dollars “Construction Grant” for the property located at 5050 east 7th street in Port Arthur Texas

As being described in Pro Se Plaintiff attached exhibit already filed with

the U.S. Clerk office in the records being described as Pro Se Plaintiff exhibit (P) And Defendant and Co-Defendant(s) collectively once again obtaining

additionally by (RICO) enterprise “scheme of things” design, instrument and device and legal court documents another monetary shame in excess of $72,500.00 U.S Dollars for the property located 448 DeQueen Blvd. in Port Arthur Texas

“Namely” on June 9th 2009 committed against the “Texas Department of Housing and Community affairs” Loan No. 2727 File






As being described in Pro Se Plaintiff attached exhibit already filed with

the U.S. Clerk office in the records being described as exhibit (Q) Namely “Mechanic’s Lien Contract” SWMJ Construction Inc., 525 N. Sam

Houston Pkwy East, Suite 600, Houston, Texas 77060 For Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar

No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein In a total (RICO) enterprise combine monetary “pattern and practice”

“scheme of things” against the “United States of America” tax payers in monetary fraudulent acquisitions gain and earnings in excess of $127,339.31 U.S. Dollars

Violations of the Pro Se Plaintiff just rights to both Federal and State citizenship “Civil Rights” of the 7th Amendment of the United States and civil rights to “due process of the law” derive thereof in said civil suit in common

law within the State of Texas

Violations of the Pro Se Plaintiff civil rights to Constitution Laws of the State of Texas namely

Article 16: “General Provisions” Section 37 provides for constitutional protection of the “mechanic’s lien” against Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein

Which Defendant and Co-Defendant(s) collectively in furtherance’s (RICO) enterprise execute efforts, conspire, hinder, obstruct, and full derailment of Pro Se Plaintiff civil rights to Constitution Laws of the State of Texas namely

Article 16: “General Provisions” Section 37 and Section (50) provides for protection of homestead against force sales to pay debts, except for foreclosure on debts related to the homestead (mortgage, taxes, mechanic’s liens, and home equity loans).

In connection with the property located at 448 DeQueen Blvd. in Port Arthur Texas being a direct party to said civil suit in common law for breach of construction contract and actual fraud derive thereof.

18.

Pro Se Plaintiff “Louis Charles Hamilton II” herein seeks Actual,

Accumulative, Compensatory, Consequential, Continuing, Expectation Damages,

Foreseeable, Future, Incidental, Indeterminate, Reparable, Lawful, Proximate,

Prospective, Special, Speculative, Substantial, Declaratory Judgment, Punitive,

Exemplary and Permanent Damages;

Pro Se Plaintiff seeks also Actual Awards for “Intentional Infliction of

Emotional Distress” and “Mental Anguish”.

Pro Se Plaintiff moves the Cost of the Honorable Court, and for the Pro Se

Plaintiff legal fees, any Attorney Fee’s occupied herein

And such other further relief as Pro Se Plaintiff “Louis Charles Hamilton II

may be deem entitled to in Law or in Equity.

Factual Background

19.

Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) and Co-Defendant(s) “Joyce M. Guy” and Edward McCray”

collectively herein having on the 28th day of August 2009 in a “live” courtroom hearing setting before

The 58th Judicial District Court of Jefferson County Texas appeared in

there persons and “legally defeated” Pro Se Plaintiff attempt to protect “Norma Guy” legal Senior Citizen Rights” from her own fraudulent destructive daughter pattern and practices in a continue long history of (RICO) enterprise scheme of things since 1997. Starting with first and foremost” in that

Namely Co-Defendant “Joyce M. Guy” (RICO) enterprise scheme had commenced early against another said Hurricane damaged “property” located at 5050 east 7th street in Port Arthur Texas.

Which the Co-Defendant(s) “Joyce M. Guy” herein enjoying a “Power of

Attorney” relating to Real Property Transactions as Described in Pro Se Plaintiff attached exhibit (O) herein already on file with the U.S. Clerk Office “Specific Power of Attorney” executed on the 27th day of May 2010.

20.

Pro Se Plaintiff being further set forth Declares, Affirm, and State further

before the “Honorable U.S. Justice” the Co-Defendant(s) “Joyce M. Guy” and Edward McCray herein collectively having already “squander” all of the entire Hurricane repair funds for her own mother home as a direct result of Hurricane “Rita” storm damages which

“Hurricane “Rita” was the fourth-most intense Atlantic hurricane ever

recorded and the most intense tropical cyclone ever observed in the Gulf of Mexico, which on September 24th 2005 the inner core and eye wall of “Hurricane Rita slams into Port Arthur, Texas

Which the Pro Se Plaintiff will show the Honorable Court” factual evidence during the Trial of this matter of being the direct “construction contractor” whom was contacted to fix,

And Pro Se Plaintiff “Louis Charles Hamilton II” herein did in factual

circumstances provide estimates of repair cost for said damaged Home located at 5050 east 7th street in Port Arthur Texas which Co-Defendant “Joyce M. Guy” submitted said estimates to a unknown at this time “private home owner insurances company”,

And received funding base upon Pro Se Plaintiff herein construction damages in connection in needed cost estimates for said property located at 5050 east 7th street in Port Arthur Texas 77640.

Thereafter Pro Se Plaintiff herein returning to his home town of “Port

Arthur Texas from working “needed (ASAP) construction repairs” after massive storm damages in New Orleans LA as a result of Hurricane “Katrina”.

21. Pro Se Plaintiff being further set forth Declares, Affirm, and State further

before the “Honorable U.S. Justice” was extremely concern for especially among other things fixing the (asap) needed roofing repairs of 5050 east 7th street in Port Arthur Texas which Co-Defendant(s) “Joyce M. Guy” refusal to comply with the terms and conditions of said

“Insurances repair Funds” to actually fix such Hurricane damages other

then Co-Defendant(s) “Joyce M. Guy” (RICO) scheming plans to obtain said “private Insurances repair Funds” for her own personal private gains.


before the “Honorable U.S. Justice” the Co-Defendant(s) “Joyce M. Guy” herein after squandering all of the said “private insurance” Hurricane repair funds designated for damaged “property” located at 5050 east 7 th street in Port Arthur Texas.

“Lot number (10) in block number (4) of Lakeview “she” next contacting Federal “FEMA” for needed roofing plastic covering to stop the rain water, and never fixed the damaged roof at all ever.

And just use the Pro Se Plaintiff Construction Contract as a device to

execute this Fraud upon the Private Insurance Company, as well as to execute

the same scheme of things against the Pro Se Plaintiff, in not having the Contract honored, for Pro Se Plaintiff Construction Company profits derive thereof,

Which all of the Co-Defendant “Joyce M. Guy”, device, instrument,

events, and circumstances was to achieve monetary fraud from the Private Insurance Company and making the Pro Se Plaintiff “Louis Charles Hamilton II” herein an unwilling party, and victim thereof at this first stage of this (RICO) enterprise involving Pro Se Plaintiff.

22. Pro Se Plaintiff being further set forth Declares, Affirm, and State further

before the “Honorable U.S. Justice” Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively secondly secretly make plans, scheme, precise calculations and plotted to carry out a further

(RICO) scheme of things against “first and foremost” the 58th Judicial

District Court of Jefferson County Texas in the scheme execution of covering up all of the Co-Defendant “Joyce M. Guy”

Monetary scheme already made against the Hurricane repair “private

insurance funds” designated for said damaged “property” located at 5050 east 7th street in Port Arthur Texas. “Lot number (10) in block number (4) of Lakeview

Which this was “Fraud upon the 58th Judicial District Court of Jefferson

County Texas being executed on August 28th, 2009 before the Honorable Bob Wortham, His Court, and all Court officers involved,

To which at this time frame said Chief Defendant Antoine L. Freeman J. D.

(Attorney at Law) Texas Bar No. 24058299 herein being in quite factual legal denial of even being the actual “attorney of record” or ever being a physical representative party present at said “Court hearing” August 28 th, 2009

To which Chief Defendant Antoine L. Freeman J. D. (Attorney at Law)

Texas Bar No. 24058299 herein actually in court documentations claiming

“among other things” in his legal services ended clearly there after filing a “General Denial” on

18th day of December 2007 for the behalf of said Co-Defendant(s) “Joyce

M. Guy and Edward McCray” collectively herein as already legally described in Pro Se Plaintiff exhibit (B) on file with the U.S. Clerk office namely

“Response to Plaintiff’s Motion for Sanctions by: Attorney of record

Antoine L. Freeman, J. D. Texas Bar. No. 240582993723 23. Pro Se Plaintiff being further set forth Declares, Affirm, and State further

before the “Honorable U.S. Justice” Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) and Co-Defendant(s)

“Joyce M. Guy” and Edward McCray” collectively herein having continue advancement further to collectively secretly make plans, and plotted to

“secondly” carry out a further (RICO) fraudulent “scheme of things” against the “Texas Department of Housing and Community affairs” Loan No. 5866 File






(Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007 to obtain on May 28th 2010 in excess of $54,839.31 U.S. Dollars “Construction Grant”

24.

As being described in Pro Se Plaintiff exhibit (P) already on file with the U.S. Clerk of Court namely a “Mechanic’s Lien Contract” with DSW Homes 805 S. Hwy. 69, Memorial Fwy, Nederland, TX, 77267

To repair the home located at 5050 east 7th street in Port Arthur Texas

after Private Insurances Monies already being a part of a continue (RICO) “pattern and practice squander scheme of things” committed by Co-Defendant(s) “Joyce M. Guy and Edward McCray”

Involving once again the Pro Se Plaintiff Louis Charles Hamilton II herein

as the Construction contractor with Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 fully in fraudulent (RICO) legal denial of ever being actually the physically acting “Attorney of record” in civil suit in common law A-180805 as a part of this cover up scheme of things

While all of this criminal half-bake concoct (RICO) scheme of things at this

stage being formed against the Pro Se Plaintiff, private insurances companies, and among others parties namely “The United States of America” for a monetary lost in excess of $54,839.31 U.S. Dollars

While Chief Defendant being still already acting “live” attorney of record

in civil suit A-180805 filed November 26th 2007 involvement with Pro Se Plaintiff Louis Charles Hamilton II herein while engaging in this (RICO) scheme of things secretly at the same time of a ongoing civil suit

Notwithstanding executing this Monetary Fraud against the Pro Se

Plaintiff, Private Insurances company to include against The 58 th Judicial District Court of Jefferson County Texas,

And United States Department of Housing and Urban Development

TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007.

All fraudulent (RICO) enterprise activities being wrongfully and secretly advance throughout the “United States Mailing System, the Jefferson County Civil Court records, and transcripts derive thereof for docket No. A-180805

25.


before the “Honorable U.S. Justice” Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively secondly secretly make plans, scheme, precise calculations and plotted to carry out a further

(RICO) scheme of things in obtaining in excess of $72,500.00 U.S Dollars

from namely “Texas Department of Housing and Community affairs” Loan No. 2727 File






In connection with the property located at 448 DeQueen Blvd. in Port

Arthur Texas 77640 As being described in Pro Se Plaintiff exhibit (Q) already on file with the

“U.S. Clerk office Namely “Mechanic’s Lien Contract” SWMJ Construction Inc., 525 N. Sam

Houston Pkwy East, Suite 600, Houston, Texas 77060 For Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar

No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein In a total (RICO) combine pattern and practice “scheme of things” against

the “United States of America” in monetary excess gain of $127,339.31 U.S. Dollars

Collectively Being directly in violation of 18 U.S.C. § 1001: US Code - Section 1001: Statements or entries generally




(3) Makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;

And collectively Being directly in violation of Title 18 U.S.C. § 1341, 1343 and 1349 “Mail and Wire Fraud”,

And section 1028(relating to fraud and related activity in connection with

identification documents), And Section 1503(relating to obstruction of justice), Violations of Chapter

96 of Title 18, United State Code: 26.

Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Chief 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

“Knowingly and willfully” engaged in skill (RICO) enterprise “pattern and practices” – to falsifies, conceals, and used covered up tricks, scheme, and device against material facts; with many materially false, fictitious, and fraudulent statement, concealment, destruction of evidence, and representation in which

Under leadership of “Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299” herein and Co-Defendant(s) “Joyce M. Guy”

and Edward McCray” collectively herein conspire, plot, engage and execute the uses of each and every false writing or documents knowing the same to contain materially false, fictitious, and fraudulent statement or entry;

All of which “Knowingly and willfully” engaged and executed Against said unknown at this time “Private Insurance Companies”, against the Pro Se Plaintiff “Louis Charles Hamilton II herein civil suit in common law Docket No. A-180805 and all records derive thereof and against all such damages derive thereof,

27.

To include “Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299” herein and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein directly direct, conspire, plot, engage and execute the uses of each and every

“Knowingly and willfully” skill (RICO) enterprise “pattern and practices” for monetary gain – to falsifies, conceals, and used covered up tricks, scheme, device, fictitious, and fraudulent statements, concealment, destruction of evidence,

And fraudulent instrument during the course of representation, false writing or documents knowing the same to contain materially false, fictitious, and fraudulent statement or entry;

Against all Jefferson County Texas Public records, against all of the 58th Judicial District Court of Jefferson County Texas,

Against all of The United States Department of Housing and Urban Development records,

And against all of the “Texas Department of Housing and Community affairs” records.

28.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. 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 further continue on forward in there

(RICO) “Scheme of things” involved in “obstruction of justice in order to

further engage collectively concealing, obscuring, masking, cloak and shielding corrupted fraudulent “mutable fraudulent business” enterprise operations the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” herein concoct, share, execute and obtaining massive hidden (RICO) enterprise income over many past years starting since 1997 described as follows:

A. Assumed name business “G & G Services” a fraudulent Medical

services for obtain “monetary payments” from “Senior Aging Handicap Citizens within Jefferson County Texas which “G & G Services” was never even a litigable Licenses with the State of Texas from May 2nd 1997- 2010 as being order shut down as described in Pro Se Plaintiff exhibit (F) already on file with the U.S. Clerk office from the Texas Department of Aging and Disability Services. *to include but not limited to “Tax Evasion” being directed at both the “State of Texas” and “The United States of America” for a actual time period of (13) plus years in this (RICO) illegal medical business operation fraudulent corrupted “scheme of things”. To include but not limited to upon information and belief “G & G Services” medical services is secretly still in business operation …….Omg (wow)


C. Assumed name business “E and J Collectibles” 448 DeQueen Blvd. in Port Arthur Texas which is in the Used Merchandise Stores business for a unknown amount of years having (2) companies in Port Arthur Texas “However” these (2) companies is not registries with “Jefferson County Texas, or the “State of Texas” fully engaging in among other things (RICO) enterprise in “Sales Tax Evasion”, *Business is current in operation as identified on the “internet” for a unknown accountability of time.

D. While “E and J Collectibles” income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward

McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

E. Assumed Name J Can Company in Port Arthur Texas business operation from April 11th 2008 – 2015 this J Can Company business operation is a “front company” for (RICO) enterprise scheme of things in “among other things” besides hidden sells of “Crack cocaine” while actually engaging in (RICO) enterprise in “money laundering” in scrap metal materials” in connection with assumed name business “Cars and Pieces”

F. Another “front company” located in Beaumont Texas. To include but not limited to J Can Company business operation and “Cars and Pieces” business operation (RICO) enterprise in State and Federal Tax Evasion.





29.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State

further before the “Honorable U.S. Justice” Chief 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 continue to engage in among

other things (RICO) “obstruction of Justice” collaboration, racket, trick and

Plot in their collective (RICO) “defense” in the direct refusal to produce

among other things said 58th Judicial District “Court Order” for discovery of the

“property deeds”, of 448Dequeen Blvd. in Port Arthur Texas and all records

involved in Hurricane “Rita,

Humberto, and Ike, in connection with the dwelling located at 448

DeQueen Blvd. in Port Arthur Texas as of this undersigned date in 2015.

And ruse, dodge, concealing, withholding, destroying, masking, obscuring

all past, property deeds, banking records, contractor(s) construction insurances

estimates and contract(s) for (5)-(6) hurricane storm damages claims,

homeowner private insurance records, for properties located at 5050 east 7th

street in Port Arthur Texas 77640,

And for properties located at 448 DeQueen Blvd. in Port Arthur Texas to

include but not limited to from the exact time frame of 1997-2015

Ruse, dodge, concealing, withholding, destroying, masking, obscuring all

past FEMA records, (4)-(6) mutable private illegal business company records,

personal banking records, business banking records, Texas Department of

Housing and Community Affairs housing records, State Tax Records,

Sales Tax records, (IRS) Tax Records, court records, and any and all

documents relating to any discovery into the corrupted (RICO) enterprise

endeavor of the Chief 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.

30.


before the “Honorable U.S. Justice” Chief Defendant Antoine L. Freeman J. D.

(Attorney at Law) Texas Bar No. 24058299 continue corrupted (RICO) enterprise

endeavor after he filed a “General Denial” for the Co-Defendant(s) Joyce M. Guy

and Edward McCray (herein) behalf to complaint

Cause No. A-180805 in Jefferson County Texas Between the dates of

December 18th 2007 engaged in several pattern and practices in the capacity as

a “Attorney of Law” in full obstruction of justice, concealing, obscuring,

masking, cloak and shielding while

Said (RICO) scheme corrupted being 100% fraudulent throughout the

dates of March 14th 2008 and continue on

a. April of 2008 b. May of 2008 c. June of 2008 d. July of 2008 e. August of 2008 f. September of 2008 g. October of 2008 h. November of 2008 i. December of 2008 j. January of 2009 k. February of 2009 l. March of 2009 m. April of 2009 n. May of 2009 o. June of 2009 p. July of 2009 q. August of 2009 r. September of 2009 s. October of 2009

Fully obstructed the 58th Judicial District Court discovery process, scuttles,

concealed, mask, and contained all “discovery materials” received from Pro Se

Plaintiff herein this civil matter from the exact time frame of March 14th 2008-

November 13th 2009

Being legally in possession, custody and control over Pro Se Plaintiff

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

and refusal to reply or response thereof

While at the same time being legally in possession of Pro Se Plaintiff

Request for admission and Interrogatories being sent throughout the “United

States mailing system

Chief Defendant Antoine L. Freeman, J.D. “Attorney at Law” herein fail

well beyond (30) days of this requested discovery to response or reply thereof,

for the information or material described in Rule 194.2: by a period of over (2)

years past the (30) days requirement to answer not only Pro Se Plaintiff

“Request to Disclose” Pursuant to Rule 194,

Chief Defendant (Attorney at Law) herein was also served Pursuant to Rule 198 of the Texas Rules of Civil Procedure Plaintiff Request for Admission(s) and Pursuant to Rule 197 of the Texas Rules of Civil Procedure Pro Se Plaintiff Set of Interrogatories

31.

All of which required a reply within (30) days of these request discovery materials as Chief Defendant a skilled (Attorney at Law) having full knowledge that a discovery phase process had commence in this civil legal in common law docket No. A-180805

There after submitting a “retain” counsel of law defense reply on behalf of the Co-Defendant(s) Joyce M. Guy and Edward McCray collectively herein on December 18th 2007 but this (RICO) enterprise endure and grew snowball affect downhill in design, instrument, documents,

Obstruction of justice, fraud upon the 58th Judicial District Court system, absolutely engaging in concealment to scuttle/hidden all required discovery document records and property deeds, all insurance records, hurricane events records, construction Contractor estimates

And contracts involved thereof from ever being discovery or brought before the Honorable 58th Judicial District subject matter Jurisdiction

100% gross unwanted stall tactics and circumstances against all material facts and required discovery described against the original State Court Complaint A-180805

To the point actual physical evidence was completely destroyed during the ongoing civil suit in common law action A-180805 to further long advancement of this complex secrete (RICO) enterprise scheme of things for a secured monetary value in excess of $73,500.00 U.S. Dollars in connection with

Namely the home located at 448 DeQueen Blvd. in Port Arthur Texas which is involved already in a disputed breach of Construction Contract, Fraud Claim made in connection with this complex violations of Title 18 U.S.C. § 1341, 1343 and 1349 “Mail and Wire Fraud”,

With Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 direct further violations relating to section 1028(relating to fraud and related activity in connection with identification documents), Section 1503(relating to obstruction of justice),

Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization to advance such a monetary enterprise In a total (RICO) combine pattern and practice “scheme of things” against the “United States of America” in monetary excess gain of $127,339.31 fully tax free and being a Housing grant of American U.S. Dollars

32.

"Computer Fraud and Abuse Act (CFAA) 18 U.S.C. § 1030 in connection with all criminal acts and actions described legally herein this Amend Complaint,

Furtherance’s being directly in violation of 18 U.S.C. § 1001: US Code - Section 1001:

As Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 100% direct leadership refusal to submit any “response or reply” to all said discovery request as indicated in paragraph (30) in a timely fashion

Or as generally required by Texas Rules of Civil Procedure “attorney of record institute a “withdrawal immediately” thereafter in the month of

December 2007 when Chief Defendant Antoine L. Freeman, J.D. “Attorney at Law” herein claiming in court documents his legal services officially ended directly Cause Pro Se Plaintiff “Louis Charles Hamilton II” herein to suffer “actual damages” in excess of $336,000.00 U.S. Dollars

And this “actual damages” is ongoing as of this undersigned date of this Amend Complaint before the Honorable U.S. Court Justice since date of injury November 17th 2007.

33.

To include but not limited to Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein fully conscious with intent direct, leadership, conspire, collaborated with the

Co-Defendant(s) collectively herein to fully violated Pro Se Plaintiff both Federal and State citizenship “Civil Rights” of the 7th Amendment of the United States and civil rights to due process derive thereof in said civil suit in common law

Namely in among other things Due Process of the law and the 7th Amendment Equal Protection within the State of Texas laws in equally title Pro Se Plaintiff having fair, just secure protection of a civil suit before the 58th Judicial District Court of Jefferson County Texas, appearing before the Honorable Bob Wortham” in docket No. A-180805

Which Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas

Bar No. 24058299 herein fully conscious with full intent direct his legal (RICO) enterprise fraudulent assault against said 58th Honorable Judicial District Court of Texas to criminally derail, conceal, contain, obstruct , and institute a denial due process of the law against

Pro Se Plaintiff said civil suit in common law for a total (RICO) combine

pattern and practice “scheme of things” against the “United States of America” in monetary excess gain of $127,339.31 fully tax free and being a (2) Housing grant sham of American U.S. Dollars scheme, plotting, and conspiring in making

the Pro Se Plaintiff herein an unwilling party thereof, and victim thereof of actual assault, for said scheme, sham in monetary excess of $127,339.31 in connection with said assault at the Property located at 448 DeQueen Blvd in Port Arthur Texas

With actual damages wrongfully directed at the Pro Se Plaintiff suffrage in

excess of $336,000.00 U.S. Dollars loss earning and earnings capacity and loss in Pro Se Plaintiff “personal property” in construction company tools, in excess of $3,800.00 lost being a part of this complex, half bake, and (RICO) endeavor

From the time frame of December 17th 2007-date of injury throughout December of 2015 as this well complex real-estate (RICO) scheme of things is ongoing and have financial maturity in 2015. With the Co-Defendant(s) “Joyce M. Guy and Edward McCray”

(RICO) racket assault” against the “United States of America”, dating well back to the exact year of 1997 in the first business “G & G Services” fraudulent scheme of things against elderly seniors for over a period of 13 years throughout 2010. “Under radar, and uncheck…

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

“G and G Service Company” until a real HCSSA license is obtains with the State of Texas which Chief Defendant Antoine L. Freeman J. D. “Attorney at Law” understood directly Pro Se Plaintiff himself being the direct cause for “Illegal medical business”

G and G Service Company being closed against Co-Defendant(s) while this civil suit was ongoing in the 58th Judicial District Court of Jefferson County Texas

34.

With Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein fully conscious with further premeditated intent, plans, direction, scheme and conspire herein his part in a (RICO) enterprise retain payments to work as legally off the books to legally fraudulently in the capacity as a

Professional attorney of law impose aid, hinder, conceal, obstruct, hide, destroy, ruse, cover up, fake and fool innocent Justice and contain not only Pro Se Plaintiff civil suit docket No. A-180805 but to include

The Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar

No. 24058299 herein also handsomely fully paid, retain, and directed to hinder, conceal, obstruct, hide, destroy, ruse, cover up, fake and make a fool of all of Pro Se Plaintiff discovery, and search into the truth in all such

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

past, present and future (RICO) enterprise “monetary racket assault” against, private insurances companies, private construction contractors, the State of Texas and the “United States of America”, dating back to the exact time frame firstly in the year of 1997

Starting in the business namely “G & G Services” another fraudulent

monetary massive medical business scheme of things against elderly seniors for over (13) years in “hidden monetary assets gains” throughout 2010 committed to within Jefferson County Texas.

As already being legally described in Pro Se Plaintiff exhibit (E) and (F) on file with the U.S. Clerk office in the file before the Honorable U.S. Justice “Magistrate”.

35.

To include but not limited to Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein fully conscious with willful intent direction, leadership, conspire, collaborated with the Co-Defendant(s) “Joyce M. Guy and Edward McCray collectively herein

And fully paid, retain, and directed to hinder, conceal, obstruct, hide, destroy, ruse, cover up, fake and make a fool of Pro Se Plaintiff civil rights to Constitution Laws of the State of Texas namely

Article 16: “General Provisions” Section 37 provides for constitutional protection of the “mechanic’s lien” against Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein

Which Defendant and Co-Defendant(s) collectively in furtherance’s (RICO) enterprise execute efforts, conspire, hinder, obstruct, and full derailment of Pro Se Plaintiff civil rights to Constitution Laws of the State of Texas namely

Article 16: “General Provisions” Section (50) provides for protection of homestead against force sales to pay debts, except for foreclosure on debts related to the homestead (mortgage, taxes, mechanic’s liens, and home equity loans).

In connection with the property located at 448 DeQueen Blvd. in Port Arthur Texas being a direct party to said civil suit in common law for breach of construction contract and actual fraud derive thereof.

36.


24058299 Fully Committed to among other things Conspiracies together to

pursue the same Criminal (RICO) “Racketeer Influenced and Corrupt

Organizations Act”, of said Co-Defendant(s) “Joyce M. Guy and Edward McCray”

in the execution, and direct usage of

“Obstruction of Justice” in the capacity as an “Officer of the Court” and

“Attorney of Law” for the State of Texas to commit and conspire to the same

causes of all (RICO) enterprise past, present and future “acts and actions” in

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

collectively herein

Fully described herein such acts and actions being unjust against the Pro Se Plaintiff,

While Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein further willfully Omitting, concealment, containment, obstruction and Destruction thereof

“Material Civil Evidences and all Material Subject Matter Facts” on its way presented before a ongoing “Civil Suit” in Common Law in Jefferson County Texas 58th Judicial District

With “among other things” Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Actual Fraud, upon the

“Texas Department of Housing & Community Affairs” Jefferson County Texas and Federal Grants derived thereof in Connection with the Pro Se Plaintiff “Louis Charles Hamilton II” herein private capacity as a “Independent Construction Contractor”

With “among other things” Chief Defendant Antoine L. Freeman J. D.

Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy”

and “Edward McCray” herein conspire, cover up, of Actual events of Fraud of

Insurance Companies”, for primary fraud during “Hurricane “Rita”, “Ike” and

“Humberto ” related Construction storm damages, in connection with the Pro Se

Plaintiff Louis Charles Hamilton II herein.

37.

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


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

doctrine documents derive thereof;

And all known communications between “Attorney and Client”

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

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

“Honorable 58th Judicial District Court” from having any “Legal Knowledge Via

Pro Se Plaintiff herein “direct discovery request” and all “Investigation” derive

thereof fully focus on among other things Co-Defendant(s) “Joyce Guy and

Edward McCray”

Collectively in the past did in fact submit numerous Hurricane disaster

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

with the Pro Se Plaintiff being a party to (2) such estimates to their “Insurance

Companies” and possibly FEMA for relief of damages caused by Hurricanes Rita,

Humberto, and Ike for the property located at 448 DeQueen blvd. in Port

Arthur, Texas.

To include also for Property located at 5050 east 7th Street in Port Arthur

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

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

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

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

fraudulent “practice and patterns” thereof.

38.

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


24058299 herein also having “insider information and communications” with

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

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

“Material evidence” that Co-Defendant(s) “Joyce Guy and Edward

McCray” was in fact in the legal process of having the old Home torn down

while the ongoing civil actions was still pending before the 58th District Court of

Jefferson County Texas to include Co-Defendant(s) “Joyce Guy and Edward

McCray”

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

$72,500.00 U.S. Dollars on a “Federal Grant” kept 100% secret from the Pro Se

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

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

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

Texas Bar No. 24058299 herein confirm and described in Pro Se Plaintiff First Set

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

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

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

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

Affairs”

39.

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

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

fraudulent claims before said “Texas Department of Housing & Community

Affairs” that Pro Se Plaintiff was the primary cause of damages to the old home

derive thereof for Co- Defendant(s)

“Joyce Guy and Edward McCray” needing a “New Home” based upon

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

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

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

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

40.


“Honorable Justice” Co-Defendant(s) collectively herein usage of this same

(RICO) enterprise fraudulent tactic, scheme, sham, plot and plans premeditated

being done to the Pro Se Plaintiff against other innocent independent

construction contractors and

Private homeowner insurances companies to obtain other mutable

fraudulent monetary assets after storm damages of Hurricane Rita, Humberto

and Ike to the said property(s) located at 448 DeQueen Blvd. in Port Arthur

Texas 77640 and 5050 east 7th street in Port Arthur Texas 77640

41.


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

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

County Clerk Office File #2009022763

To obtain from “Texas Department of Housing & Community Affairs”

$72,500.00 on a “Federal Grant” as the secretly destruction of the older home

took place during this ongoing “Civil Suit”

42.


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

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

and the destruction of the older one and all circumstance involved thereof being

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

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

To achieve the same fraudulently (RICO) enterprise monetary objective(s)

gain being $72,500.00 “New Home” on a “Federal Grant” shamefully submitted

Before the “Texas Department of Housing & Community Affairs” by Co-

Defendant(s) after already “Greedy Squandering” all of the Numerous Insurance

Funding” from each previously Hurricane “Rita”, “Humberto”, and “IKE” related

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

Texas.



Texas Bar No. 24058299 herein had a fiduciary duty to disclose all material facts

as described herein and regardless of his “Attorney/Client defense of the Co-

Defendant(s)


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

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

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

upon the Co-Defendant “Joyce M. Guy and Edward McCray numerous

fraudulent acts and actions discovery of a shocking further investigation

involving “among other things” the actual designed “Fraud of Contractors”

related to “Insurance Company” Scams and scheme of things the Co-

Defendant(s) monetary calculated and concocted during Hurricane “Rita”, “Ike”

and “Humberto”.

43.


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

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

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

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

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

24058299 was retain to commit to numerous fraudulent acts and actions

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

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

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

instituted by the Co-Defendant(s) .

44.


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

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

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

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

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

records #72594

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

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

Scrap Industry”

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

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

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

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

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

77640

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

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

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

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

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

rate of

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

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

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

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

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

endeavor.

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

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

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

Industry”.

45.


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

Law” herein at the very start clearly in December 18th of 2007 was engaging in

Professional Skills of a Attorney at Law” in a “Legal” ongoing court room

obligations to defend this civil case A-180805 against Pro Se Plaintiff

Chief Defendant (Attorney at Law) herein committed to Fraud upon the

58th Judicial District Court claiming in a documents filed by “Chief Defendant his

only legal job was to draft a (Simple) General denial on behalf of the Co-

Defendants “Joyce M. Guy and Edward McCray which was filed on December

18th 2007, as such to avoid a default on behalf of Co-Defendant(s) collectively by

filing his “Chief Defendant (Attorney at Law)”

Original Answer and at that point his “Fiduciary Duty” to his clients Co-

Defendant(s) “Joyce M. Guy and Edward McCray and before the 58th Judicial

District Court ended on that date December 18th 2007 thereafter and was legally

completely over,

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

before the “Honorable Justice” this is not the case at hand as chief Defendant

(Attorney at Law) herein Fully scuttles, hidden, obscured, and conspire in the

destruction all discovery materials and material evidence received from

Plaintiff in this civil matter from

December 18th 2007- November 13th 2009 being the official day clients Co-

Defendant(s) “Joyce M. Guy and Edward McCray and Chief Defendant Antoine L.

Freeman J. D. (Attorney at Law) (Active) in and for the State of Texas Bar No.

24058299 fully in possession, custody, control, and combine knowledge thereof

Pro Plaintiff request for production of Documents, Interrogatories, and

request for admission and to disclose Pursuant to Rule 194 during the entire

year of 2008-2009 Chief Defendant Antoine L. Freeman, J.D. “Attorney at Law”

herein fail well above and beyond (30) days of this request, for the discovery

information or material described by a period of over (2) years past the (30)

days requirement to answer not only Pro Se Plaintiff “Request to Disclose”

Pursuant to Rule 194,

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

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

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

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

Chief Defendant a skilled (Attorney at Law)

Having such full knowledge that a discovery phase process had

commence in this civil legal matter and simply (RICO) monetary retain to 100%

refusal to submit any “response or reply” to all said required discovery request

for a period exceeding (1) year and (11) Months and Pro Se Plaintiff Filed

“Motion for sanctions” against said Chief Defendant (Attorney at Law) in

violation of Rule 193.1 of the Texas Rules of Civil Procedure.

46.

Chief Defendant (Attorney at Law) in his defense of Pro Se Plaintiff

motion for Sanctions committed to the Following further Fraudulent activities

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

records derive thereof.

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

a fraudulent Affidavit in Support of Chief Defendant (Attorney at Law)

dated September 11, 2009

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

the same act of having this fraudulent document “Subscribed and

Sworn on the 11th day of September 2009

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

this to be 100% false and fraudulent describing event of April 2nd, 2008

and April 11th, 2008 in connection with Pro Se Plaintiff discovery

request.

47.


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

Defendant (Attorney at Law) fraudulent informed Co-Defendant(Guy) between

April 2nd, 2008 and April 11th, 2008 about Pro Se Plaintiff “Discovery Request”

providing proof that Chief Defendant (Attorney at Law) was in fact in

possession, custody, and control of said discovery request while representing to

the “Honorable Court” this was not the case when said legal possession,

custody, and control commenced March 14th 2008.

48.

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

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

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

McCray”, there after filing “the original answer” with the

58th Judicial District Court back in December 18th of 2007 when Chief

Defendant (Attorney at Law) herein in fact fraudulent stating having Pro Se

Plaintiff Discovery in Chief Defendant own Affidavit being in his possession,

custody and legal control as of April 2nd, 2008 and April 11th, 2008.

49.


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

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

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

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

him as described herein this complaint.,”

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

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

Bar No. 24058299 did in fact make a court appearance in a hearing the Pro Se

“set” before the Honorable 58th District Court on the 28th day of August 2008

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

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

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

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

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

Defendant (Guy) having process the same

(RICO) enterprise “scheme and scam” of things regarding Private

Insurance, Construction Contract estimates and contracts of the Pro Se Plaintiff

herein, FEMA roofing repair funds, and all fraudulent scheme against the

property located at 5050 East 7th street in Port Arthur Texas being Norma Guy

Home Mother of the Co-Defendant (Joyce M. Guy) whom Norma Guy is dead

now and Co-Defendant “Joyce M Guy and Edward McCray” collectively in 2015

time frame having direct legal possession, custody and control over (2) real-

estate sham in excess of $127,339.31 involving the Pro Se Plaintiff as a unwilling

party and victim thereof.

50.

Chief Defendant (Attorney at Law) Antoine L. Freeman J. D. (Attorney at

Law) Texas Bar No. 24058299 herein physically argued this issue of a (TRO)

alone before the Honorable Judge Bob Wortham, and the 58th Judicial District

Court of Jefferson County Texas on August 28th 2009

And Chief Defendant (Attorney at Law) Antoine L. Freeman J. D. (Attorney

at Law) Texas Bar No. 24058299 herein also foolishly claiming in Court

document(s) filed with the U.S. Clerk office as exhibit (B) and presently in the

records and files before the U.S. Justice Magistrate that he said Chief Defendant

(Attorney at Law) herein was never even present there at said hearing or

physically being the acting Attorney of record on said hearing date of August

28th 2009 before the 58th Judicial District Court of Jefferson County Texas

While at this time frame of hearing date August 28th 2009 at no time was

Chief Defendant herein not acting in the capacity as “Attorney of Record” at

said August 28th 2009 hearing date to include but not limited to from the time of

filing of his notice of counsel and original answer on December 18th 2007 until

Chief Defendant (Attorney at Law) filed a Motion to withdraw as Attorney of

Record in November of 2009.


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

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

timely reply, or file any type motion for withdrawal notice with the 58th Judicial

District Court during this 16 Months time period while Texas Rules of Civil

Procedure require he so do which all of this was to advance such (RICO)

enterprise endeavor as

Chief Defendant a professional Attorney at Law required to Adhere to

local rules of the Texas Court System and reply within (30) days later not on a

time table of (16) months later after mailing service of Said Discovery request by

Pro Se Plaintiff Louis Charles Hamilton II on March 14th 2008.

51.


“Honorable Justice” Chief Defendant (Attorney at Law) herein, further then took

a even bolder set in “Obstruction of Justice” in that after in excess of (16)

months of scuttling Pro Se Plaintiff Discovery request to further aid, obscure,

conceal, and Hide all of the corruption going on at present time frame engaged

further in the direct

Destruction of the old home being physical evidence in civil suit in

common law and the new one being built, secretly during this ongoing Civil Suit

and all of the inquiries being made by the Pro Se Plaintiff regarding Fraud

relating to Insurance Companies, Former Contractors, and Hurricane “Rita”,

“Ike” and “Humberto”.

Chief Defendant (Attorney at Law) herein conspire with Co-Defendant(s)

“Joyce M. Guy” and Edward McCray to provided further Fraud upon the 58 th

Judicial District Court in Fraudulent Information in the Interrogatories claims

against the Pro Se Plaintiff construction tools and being in possession theft of

personal thereof, and Never Investigated the circumstances of the questions

being raised surrounding the “Theft” of The Pro Se Plaintiff Construction Tools

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

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

Defendant(s) collective wrong doings from the Honorable Court per Pro Se

Plaintiff Discovery Request being scuttled for (16) months time frame as being

described in this Amend Complaint.

52.

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

where ever on the property of the Pro Se Plaintiff being complain of

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

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

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

delivery all of Pro Se Plaintiff said in excess of

$3000.00 U.S. Dollars in construction tools to the dwelling in his Truck to

the Home of The Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” on

November 16th 2007. Defendant (Attorney at Law) did not Investigate any of

these facts nor was he ever even concern to attempt to investigate into the

issues of the were about of Pro Se Plaintiff Construction tools.

53.


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

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

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

when Chief Defendant (Attorney at Law) herein filed with the Clerk of Court of

Jefferson County Texas a Motion for Withdrawal of Counsel

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

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

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

and enforced as Follows:

54.

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

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

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

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

55.

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

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

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

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

Blvd. in Port Arthur, Texas.

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

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

56.


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

remain in Hostile abscond scuttle refusal of the Honorable 58th Judicial District

Court Order as of the undersigned date in the Month of February 2015 of this

Amend Complaint being refilled in U.S. District Court.

57.


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

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

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

of 16 months in possession thereof

To include Chief Defendant (Attorney at Law) herein unethical

commitment to (RICO) enterprise conspires further under the disguise of

“Attorney/Client” privileges.

Work Product doctrine, and all Communications derive thereof being

secrete between the Chief Defendant (Attorney at Law) and the Co-

Defendant(s) “Joyce Guy and Edward McCray” collectively herein

To the point such Fraud committed by the Chief Defendant (Attorney at

Law) herein on the Jefferson County 58th Judicial District Court in Texas

completely forced the Pro Se Plaintiff to be at an extreme “civil disadvantage” in

the ongoing court proceeding in the time frame of 2007-2009 and present in the

time frame throughout 2015

Based solely upon Chief Defendant (Attorney at Law) Rouge monetary

high dollars retain (RICO) “obstruction of Justice” leadership, direction among

other things being fully a professional hire “Legal Gun” knowledge thereof to

scuttle, omit, delay, obstruct, destroy, concealment,

Containment, and fraudulently mishandling required duties to supply a

honest, required respond to all of Pro Se Plaintiff discovery request in a timely

fashion, within the (16) months being in possession, custody and control of said

Pro Se Plaintiff Discovery request.

58.



Texas Bar No. 24058299 retainer fees was solely paid to keep the Co-

Defendant(s) “Joyce M. Guy and Edward McCray” numerous discover (RICO)

enterprise fraud discovery by the Pro Se Plaintiff herein absolutely 100% top

secret from the 58th Judicial Court”

While the other newer $72,500.00 U.S. Dollars and the newer $54,839.31

“scheme of things” being in current play and process to now a ongoing

(RICO) fraud monetary scheme of things the Co-Defendant(s) “Joyce M. Guy and

Edward McCray” concocted involving Fraud (Now) against The “Texas

Department of Housing & Community Affairs” issuance of a “Housing Grant” in

favor for the Co- Defendant(s) “Joyce Guy and Edward McCray”

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

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

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

conspire to keep this under wraps from any financial setback glitches being fully

caused by The Pro Se Plaintiff Louis Charles Hamilton II bring this additional

Fraudulent activities before The Honorable 58th Judicial District Court of

Jefferson County Texas well deserved attention.

59.



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

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

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

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

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

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

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

193.1

60.

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

further before the “Honorable Justice” solely done by Chief Defendant

(Attorney at Law) (Only) to conspire in the illegal (RICO) enterprise aid to hide,

conceal, destroy, obstruct in concert of all of the Co-Defendant(s) “Joy M. Guy”

and “Edward McCray” many corrupted Business Enterprises endeavors,

Mutable Counts of Fraudulent past, present and future “pattern and

practices” activities involving Hurricane “Rita”, “Ike” and Humberto” with its

Monetary rip off scams and schemes against FEMA, Building Contractors

estimate and invoices and Home Owner Insurances Companies repair funds

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

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

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

Community Affairs” in excess of $72,500.00 U.S. Dollars and $54,839.31 U.S.

Dollars for a combine total additional (RICO) enterprise sham of in excess of

$127,339.31 involving the Pro Se Plaintiff as a unwilling party and victim thereof

Couple in providing with Pro Se Plaintiff combines actual damages

suffrage in excess of $336,000.00 U.S. Dollars, lost earning and earning capacity,

Breach of Construction Contract of $10,800.00, additional scam in a

Construction contract for property located at 5050 east 7 th street in Port Arthur

Texas 77640, and $3,800 theft of personal property (Construction tools) for


24058299

And Co-Defendant(s) “Joyce M. Guy and Edward McCray” ongoing (RICO)

enterprise endeavor against the Pro Se Plaintiff Louis Charles Hamilton II herein

Civil Rights, Peace and dignity in excess of $467,139.31 U.S. Dollars.

61.

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

consciousness mind and disregard for the consequences for his actions in the

“capacity as an Attorney of Law”, Antoine L. Freeman J. D. conspire to continue

to use his legal lawyer skills” in the full “aid and abetting”, and commitment to

“Obstruction of Justice” in the capacity of a

Attorney at Law forthwith in providing his own numerous Attorney fraud

legal commitment documentations upon the 58th Judicial District of Court of

Jefferson County Texas, the Court records thereof as being fully described in this

U.S. District Court Amend Complaint of the Pro Se Plaintiff.

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

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

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

“ill-gotten pirate loot” from the “past”

Hurricanes Seasons “Rita”, Ike” and “Humberto” and “present and future”

pirate loot” of (2) “Federal Housing Grant” on the behalf of “Texas Department

of Housing & Community Affairs”

Awarding Federal Agency: “United States Department of Housing and

Urban Development” in excess of $72,500.00 U.S. Dollars, and $54,839.31 of the

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

acquisitions earning since past (RICO) enterprise endeavors as described since

activated in such monetary corruption starting legally in 1997.

62.

Fully affecting the Pro Se Plaintiff (Life) with “among other things” cause of action for “actual damages” being in excess of $336,000.00 U.S. Dollars in “lost wages” from 2007 – 2014 and lost profit in excess of $7000.00 of the $10,800 Breach of Construction contract, lost of profits in the sham & scheme against the property located at 448 DeQueen Blvd. in Port Arthur Texas

With also “actual damages” in excess of “3093.00 U.S. Dollars causing lost

wages and lost earning capacity in all of the Pro Se Plaintiff Construction tools: as described in “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.

63.

Notwithstanding causing the Pro Se Plaintiff undue unwanted extreme

hardship, infliction of emotional distress and anguish in the “Theft of Pro Se

Construction Profession” for a ongoing time frame over (7) years and still

counting well into 2015

The Texas State Civil Suit is “Live” and ongoing due in large part to Chief

Defendant (Attorney at Law) herein

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

things” a complete assault of “Obstruction of Justice” and “Fraud upon a Court”

in the 58th Judicial District Court District of Jefferson County Texas

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

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

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

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

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

64.



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

“Fraudulent Activities” upon the Pro Se Plaintiff civil suit and fraud of the

58th Judicial District Court of Jefferson County Texas for the full benefit of hiding

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

To include “among other things” numerous corruption activities with the

usage of the fraudulent scheme of things in usage of the “United States Mailing

System” to further long this fraudulent (RICO) enterprise “scheme of things”

before a “Honorable 58th Judicial District Court of Law” within the State of Texas

and further long this fraudulent

(RICO) enterprise “scheme of things” against the State of Texas and The

United States of America Housing grant program while all also being direct

against the Pro Se Plaintiff Louis Charles Hamilton II as being described herein

this amend complaint.

65.



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

Guy” and “Edward McCray” described

(RICO) enterprise past, present and future corruption(s) and fraudulent

activities with the usage of among other things the “United States Mailing

System” to further long this

(RICO) enterprise fraudulent “scheme of things” before a “Honorable 58th

Judicial District Court of Law” within the State of Texas and further long this

“civil scheme” conspire 100% against the Pro Se Plaintiff “seventh” Amendment

right of the Constitution of The United States of America and the State of Texas

Constitutional rights as being fully described herein this amend complaint.

66.



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

that he further conspire to and did in all facts and circumstances

“Facilitate” provide concealment in court documentations, and evade

Justice from the time frame of 2007-2015 for all of the Co-Defendant(s) “Joyce

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

activities” with the usage of the Jefferson County “Clerk of Court” Office

Computer System, electronic records, and filing system thereof to further long

this fraudulent “scheme of things”

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

long this “civil scheme” against the Pro Se Plaintiff civil rights in a suit in

common law as being described herein this amend complaint.

67.



Texas Bar No. 24058299 herein fully “facilitate” and engage further in the usage

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

interest of Co-Defendant(s)

“Edward McCray and Joyce M. Guy” to stop, conceal and hinder,

providing representation and presentation as acting attorney of record to cause

Pro Se Plaintiff from rightfully not being involved in said discovery request, so

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

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

“Edward McCray” in the civil suit in State Court docket No. A-180805.

68.


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

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

substandard Construction Contractor and

Pro Se Plaintiff is the reasoning for the older home located at 448

DeQueen Blvd. in Port Arthur Texas being demolished for providing faulty

contractor structural work and repairs being unskillfully provided by Pro Se

Plaintiff herein in connection with the $10,800.00 U.S. Dollars “Breach of

Construction Contract” issues still ongoing in 2015.

69.


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

the defamation of the Pro Se Plaintiff substandard construction performance

tactics with their previously Home Owner Insurance Company to satisfied any

suspicion concerning the $10,800.00 dollars already wrongfully (RICO)

enterprise squander by said Co-Defendant(s) “Joyce M. Guy and Edward

McCray” herein.

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

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

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

being a substandard contractor in construction performance

By providing faulty contractor structural work and repairs skills to the

dwelling of 448 DeQueen and Pro se Plaintiff being directly responsible for the

need of destruction of the old dwelling thereof in Port Arthur Texas

In order through this same wrongful scheme of defamation against the

Pro Se Plaintiff contractor skills to obtain further a New Home with this (RICO)

enterprise “scheme of things” being done directly against

“Texas Department of Housing and Community affairs” Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005




United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007 in obtaining the already total of $72,500.00 U.S Dollars

As being described in Pro Se Plaintiff exhibit (Q) on file with the U.S. Clerk

office Namely “Mechanic’s Lien Contract” SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060

70.



Texas Bar No. 24058299 herein “facilitate” to conspire in concert in the same

defamation against the Pro Se Plaintiff reputation as being a dishonest,

unskilled, substandard Construction Contractor and Pro Se Plaintiff is the direct

reasoning for the older home located at 448 DeQueen Blvd. in Port Arthur Texas

being torn down and a new one being built.

71.


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

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

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

“Ensnare” Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar

No. 24058299 herein in his “Legal Capacities” as a “Attorney at Law”

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

County Texas for the (RICO) enterprise purpose of “delays”, “concealment”,

obstruction, “omitting” and “hindering” all material facts, accounts, material

circumstances, events, both being now past, present, and future monetary gain

of the Co-Defendant(s) collective “corrupted enterprise activates”

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

before the “Honorable Justice” of making numerous complaints thereof in Court

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

Services into the elderly

As well as all “secrete Pro Se Plaintiff discovery investigations” Pro Se

Plaintiff was pursuing presently during said State Court Civil Complaint involving

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

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

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

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


24058299 herein in his

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

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

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

Plaintiff Discovery request

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

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

committed against The Pro Se Plaintiff, and the monetary scheme of things

against said Federal and State Community Housing Grant

(RICO) collective scheme of things 58th Judicial District Court of Jefferson

County Texas, Private Insurances Companies, State of Texas, and The United

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

Monetary Gain” of said Co-Defendant(s)

“Joyce M. Guy and Edward McCray collectively “rip off” scheme activities

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

State Federal Court having subject jurisdiction matter over the” Defendant and

Co-Defendant(s)” collectively.

72.

Pro Se Plaintiff, Declare, Affirm, and State before the “Honorable Justice”

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

Claims that he was “not legally retained” 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 but was physically present in the capacity as “acting attorney of record”

While Chief 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 March 14th 2008

And Chief 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 Chief 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 Chief Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein did in all 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 already on file with the U.S. Clerk as Pro Se Plaintiff Exhibit (F)

73.

Pro Se Plaintiff, Declares, Affirm, and State further before the “Honorable Justice” Chief Defendant himself Antoine L. Freeman J. D. (Attorney at Law) herein legally was acting as (RICO) enterprise “Attorney of Record” on or about the dates of August 28th 2009 and September 11th 2009 “Live” court hearing dates

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

Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) claiming of not being the actual legal counsel of representation/presentation of said civil suit No. A-180805 on or about the same said dates of August 28th 2009 and September 11th 2009 “Live” court hearing dates

74.

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

and throughout their “Attorney of Record” being Chief Defendant (Attorney at

Law) herein himself complex conspire together with the additional ongoing

fraudulent activities of pirate loot” of (2) “Federal Housing Grant” on the behalf

of “Texas Department of Housing & Community Affairs”

Awarding Federal Agency: “United States Department of Housing and Urban Development” in excess of $72,500.00 U.S. Dollars, and $54,839.31 of the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” (RICO) gradually acquisitions earning since past (RICO) enterprise endeavors as described since activated in such monetary corruption starting legally in 1997

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 $72,500.00 Federal Housing Grant, as being described in “Jefferson County Texas Property Search Index” and Pro Se Plaintiff exhibit (Q) already on file with the U. S. Clerk

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

June 18th 2009 while involved in this (RICO) activities 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 $72,500.00 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 the 58th Judicial District Court of Jefferson County Texas “Court Order” to for Co-Defendant(s) “Joyce M. Guy and Edward McCray” collectively herein to produce among other such “Honorable 58th Judicial District Court” of Jefferson County Texas orders such

“Property Deeds” to said Property located at 448 DeQueen Blvd. in Port

Arthur Texas (Block) 172, (Lot) 1-2 well into 2015 being (RICO) enterprise obstruction of justice, concealment, hidden and hinder in this scheme of things still in no compliance from first and foremost “Chief Defendant Attorney at Law” herein from

March 14th 2008- November 2009 and Co-Defendant(s) collectively

throughout the present time frame in this undersigned date in 2015 When this Pro Se Plaintiff Louis Charles Hamilton II required discover

subject matter into property deeds was legally request and required to be produced on exact date of March 14th 2008.

76.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. 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

(RICO) scheme of things in the direct refusal of the actual request in

discover request dated back in March 14th 2008 with a Court Order further

following for such a Production of said “property deeds” now being Pro Se Plaintiff exhibit (L) already on file with the U.S. Clerk office dated May 10th 2010 notwithstanding factual events and circumstances said

Property deeds being officially “free and clear” from the “Texas

Department of Housing and Community affairs” United States Department of Housing and Urban Development Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005 as filed and recorded April 22nd 2014 at 12:38 pm

As described in Pro Se Plaintiff exhibit (T) already on file with the U.S. Clerk office namely “Property Deeds” of the Co-Defendant(s) Joyce M. Guy and Edward McCray” herein dated April 22nd 2014for the dwelling located at 448 DeQueen Blvd in Port Arthur Texas

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

fraudulent “Financing Statement” dated June 18th 10:20 am filed as Pro Se Plaintiff exhibit (U) already on file with the U.S. Clerk office

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

Termination of Fraudulent Financing Statement Amendment dated July 22nd 2013 2:01 pm filed as Pro Se Plaintiff exhibit (V) already on file with the U.S. Clerk office

78. Which Pro Se Plaintiff being further set forth Declares, Affirm, and State

further before the “Honorable U.S. 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

further (RICO) scheme of things is involved in not being honest and providing full disclosure all of the actual Business being owned and all income derive thereof

“Namely” G & G services and E and J collectable, J Can Company, Cars and Pieces, Paragon Business Inc, in order to obtain fraudulent from the “Texas Department of Housing and Community affairs” and” United States Department of Housing and Urban Development said Loan No. 2727 File No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005 in excess of $72,500.00

Being directly in violation of 18 U.S.C. § 1001: US Code - Section 1001: Statements or entries generally




(3) makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;

With this whole “Dreamy (RICO) enterprise endeavor furtherance directly in violation of the same 18 U.S.C. § 1001: US Code - Section 1001: for such grand “Chief Defendant” (Attorney at Law) grand (RICO) enterprise wizard materially false, fictitious, and fraudulent statement(s) and fraudulent representation upon the

58th Judicial District Court of Jefferson County Texas to pursue the same (RICO) monetary enterprise object(s) of the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively, past, presently, and future beyond December 2015, scam, schemes and racket life style.

79.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. 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 further continue

In this well designed (RICO) “Scheme of things” involved in concealing,

obscuring, masking, cloak and shielding corrupted fraudulent “mutable fraudulent business” enterprise operations the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” herein concoct and obtaining massive hidden income over many years and presently described as follows:

A. Assumed name business “G & G Services” a fraudulent Medical services for obtain “monetary payments” from “Senior Aging Handicap Citizens within Jefferson County Texas which “G & G Services” was never even a litigable Licenses with the State of Texas from May 2nd 1997- 2010 as being order shut down as described in Pro Se Plaintiff exhibit (F) already on file with the U.S. Clerk office from the Texas Department of Aging and Disability Services. *to include but not limited to “Tax Evasion” being directed at both the “State of Texas” and “The United States of America” for a actual time period of (13) plus years in this (RICO) illegal medical business operation fraudulent corrupted “scheme of things”. To include but not limited to upon information and belief “G & G Services” medical services is secretly still in business operation …….Omg (wow)


C. Assumed name business “E and J Collectibles” 448 DeQueen Blvd. in Port Arthur Texas which is in the Used Merchandise Stores business for a unknown amount of years having (2) companies in Port Arthur Texas “However” these (2) companies is not registries with “Jefferson County Texas, or the “State of Texas” fully engaging in among other things (RICO) enterprise in “Sales Tax Evasion”, *Business is current in operation as identified on the “internet” for a unknown accountability of time.

D. While “E and J Collectibles” income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

E. Assumed Name J Can Company in Port Arthur Texas business operation from April 11th 2008 – 2015 this J Can Company business operation is a “front company” for (RICO) enterprise scheme of things in “among other things” besides hidden sells of “Crack cocaine” while actually engaging in (RICO) enterprise in “money laundering” in scrap metal materials” in connection with assumed name business “Cars and Pieces”

F. Another “front company” located in Beaumont Texas. To include but not limited to J Can Company business operation and “Cars and Pieces” business operation (RICO) enterprise in State and Federal Tax Evasion.





80.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State

further before the “Honorable U.S. Justice” Chief 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 continue to engage in among

other things “obstruction of Justice” collaboration, racket, and monetary cover

up

Plot in their collective (RICO) enterprise “defense” the direct refusal to

produce among other things said 58th Judicial District “Court Order” for

discovery of the “property deeds”, and all records involved in Hurricane “Rita,

Humberto, and Ike, in connection with the dwelling located at 448

DeQueen Blvd. in Port Arthur Texas as of this undersigned date in 2015.

And ruse, dodge, concealing, withholding, destroying, masking, obscuring

all past, property deeds, banking records, contractor(s) construction insurances

estimates and contract(s) for (5)-(6) hurricane storm damages claims,

homeowner private insurance records,

FEMA records, (4)-(6) mutable private illegal business company records,

Texas Department of Housing and Community Affairs housing records materially

false, fictitious, and fraudulent statement and representation being made in

such records at the

“Texas Department of Housing and Community affairs” and ” United

States Department of Housing and Urban Development

To include but not limited to all State Tax Records, Sales Tax records, (IRS)

Tax Records and any and all document(s) relating to any discovery into the

corrupted (RICO) enterprise endeavor fully executed since the time exact frame

of 1997-2015 as being legally described by the Pro Se Plaintiff “Louis Charles

Hamilton II” herein.

81.

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

No. 24058299 with legal intent to bring Pro Se Plaintiff “Civil Suit” in Common

Law A-180805 to a full collapse lost civil cause of action in a well plan, visionary

clever skilled lawyer strategy scheme to “first and foremost” make the bogus

(RICO) fraudulent “representation and presentation”

As acting “attorney of record” for the legal behalf of the Co-Defendant(s)

“Joyce M. Guy and Edward McCray collectively to fool, hinder, obstruct, and

hamper the Pro Se Plaintiff civil suit in common law within the State of Texas

docket No. A-180805

While at the same time frame Chief Defendant Antoine L. Freeman J. D.

(Attorney at Law) Texas Bar No. 24058299 herein making the same bogus (RICO)

fraudulent “representation and presentation”

As being not the acting “attorney of record” fraudulent appearing above

the law before the Honorable 58th Judicial District Court of Jefferson County

Texas in direct violation in “among other things”

Pro Se Plaintiff full citizenship of the United States of America and

Military Veteran entitlement of the Seventh Amendment of the United States of

America, Permanently Disable Veteran protected under:

(ADA) American with Disability Act; And also minorities persons cover

under Title VII of the Civil Rights Act of 1964; and all full citizenship entitlement

of the Seventh Amendment in connection with the State of Texas Constitution,

Article 16: "General Provisions" Section 37 provides for the constitutional

protection of the mechanic's lien, and Section 50 provides for protection of a

homestead against forced sale to pay debts,

Except for foreclosure on debts related to the homestead (mortgage,

taxes, mechanic's liens, and home equity loans). Pro Se Plaintiff Louis Charles

Hamilton II Being Domiciliary State of Texas, P.O. Box 17524 Sugar Land, Texas

77496

To Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar

No. 24058299 execute withholding all discovery as now being escalated as

described of the Grand (RICO) enterprise “scheme of things” involving the Pro

Plaintiff alone in a sham in excess of $127,339.31 scam of (2) U.S. Federal

Housing Grant.

82.

Couple in providing with Pro Se Plaintiff combines actual damages

suffrage in excess of $336,000.00 U.S. Dollars, lost earning and earning capacity,

Breach of Construction Contract of $10,800.00, additional scam in a

Construction contract for property located at 5050 east 7 th street in Port Arthur

Texas 77640, and $3,800 theft of personal property (Construction tools) for


24058299

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

conspire concert crafty 2015 ongoing (RICO) enterprise endeavor against the Pro

Se Plaintiff Louis Charles Hamilton II herein Civil Rights, Peace, personal

property and dignity in excess of $477,939.31 U.S. Dollars.

83.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein

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DATE & TIME STATUS OF ITEM LOCATION

January 29, 2015 , 10:53 am

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PORT ARTHUR, TX 77640

We attempted to deliver your item at 10:53 am on January 29, 2015 in PORT ARTHUR, TX 77640 and a notice was left because an authorized recipient was not available. You may arrange redelivery by visiting

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January 29, 2015 , 8:29 am

Out for Delivery PORT ARTHUR, TX 77640

January 29, 2015 , 8:19 am

Sorting Complete PORT ARTHUR, TX 77640

January 29, 2015 , 7:15 am

Arrived at Unit PORT ARTHUR, TX 77640

January 29, 2015 , 6:34 am

Departed USPS Facility BEAUMONT, TX 77707

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DATE & TIME STATUS OF ITEM LOCATION

January 29, 2015 , 4:15 am

Arrived at USPS Origin Facility

BEAUMONT, TX 77707

January 28, 2015 , 10:37 pm

Arrived at USPS Origin Facility

NORTH HOUSTON, TX 77315

January 28, 2015 , 10:09 am

Acceptance SUGAR LAND, TX 77479

Flat out in refusal to except any “certified Mail” from this particular Pro Se Plaintiff Louis Charles Hamilton II in the State Court action A-180805 on January 29, 2015, 10:53 am as being described Tracking Number: 70092820000295595205

For a “Writ of Attachment”, Summary Judgment, Contempt of Court

hearing being held on the 19th day of February 2015 before the 58th Judicial

District Court of Jefferson County Texas at 9:00 am hr.

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

herein in 2015 again with such grand scuttle plans, to hide, melt, destroy,

conceal, ruse, scheme, dodge, all records, or being a party thereof in this grand

(RICO) scheme of things involving not only the Plaintiff but the entire “United

States of America”

And “The State of Texas” in a half bake (RICO) combine “greedy racket

enterprise” scheme of things that has accumulated gradually past acquisition of

hidden (RICO) monetary earnings cars, possessions and mutable properties

estimates in excess of $980,000.00 U.S. dollars from the direct time frame of

1997-2015

And to include but not limited to the Grand (RICO) scheme of things

involving the Pro Plaintiff Louis Charles Hamilton II herein alone in excess

$127,339.31 monetary scam of (2) U.S. Federal Housing Grant in his Private

Profession as a “Independent Construction Contract” since date of injury being

in the year of 2007.

84.

Chief Defendant Attorney at Law herein and the Co- Defendant Joyce M. Guy” herein supply the following Answer to Pro Se Plaintiff Interrogatories Discovery Document pursuant to Rule 197 of the Texas Rules of Civil Procedures at Question: 10, 11, 12, 13, 14, 15, and 16.

10. Where is the Funding for the New Home?

Answer: Federal Grant

11. What are the terms and conditions of any contract in regards to the new home?

Answer: Federal Government built home free of charge Defendant must remain in home for at least 3 years.

12. What is the entire cost of the construction for the new home?

Answer: $76,000.00 U.S. Dollars

13. How is the city of Port Arthur Involved?

Answer: Not involved

14. How is the State of Texas Involved?

Answer: Not Involved

15. How is the Federal Government involved?

Answer: Federal Grant

16. How much money did the Co-Defendant actually paid for the new home construction?

Answer: No money paid by Co-Defendant

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Chief Defendant “Attorney at Law” herein and the Co- Defendant

Joyce M. Guy” and Edward McCray collectively herein supply the following “false and fraudulent” Answer to Pro Se Plaintiff Interrogatories at question number 14

14. How is the State of Texas Involved?

Answer: Not Involved

In comparison to said “Property Deeds” for the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas of the Co-Defendant(s) “Joyce M. Guy and Edward McCray herein collectively custody, control and legal possession was Legally Transfer to the

“Texas Department of Housing & Community Affairs” on June 18 th 2009 for a $72,500.00 U. S. Dollars Housing Grant.

. And further that Documents along with the fraudulent Affidavit of Co- Defendant Joyce M. Guy” herein supply the following “false and fraudulent” Answer to in regards to possession, custody and control

Knowledge during the fraudulent dates in cover up this discovery obstruction scheme of things was Placed in the United States Mail and

Publically Mailed to the Jefferson County Texas Court House “Clerk of District Court” for cause No. A-180805 and was electronically computer filed in Document # 8 herein 58th Judicial District Court of Jefferson County Texas “Case Ledger” and Court Records for cause No. A-180805

85.

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein

Fully legally precisely having legal interest with the Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein collectively

Having a physical “legal binding contract” of some hidden sorts for such (RICO) enterprise “legal services” of thee’ described Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein from the time exact time frame of December 18th 2007 when you filed “Your” General Denial…

Throughout the time frame until “You” finally official filed a “Motion for Withdrawal of Counsel”, filed stamp dated November 13th 2009 10:22 am hour

Being fully quite “Legally” described in Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein “Motion for withdrawal of counsel”

As stated legally by Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein as follows:

To The Honorable Judge of Said Court:

Now Comes Movant, Antoine L. Freeman J.D., Attorney for Defendants, Joyce Guy and Edward McCray, (hereinafter Defendants), and brings this Motion for withdrawal of Counsel, and in support thereof, shows the court the following:

I.

Good cause exists for withdrawal of Movant as counsel because Defendants have not complied with the terms of employment agreement with this attorney. Plaintiffs refuse to adhere to the terms of the employment agreement with this attorney.

II.

The setting and deadlines in this case are as follows: Motion for Sanction & Contempt on December 11th, 2009 @ 9:00 am (With Your Initials)

III.

This Motion is not sought for the purposes of delay.

IV.

A copy of this motion bearing the enclosed notice has been delivered to the last known addresses of the Defendants.

“Joyce Guy” 5050 7th street Port Arthur, Texas 77642

“Edward McCray” 5050 7th street Port Arthur, Texas 77642

V.

Defendants are hereby notified in writing of the right to object to this motion.

NOTICE

You are hereby notified that this motion for withdrawal of Counsel is set for hearing at the time and place set out below. You do not agree to this motion. If you wish to contest the withdrawal of Antoine L. Freeman, J.D. as your attorney, you should appear at the hearing.

If you do not oppose Antoine L. Freeman, J.D.’s withdrawal as your attorney, you may notify Antoine L. Freeman, J.D. in writing of your consent to this motion.

Wherefore, Premises Considered, Movant prays that the Court enters as order discharging Movant as attorney of record for Defendants, “Joyce Guy” and “Edward McCray”, and for such other and further relief that may be awarded at law or in equity.

Respectfully submitted, by “Antoine L. Freeman, J.D., Texas Bar No. 24058299, 3723 Gulfway Dr. Ste #104, Port Arthur, Texas 77642 (409) 293-1627, Fax (409) 983-7405

“Attorney for Defendants” Joyce Guy and Edward McCray

86.

Now legally Chief Defendant “Antoine L. Freeman, J.D., Texas Bar No.

24058299 seeking the 58th Judicial District Court Judge Bob Wortham “honest

official approval” to terminate said contract… in December 11th 2009 Court

Hearing after all of this past, present

“Grand (RICO) enterprise scheme of things, executed with a skilled

attorney real-estate eyes toward future 2015 financial gains of racket maturity

on

$54,839.31 U.S. Housing Grant to free and clear property deeds on the

dwelling located at 5050 east 7th street in Port Arthur Texas, Co-Defendant

“Joyce M. Guy”

enjoy such control and said “Mother” now being (Dead) providing legally

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

direct legal, possession, custody and control over (2) Fraudulent (RICO)

enterprise “scheme of things”

Namely “Federal Housing Grants” on the behalf of “Texas Department of

Housing & Community Affairs” in excess of $72,500.00 U.S. Dollars

And $54,839.31 U.S. Dollars for a combine total additional (RICO)

enterprise sham of in excess of $127,339.31 involving the Pro Se Plaintiff as a

unwilling party and victim thereof

87.

With the direct (RICO) enterprise “Leadership”, “Director”, CEO, CFO, Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein since March of 2008, April of 2008, May of 2008, June of 2008, July of 2008, August of 2008,

September of 2008, October of 2008, November of 2008, December of 2008, January of 2009, February of 2009, March of 2009, April of 2009, May of

2009, June of 2009, July of 2009, August of 2009, and September of 2009 against Texas Rules of Civil Procedures

Kidnap, pimp slap, spoil, mar, impair, desecrate, and plain old back woods “Negro Brother Esq.” corrupted in the hood with a random “casino buffet law degree” of some sorts “savagely sodomising” repeatedly “Lustita”

The Roman Goddess of “Justice” or as in commonly known in U.S. of America” namely “Lady Justice”

88.

In this shameful extra slooooow chicken thievery quarter-back, skilled “Legal Directional” choice of Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein

Super half bake mixture of “fermented formaldehyde-n-meth” soaking to formulate a toxic crack cocaine freebase cooking

(RICO) enterprise endeavor cocktail to display an obviously being quite the handsome “smoked out” broken old stove legal professional Esq. of some sorts magically appearing/disappearing “poof “ here and there legally” before a “Honorable 58th Judicial District Court of Law”

With such deployment, and actions of slipping in and out of this “legal self induce “smoked out” coma” of some sorts” as “acting attorney of record” vs. “not acting attorney of record” between the exact time frame of

December 18th 2007 – throughout the “Motion for Withdrawal of Counsel”, filed stamp and dated November 13th 2009 10:22 am hour

Being fully quite “Legally” described in Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein, “Motion for withdrawal of counsel” in his bogus, fraudulent “representation and presentation” in obstruction of Justice, Fraud upon the 58th Judicial District Court of Jefferson County Texas in a collective

Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein secrete, conspire, collusion (RICO) enterprise scheme/sham in crafty hostile complex skilled attorney at law design directed wrongfully now at the

(Sucker) namely Pro Se Plaintiff Louis Charles Hamilton herein “civil rights” in a suit in common law expensive on now time to depart, abandon, flee from such

(RICO) enterprise scheme/sham endeavors of Chief Defendant “Antoine L. Freeman, J.D.” Texas Bar No. 24058299 herein on November 13th 2009 10:22 am hour.

89.

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

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

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

ever being so “crystal clear” in 2015

Amend Complaint of the Pro Se Plaintiff confident in being precise, and

having a “well understanding” into this well twisted, calculated, future plotted,

manipulated,

(RICO) mutable Fraudulent count enterprising “scheming activities”

derive thereof and its involvement with Chief Defendant Antoine L. Freeman J.

D. Attorney at Law Texas Bar No. 24058299 herein for

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

Defendant(s) “Joyce M. Guy and Edward McCray herein to depriving the Pro Se

Plaintiff of his “personal property” namely “Construction tools” in excess of

$3800.00 U.S. Dollars and “lost wages” and earning capacity at a minimums of

$48,000.00 U.S. Dollars per year.

90.

Pro Se Plaintiff herein once being an “Independent Construction

Contractor” suffrage such brutal destruction of his profession per (7) year since

date of injury of November 2007 in the “Actual Theft of property” of Said Entire

Construction Company tools.

To include loss in construction company profit earning derive against

another (RICO) enterprise conspire sham against said property of 5050 east 7th

street in Port Arthur Texas and connections to Hurricane “Rita”.

To include loss of earning derive against another (RICO) enterprise

conspire sham against said property of 448 DeQueen Blvd. in Port Arthur Texas

With 6% interest incurred since date of Pro Se Plaintiff injury incurred

being November 17th 2007 into the future of 2015 as this Amend Complaint

being “examine and entertain” before the “Honorable Justice” of such “Actual

Damages”.

91.


before the “Honorable U.S. Justice” herein mutable complex “Federal

Questions” subject matter being raised before the

“Honorable Justice” as to the Chief Defendant (Attorney at Law) and Co-

Defendant(s) collective (RICO) enterprise criminal/civil corrupted scheming

uncivil behavior being committed

Against the Pro Se Plaintiff civil rights, peace, will, personal property and

dignity in a Civil Suit in common Law in connection with the Chief Defendant

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

thereof.

Which this “United States Eastern District Court of Texas” having full

expert “Honorable Justice” Subject Matter” over such among other things

(RICO) activities described herein full in this Amend Complaint with supporting

laundry list of “ prime meat and potatoes being namely evidence/exhibit

already on file with the U.S. Clerk office

And the further full knowledge Defendant (Attorney at Law) executed in

full wrongful conspire involvement being of a “Legal expert” to commit to

among other things “obstruction of justice”, corrupted, misleading,

manipulation” and fraud commitment upon the 58th Judicial District Court of

Jefferson County Texas in the public professional trade “among all things”

The “fiduciary capacity” of a legal “Attorney at Law” and “Officer of the Court” in and For the State of Texas.

92.

The Pro Se Plaintiff States, Affirm and Declares Chief Defendant (Attorney at Law) herein willfully engaged in conduct criminaly fraudulent and knowingly assist his client/co-defendant(s) in such (RICO) monetary grand enterprise activities while the

Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein having fully skilled legal knowledge that

A lawyer shall not counsel a client to engage in conduct that the lawyer knows is criminal or fraudulent, nor knowingly assist a client in such conduct, but a lawyer may discuss the legal consequences of any proposed course of conduct with a client and may counsel or assist a client to make a good faith effort to determine the validity, scope, meaning or application of the law. • shall not counsel to engage in conduct that the lawyer knows is criminal or fraudulent. • shall not knowingly assist a client in such conduct. • When an attorney allows his client to give false sworn testimony or file false sworn affidavits, he is sanctioning the crimes of perjury and obstruction of justice by his client, and this violates the Rules. • When an attorney allows his client to destroy or withhold documents that the client is obligated to produce, he is sanctioning the crimes of tampering with

evidence and obstruction of justice. • When an attorney allows his client to falsify documents or file bogus documents, he is sanctioning the crimes of tampering with evidence, obstruction of justice, and perhaps forgery. • When an attorney knows his client is lying, concealing evidence, obstructing justice, violating any criminal statute, or committing fraud in any way, the attorney has an ethical obligation to tell the client that this cannot be allowed.

In the representation of a client, a lawyer shall not: (a) file a suit, assert a position, conduct a defense, delay a trial, or take other action on behalf of the client when the lawyer knows or when it is obvious that such action would serve merely to harass or maliciously injure another; (b) knowingly advance a claim or defense that is unwarranted under existing law, except that the lawyer may advance such claim or defense if it can be supported by good faith argument for an extension, modification or reversal of existing law. Disclosure to prevent a crime, tort, or fraud

The crime-fraud exception can render the privilege moot when communications between an attorney and client are themselves used to further a crime, tort, or fraud. In Clark v. United States, the

US Supreme Court writes that "A client who consults an attorney for advice that will serve him in the commission of a fraud will have no help from the law. He must let the truth be told."

The crime-fraud exception also does require that the crime or fraud discussed between client and attorney be carried out to be triggered

93.

Which Pro Se Plaintiff “Louis Charles Hamilton II” herein States, Affirm and Declares such “crime-fraud” so richly (RICO) enterprise endeavor having been plotted, committed, and achieved by Chief Defendant and Co-Defendant(s) collectively being directly in violation of

18 U.S.C. § 1001 : US Code - Section 1001: Statements or entries generally




(3) Makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;

94.

Cause of Actions

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist for U.S. Code: Title 28:1343 Violations of Pro Se Plaintiff Civil Rights herein

95.

Cause of Actions


“Honorable Justice” a Cause of Actions exist for "Violations against the

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

(RICO) enterprise “criminal acts and actions”, as legally described fully herein.

96.

Cause of Actions


“Honorable Justice” a Cause of Actions exist for Violations of Chapter 96 of Title

18, United State Code: (RICO) Racketeering Influences Corruption Organization,

Title 18 U.S.C. § 1341, 1343

And 1349 “Mail and Wire Fraud”, section 1028(relating to fraud and

related activity in connection with identification documents),

Section 1503(relating to obstruction of justice) in connection with the Pro

Se Plaintiff and all records, affidavits, court records, transcripts, files and

documents, described legally fully herein.

97.

Cause of Actions


“Honorable Justice” a Cause of Actions exist for" Violations against the

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

(RICO) enterprise “criminal acts and actions”

In connection with the Pro Se Plaintiff and all transcripts records, “State

and Federal” Computer records, Jefferson County Texas Public records described

legally fully herein.

98.

Cause of Actions


“Honorable Justice” a Cause of Actions exist for Amendment VII Violation

against the Pro Se Plaintiff In Suits at common law, where the value in

controversy shall exceed twenty dollars, the right of trial by jury shall be

preserved, which the Chief Defendant and Co-Defendant(s) “Joyce M. Guy and

Edward McCray”

(RICO) enterprise was Obstruction of Justice not to preserved, and total

destruction thereof Pro Se Plaintiff right of o due process in said suit in common

law,

99.

Cause of Actions

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist for Violation against Pro Se Plaintiff entitlements under The Constitution of the State of Texas,

In civil suit within the State of Texas, Article 16: "General Provisions" Section 37 provides for the constitutional protection of the mechanic's lien.

Section 50 provides for protection of a homestead against forced sale to pay debts, except for foreclosure on debts related to the homestead (mortgage, taxes, mechanic's liens, and home equity loans).

100.

Cause of Actions


“Honorable Justice” a Cause of Actions exist for Violations of Chapter 96 of Title

18 United State Code:

In that Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas

Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray”

collective engaged in mutable monetary counts of (RICO) Racketeering

Influences Corruption Organization Enterprise,

Fraudulent engagement monetary endeavor from the exact time frame

of March 14th 2007 throughout 2015 as described herein this Amend Complaint.

101.

Cause of Actions


“Honorable Justice” a Cause of Actions exist for Chief Defendant(s) and Co-

Defendant(s) collective conspire Defamation of the Pro Se Plaintiff Construction

reputation in connection with the execution of such fraudulent (RICO)

enterprise objectives as described legally herein this Amend Complaint.

101.

Cause of Actions


“Honorable Justice” a Cause of Actions exist for Chief Defendant(s) and Co-

Defendant(s)collective Fraudulent Corruption of The 58 th Judicial District Court

of Jefferson County Texas System to induce,

And perpetrate such Fraud upon the 58th Judicial District Court in a suit in

common law for a period in excess of (19) Months as all subject matter

statements, “events” and “circumstances” described fully legally herein this

Amend Complaint of the Pro Se Plaintiff.

102.

Cause of Actions


“Honorable Justice” a Cause of Actions exist for “Intentional Infliction of

Emotional Distress” against Defendant Antoine L. Freeman J. D. Attorney at Law

Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward

McCray”.

Pro Se Plaintiff herein Incorporated and state all Defendant (Attorney at

Law) and Co-Defendant(s) herein enjoyed collectively their “Intent” scheming

fraudulent manufactory purpose in wanting the

Pro Se Plaintiff herein to suffer, extreme agony, heartache, distrait,

Accompany substantially massive monetary loss of “tools and independent

services” in the Construction profession thereof,

Humiliation, Defamation, and crushing legal defeat to inflict “excessive

mental anguish” as a result of their combine craft complex ongoing conspire

(RICO) elements, and fraud on the court to execute the same (RICO) objective

All of which being past, present, and further derive thereof Pro Se Plaintiff

suffrage such future (7) years of ongoing “mental anguish” of the Chief

Defendant and Co-Defendant(s) enforced legal corrupted (RICO) enterprise

strong hold over the civil suit in “common law” rights of the Pro Se Plaintiff

herein


24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray”.

Civilly accomplish with strong corrupted concealment motive not to be

“confused or construed” with a simple attorney mistake by Chief Defendant

(Attorney at Law) in a combine collective “cause of action” before the

“Honorable Justice” for continual past, present, and future “Intentional

Infliction of Emotional Distress” upon the Pro Se Plaintiff herein.

102.

Cause of Actions

Actual Damages Pro Se Plaintiff wrongfully civilly suffer as follows:

$336,000.00 U.S. Dollars in “loss wages” and Loss Earning capacity from date of

injury December 17th 2007 – 2014 and “actual damages” in excess of $3800.00

U.S. dollars for theft of

Pro Se Plaintiff personal property namely construction tools, Actual

Damages in the conspire $10,800.00 U.S. Dollars Breach of Construction profits

derive thereof, Actual damages in the Conspire Construction Contract for the

property located at 5050 east 7th street in Port Arthur Texas 77640

103.

Cause of Actions


“Honorable Justice” a Cause of Actions exist for “Declaratory Judgment” of the

Honorable Court against Chief Defendant Antoine L. Freeman J. D. Attorney at

Law Texas Bar No. 24058299 herein

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

collectively as to all of the “material subject matter” fully declared past, present

and future Before the Honorable Justice herein

Of the Defendant and Co-Defendant(s) Collective conclusive, conspire,

concert, agreements, engagement, and execution, pilot, maneuver,

manipulated, scheme upon (RICO) enterprise endeavors, objectives, actions and

dealing, from the time frame of March 14th 2007 throughout 2015

103.

Cause of Actions

Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist for “Actual Fraud”, Simultaneously with a (RICO) enterprise, mail and wire fraud, breach of Contract, Obstruction of Justice,

Fraud is using deceit and dishonest means for the purpose of depriving of money/profits, personal property and a legal civil right in a suit in common law docket No. A-180805 against the Pro Se Plaintiff herein.

104.

Cause of Actions

“Treble Exemplary Damages” Statue of the “Honorable Court Justice”

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

24058299 against Co-Defendant “Joyce M. Guy” and Edward McCray”

Collectively herein in favor of the Pro Se Plaintiff.

105.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves

the “Honorable Court Justice” for accumulative, compensatory, consequential,

continuing, expectation damages, foreseeable, Future, incidental,

indeterminate, reparable, lawful, proximate, prospective, special, speculative,

substantial, Awards in

Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against Co-

Defendant(s) “Joyce M. Guy” and “Edward McCray” collectively in favor of the

Pro Se Plaintiff for (RICO) enterprise against the Pro Se Plaintiff civil rights,

peace, personal property and dignity.

106.


the “Honorable Court Justice” for “ Intentional Infliction of Emotional Distress”

against Chief 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 Awards in

Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against Co-

Defendant(s) “Joyce M. Guy” and “Edward McCray” collectively in favor of the

Pro Se Plaintiff for (RICO) enterprise against the Pro Se Plaintiff civil rights,

peace, personal property and dignity.

107.


the “Honorable Court Justice” for Chief Defendant Antoine L. Freeman J. D.

Attorney at Law Texas Bar No. 24058299 herein to pay “Actual Damages” to the

Pro Se Plaintiff “Louis Charles Hamilton II” wrongfully civilly suffer as follows:

$336,000.00 U.S. Dollars in “loss wages” and Loss Earning capacity from date of

injury December 17th 2007 – 2014

And “actual damages” in excess of $3800.00 U.S. dollars for theft of Pro

Se Plaintiff personal property namely construction tools,

Actual Damages in the conspire $10,800.00 U.S. Dollars Breach of

Construction profits derive thereof, Actual damages in the Conspire

Construction Contract for the property located at

5050 east 7th street in Port Arthur Texas 77640 all of which said Chief

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

herein

Directly provided (RICO) enterprise skilled attorney at law racket, scheme,

plot, conspire, concert, leadership and obstruction of Justice thereof among

other devise, instruments, trick, shams to deprive the Pro Se Plaintiff herein

thereof said

“Actual Damages” with 6% interest incurred since date of Injury

December 17th 2007.

108.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Respectfully

Moves the “Honorable Court Justice” for “Declaratory Judgment” of the

Honorable Court against Chief Defendant Antoine L. Freeman J. D. Attorney at

Law Texas Bar No. 24058299 herein

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

collectively as to all of the “material subject matter” fully declared, described

fully past, present and future Before the Honorable Justice herein.

109.


Moves the “Honorable Court Justice” for “Treble Exemplary Damages” Statue of

the “Honorable Court Justice”

Against Chief Defendant Antoine L. Freeman J. D. Attorney at Law Texas

Bar No. 24058299 against Co-Defendant “Joyce M. Guy” and Edward McCray”

Collectively herein in favor of the Pro Se Plaintiff.

110.


Moves the “Honorable Court Justice” for the Chief Defendant and Co-

Defendant(s) collectively pay all court cost of this U.S. Civil Court Action,

And all legal cost the Pro Se Plaintiff incurred, and all Pro Se Plaintiff

Attorney cost incurred herein.

111.


and Request the “Honorable Court Justice” for any further, Just, proper,

Damages, Orders, and Awards

The “Honorable Court Justice” Deems favorable for the behalf of Pro Se

Plaintiff “Louis Charles Hamilton II” herein in “Law and equity”.

On this ______ Day of ________________ 2015

By, _______________________________

Louis Charles Hamilton II

Pro Se Plaintiff

P.O. Box 17524

Sugar Land Texas 77496