1. Defendant(s) “Joyce Guy and Edward McCray” having “Actual Damages” being owed to the Plaintiff in the Amount of $11,024.00 with full 6% interest rate incurred since date of injury November 16th 2007 To include but not limited to the “Actual Theft” of the Plaintiff entire Construction Company set of tools in excess of $3093.00 Dollars
2. Defendant(s) “Joyce Guy and Edward McCray” having “Actual Damages” being owed to the Plaintiff in the Amount of $336,000.00 minimal lost wages and lost earning capacity” per year with full 6% interest rate incurred since date of injury November 17th 2007
3. This do not include, or exempt any exemplary, intentional infliction, mental anguish, physical assault & battery upon the Plaintiff person, just awards and damages the Pro Se Plaintiff may be entitled in addition to Actual damages as described in Paragraph (1) and (2) above.
Louis Charles Hamilton II PLAINTIFF MOTION FOR WRIT OF ATTACHMENT No. A-180805
1. No. A-180805
Louis Charles Hamilton II INTHE DISTRICTCOURT
Plaintiff 58TH
JUDICIAL DISTRICT
V.
Joyce Guy & Edward McCray ET AL OF JEFFERSONCOUNTY, TEXAS
Defendants.
Writ of Attachment
Comes Now Before the Honorable58th
DistrictCourtthe Pro Se Plaintiff, Louis
Charles Hamilton II,
Motion before the HonorableCourt, For a Writ ofattachment, being
enforced on the Property located at 448 DeQueen Blvd. in PortArthur Texas and
for justcause the Pro Se Plaintiff state as Follows:
1. Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This
Honorable58th
DistrictCourt of Jefferson County Texas on the 10th
day
of May 2010
2. To producecopies of deeds, property deeds or any other such physical
document in Defendants’ possession, custody or control that shows
actual ownershipof the property of the dwelling locatedat 448
DeQueenBlvd., inPort Arthur Texas and fully failing toadhere to an
Honorable Court Order. Said Court order attachedas Plaintiff exhibit
(A) herein
3. And actual real ownership of said Property is in fact being in a state of
“unknown ownership”beforethe Plaintiff and This Honorable Court as
proof was so required beforethe Honorable 58th
DistrictCourt of
Jefferson County Texas to be produced while a “civil dispute” is ongoing
over said dwelling located at 448 DeQueen Blvd., in PortArthur Texas
with the Pro Se Plaintiff “Louis Charles Hamilton II” herein
2. 4. As a question of disputed Law Plaintiff raise now real concern further
before this Honorable58th
DistrictCourtof actual real property
ownership of said dwelling the possiblesells of said Property whilebeing
in such Defendant(s) “Joyce Guy and Edward McCray” as of this
undersigneddate in2014 Fully inPossession, Custody andControl of
the said unidentifiedactual property anddwelling locatedat 448
DeQueenBlvd., inPort Arthur Texas with a Judgment being render
against the Defendant(s) Collectively
5. To include but not limited to Defendant(s) “Joyce Guy and Edward
McCray”having possible Possession,Custody, and Controlover many
other Properties located in PortArthur Texas, Jefferson County
6. “Actual Damages” being owed to the Plaintiff fromthe Defendant(s) in
the Amountof $11,024.00 with full6% interest rate incurred since date
of injury November 16th
2007
7. Being as of 2008 rateincurred $661.44 totalof $11,685.88
8. Being as of 2009 rateincurred $701.15 totalof $12,387.03
9. Being as of 2010 rateincurred $743.22 totalof $13,130.25
10.Being as of 2011 rateincurred $787.81 totalof $13,918.06
11.Being as of 2012 rateincurred$835.08 totalof $14,753.14
12.Being as of 2013 rateincurred$885.18 totalof $15,638.32
13. Being as of 2014 November 17 rate incurred $938.29 totalof
$16,576.61
*This do not include any other monetary “Exemplary Awards” Granted to
the Pr Se Plaintiff as Order for Final Judgment in this Civil Action against said
Defendant(s) “Joyce Guy and Edward McCray” for their combine wrongfully
actions, against the civil rights, peace anddignity of the Pro Se Plaintiff “Louis
Charles HamiltonII herein.
Defendant(s) collectively seeks to “really physically abscondsecretly”from
the 58th
District Court Jurisdiction Justice during a“ongoing civil”action pending
before the Honorable Court against them,
3. To among other “slow simple minded dizzy bold reasoning” of the
Defendant(s) collective behavior also include avoiding 100% being monetary
accountable and responsiblefor their combine acts and actions within the
Jurisdiction of this civil action for the unlawful civil acts and actions as fully
described against the Defendants “Joyce Guy and Edward McCray” in Complaint
of the Pro Se Plaintiff filed Cause No. A-180805
To include the “Actual Theft”of the Plaintiff entire Construction setof tools
in excess of $$3093.00Dollars Defendant(s) further seeks to fully abscond to
avoid paying real damages for such “Thievery” as described by the Plaintiff now
ongoing over 7 years and 30 days to date as of November 17, 2014 Defendant(s)
“Joyce Guy and Edward McCray” collectively being in possession of Plaintiff
“PersonalProperty”
The “unknown ownership dwelling”Located at 448 DeQueen in Port
Arthur Texas having a real “Property Lien” being now enforced against this said
property herein by The Jefferson County Sheriffs Dept. as per Order by this
HonorableCourt for the covering the full amountof Judgment render of this Civil
Action Docket No. A-180805as requiredby the ProSe Plaintiff.
Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves
the HonorableCourtherein that 30 days after entry of said “Final Summary
Judgment” againstDefendant(s) “Joyce Guy and Edward McCray” in favor of the
Pro Se Plaintiff being fully recorded in the Courtrecords at the “Clerk of Court”
office of Jefferson County Texas
This “Writof Execution” being fully enforced thereby 30 days after entry of
said “Final Summary Judgment” for The Jefferson County Sherriff’s Officeherein
to physically seize the said unidentified ownership property and dwelling located
at 448 Dequeen Blvd. in Port Arthur, Texas
To include “Jefferson County Sherriff’s Officeto fully evict all unknown
“Personand or Person(s)”having, possession, custody, and controlover the
dwelling being physically removed them fromthe Unidentified Ownership
Property located at 448 Dequeen Blvd. in Port Arthur Texas there after
4. Said “Writ of Execution” being enforced by the “Clerk of Courtof “Jefferson
County Texas directing The Jefferson County Sherriff’s Officehereby to
commence fully in the “sale of said Property” Already having a “Property Lien
Enforcement” against it in Favor of the Plaintiff for such sales
For payments of any and all such, Damages, Awards, and fullinterest
incurred for full compensation of this “civil action” being paid to the Pro Se
Plaintiff herein with interest incurred being still paid to Plaintiff at a rate of 6% on
all Judgment until final sale of Unidentified Property and dwelling located at 448
DeQueen Blvd. in PortArthur Texas is completed as Order by the Honorable
Court. To include the said seize unidentified ownership property and dwelling
located at 448 Dequeen Blvd. in PortArthur, Texas
Being made to cover for full payments to The Jefferson County Sherriff’s
Officefor rendering duties for such sells of undefined property and dwelling
located at 448 Dequeen Blvd. in PortArthur Texas and to cover all court costof
this civil action fully being complete,
And covering any and all Sherriff’s OfficeCostderived in the Execution of
this “Writ of Execution” and any other cost Sherriff’s Officeincurred as required
by the court during this civil action as directed by this HonorableCourt.
Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves The
HonorableCourt for any further, Just, proper deviseto secure Plaintiff “Writ of
Execution” Until this Civil Disputehas reach a Full, Final and Complete Judgment
Before This Honorable58th
DistrictCourt of Jefferson County Texas
By,_______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496