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Motion for sanctions

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Civil Action

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Motion for sanctions

  1. 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. PLAINTIFF MOTIONFOR SANCTIONS Motion before the HonorableCourt, For a Sanctions, being enforced against the Defendant(s) and for just causethe Pro Se Plaintiff state as Follows: 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 to produce copies of deeds, property deeds or any other suchphysical 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 to adhere to an Honorable Court Order. Defendant(s) already refused completely discovery devises being numerous requests of the Plaintiff threw the Crafty shady slights of hand acts and actions Attorney of Record “Antoine L. Freeman, J.D. Texas Bar No. 24058299 Fully Committing to the same fraud in conspiring with the Defendant(s) to with hold all records of to this civil action at any cost, considering the enforced criminal penalties in light of the many frauds being committed againstInsurance companies, and FEMA claims for damages, as a result of this History of Hurricane Damages of related God Act’s as described by the Plaintiff his “Investigation Concluded”
  2. 2. That Elementary Indeed, the Defendant(s) arequite crafty in hustling numerous fakebusiness, to include but not limited to Defendant(s) engaging illegal sales of a “Crack Industry” for which Defendant(Edward McCray) convicted twice of Federal Traffic of Crack Cokecaine, serving two separate prison terms, which Plaintiff also described before the HonorableCourtDefendant(s) business of recycle of Cans, as resulting also raid by PAPD Dept. for the City of PortArthur Texas engaging in “illegal scrap metal Industry” While Defendant(s) “JoyceGuy” already committed for way to many uncountless years of a undocumented “gruesome medical business”taking care of the Poor elderly Senior Citizens not even having documented health Lic# or any kind with the State of Texas or any kind of Insuranceon this medical business, or proper personaldealing with Poor elderly Senior Citizens. Pro Se Plaintiff moves respectfully beforethe HonorableCourt that these Crude Defendant(s) bedealt there on devise To include having a total disregard for the HonorableCourt, Plaintiff, Civil Rights, Peace and Dignity And an Ordered into these records for sanctions being fully merit against the Defendant(s) “Joyce Guy” and “Edward McCray” for their collective refusalof the 58th DistrictCourtOrders attached herein with this Motion for sanctions against the Defendant(s). Defendant(s) having stolen the Plaintiff lively hood of Construction tools’ in excess of $3093..00 dollars in their possession, custody and controlover now a period of 7 years and counting. Defendant and Defendant’s Attorney did in fact violated rule 193.1 by failing to respond to Plaintiff’s discovery request AS Plaintiff files all Proof attached to Plaintiff Motion for Final Summary Judgment Defendant(s) continue to commit to the same, and refusalof a Court Order to submit to Plaintiff Discovery Request Court Order was enforced on the 10th day of May 2010
  3. 3. Defendant(s) continualto commit to refusal of The Jefferson County 58th District Judicial “CourtOrder” being now 4 years and 6 Months and counting The Defendant(s) Extreme “Wicked” and “Hostile” unwanted actions Directed at the Plaintiff “Civil Rights”, “Peace” and “Dignity” within Jefferson County Texas with actual damages being in excess of the Amount of $11,024.00 combine for Defendant(s) “Breach of Contract” with full 6% interest rate incurred since date of injury November 16th 2007 1. Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves the HonorableCourt to grant the Plaintiff attached joining motion for sanctions filed herein with good “Merit” for the Discovery which was Order to be produced by The Court 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 to produce copies of deeds, property deeds or any other suchphysical document in Defendants’ possession, custody or control that shows actual ownershipof the property of the dwelling locatedat 448 DeQueenBlvd., inPort Arthur Texas Defendant(s) Further Order to beproduced by The Court Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This Honorable58th District Court of Jefferson County Texas on the 10th day of May 2010 to produce Copies of any and all construction estimates for repairs inDefendants’ possession, custody or control inrelationshiptodamage causedby Hurricanes Rita, Humbertoand Ike to the property locatedat 448 DeQueenBlvd. inPort Arthur, Texas. And apply civil sanctions againstthe Defendant(s) in excess of $1000.00 U.S. dollars per every year betweenthe dates of 2010-2014 theDefendant(s) collectively being quite bold hostile disrespectfulfleeing absconded completely
  4. 4. fromthe civil actions as they were so required to producesuch discovery via the HonorableCourt Order of the 58th DistrictCourtof Jefferson County Texas. 2. Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves the HonorableCourt sanctions amountbeing granted in favor of the Plaintiff in the amount of $4500.00 U.S. Dollars fromdates of 10th day of May 2010 throughout December 17th 2014 As undersigned date being before “OralArguments/Hearing” on the 17th day of December 2014 at8:30 before the Court. 3. Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves The HonorableCourt for any further, Just, proper until this Civil Disputehas reach a Full, Final and Complete Judgment of This Honorable58th DistrictCourt of Jefferson County Texas in Favor of the Pro Se Plaintiff. By, _______________________________ Louis Charles Hamilton II Pro Se Plaintiff P.O. Box 17524 Sugar Land Texas 77496

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