In The United States District Court 
For The Eastern Division of Texas 
Beaumont Division 
Louis Charles Hamilton II 
Pro Se Plaintiff 
Vs. 
Antoine L. Freeman J. D. 
(Attorney at Law) Texas Bar No. 24058299 
Defendant 
Joyce M. Guy 
Edward McCray 
Co-Defendant(s) 
Civil Complaint 
Jury Demand 
Comes Now The Pro Se Plaintiff “Louis Charles Hamilton II” Pro Se Plaintiff 
files “Complaint” with the above Honorable U.S. District Court and for Just 
Cause, Plaintiff herein will show before the “Honorable Court” all facts, 
circumstances, detailing among other things (RICO) “Racketeer Influenced and 
Corrupt Organizations Act, 
Causes of “acts and actions” committed against the Pro Se Plaintiff herein 
“Will”, “Civil Rights”, “Peace” and “Dignity”. 
“United States of America” Not a Party to this Suit. 
1.
Parties. 
Pro Se, Louis Charles Hamilton II, African American Male, U.S. Navy 
Veteran, 
Pro Se Plaintiff , Louis Charles Hamilton II, African American Male, 
Permanently Disable Veteran protected under: 
(ADA) American with Disability Act; 
And also minorities persons cover under Title VII of the Civil Rights Act of 1964; 
Domiciliary State of Texas, P.O. Box 17524 Sugar Land, Texas 77496 
2. 
Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) (Active) in and 
for the State of Texas Bar No. 24058299 
Has “Two Legal Law Offices” in Port Arthur Texas, 3627 Professional Dr. 
Port Arthur Texas 77642 and 3723 Gulfway Dr. Port Arthur Texas 77642 
3. 
Co-Defendant(s) Joyce M. Guy and Edward McCray (Legally Married) has 
(5) business E and J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur 
Texas Information about E & J Collectibles E & J Collectibles is in the Used 
Merchandise Stores business and this category has 2 companies in Port Arthur 
Texas. 
J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 
448 DeQueen Blvd. in Port Arthur Texas 77640, 
G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur 
Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640 and 
“Cars and Pieces” Located in Beaumont Texas (Office) also located at 448 
DeQueen Blvd. in Port Arthur Texas 77640
4. 
Jurisdiction 
Jurisdiction is proper before the “Honorable Court” of Eastern District of 
Texas in that (Plaintiff) is always a resident of Jefferson County Texas, and all 
acts and actions described herein by all the Defendant(s) described herein fully 
occurred within the Jurisdiction of Eastern District of Texas 
Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 
24058299 is a (Active) “Attorney at Law” for the State of Texas as described 
above in paragraph (2) 
Further said Defendant Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 was acting in his full capacities as an “License Attorney” on 
retainer for the legal behalf of (Co)-Defendant(s) “Joyce M. Guy” and “Edward 
McCray” in a Civil Action in The District Court 58th Judicial District of Jefferson 
County, Texas, Docket No. A-180805 
When said Defendant herein in his fiduciary capacities as an “Attorney of 
Law” Antoine L. Freeman J. D.) Texas Bar No. 24058299 
Committed to “among many other things” (RICO) “Racketeer Influenced 
and Corrupt Organizations Act”, Fraud on the Court 
“Mail and Wire Fraud”, “Direct Fraud” and “Constructive Fraud” in 
connection with Jefferson County Texas 58th District Court Records, and Fraud 
of Jefferson County Public Records 
5. 
To include Defendant(s) and Co-Defendant(s) collectively in concert, and 
collaboration in violations of Title 18 U.S.C. § 1341, 1343 and 1349 “Mail and 
Wire Fraud”, Violations of Chapter 96 of Title 18, United State Code: (RICO) 
Racketeering Influences Corruption Organization, Defendant Antoine L. 
Freeman J. D. Attorney at Law Texas Bar No. 24058299
Aiding and abetting to commit to A Criminal Enterprise in “Racketeer 
Influenced and Corrupt Organizations Act” in his capacity as a Attorney of Law, 
against the rights, peace, and dignity, and civil rights of the Pr Se Plaintiff herein 
in suit in common law in Jefferson County Texas 58th Judicial District Court. 
"Computer Fraud and Abuse Act (CFAA) 18 U.S.C. § 1030 in connection 
with all criminal acts and actions, as described fully herein. 
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 Fully Committed to among other things “Obstruction of Justice” in the 
capacity as an “Officer of the Court” and “Attorney of Law” for the State of 
Texas To commit and conspire to the same causes of all “acts and actions” in 
concert with the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” 
Fully Described herein against the Pro Se Plaintiff, While further willfully 
Omitting to and Destruction thereof “Material Civil Evidences and Facts” before 
a ongoing “Civil Suit” in Common Law in Jefferson County Texas 58th Judicial 
District 
With “among other things” Defendant Antoine L. Freeman J. D. Attorney 
at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and 
“Edward McCray” Actual Fraud, upon the “Texas Department of Housing & 
Community Affairs” Jefferson County Texas and Federal Grants derived thereof 
in Connection with the Pro Se Plaintiff “Louis Charles Hamilton II” herein 
With “among other things” Defendant Antoine L. Freeman J. D. Attorney 
at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and 
“Edward McCray” Actual Fraud of Insurance Companies”, for primary fraud 
during “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm 
damages, in connection with the Pro Se Plaintiff 
6. 
Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” To commit to the 
same “Obstruction of Justice” of 58th Judicial District Court, for primary fraud 
during “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm 
damages,
Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) (Active) in and 
for the State of Texas Bar No. 24058299 and in collusion with Co-Defendant(s) 
“Joyce M. Guy” and “Edward McCray et al” Conspiracies together to pursue the 
same Criminal (RICO) “Racketeer Influenced and Corrupt Organizations Act”, 
Fraud on the Court “Mail and Wire Fraud”, “Direct Fraud” and 
“Constructive Fraud” of Jefferson County Texas 58th District Court Records, 
Fraud of Jefferson County Public Records All “among other things” being done 
criminally/civilly against the Pro Se Plaintiff civil rights, peace, will, and dignity, 
During an ongoing “Civil Suit” of Common Law in Jefferson County Texas 
as described in paragraph 4 and 5 above. 
All being wrongfully and fully committed to Within the Jurisdiction The 
Eastern Division of Texas United States District Honorable Court. 
7. 
Subject Matter Jurisdiction 
Venue 
Pro Se Plaintiff Louis Charles Hamilton II herein States, Affirm, and 
Declare Before the “Honorable Justice” Subject Matter Jurisdiction is proper 
before this U.S. District Court “primary exclusive many “federal Questions” 
involving among other things 
Violations of Chapter 96 of Title 18, United State Code: (RICO) 
Racketeering Influences Corruption Organization, Section 1341 (relating to mail 
fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and 
related activity in connection with identification documents), Section 
1503(relating to obstruction of justice), 
Falsification of “Material facts”, with Conspiracies by all described 
Defendant(s) to pursue to the same Criminal Monetary Objective(s) involving 
the Pro Se Plaintiff herein,
With mutable counts of constructive fraud activities “hiding behind” 
among other things “attorney-client privilege” and all “work-product doctrine” 
derive thereof, to include but not limited to all “communications” between an 
“Attorney and his client”, 
Namely Defendant Antoine L. Freeman J. D. (Attorney at Law) (Active) in 
and for the State of Texas Bar No. 24058299 in collusion and conspiracies with 
Co-Defendant(s) “Joyce M. Guy” and “Edward McCray et al” 
To Commit to Fraudulent acts in all “prepared legal court documents”, 
“affidavit(s)”, “interrogatories”, “request for admissions”, sign statements and 
all other materials of Jefferson County Court records, document(s) and materials 
facts in 58th Judicial District Court of Jefferson County Texas Court Docket No. A- 
180805 “To include but not limited” to fraud upon the Honorable Judge Bob 
Wortham, and His Court 
Fraud in all records of the Jefferson County Clerk Office records involving 
financial records of “Insurance Companies”, “Financial Statements” for primary 
monetary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and 
“Humberto ” scheme of things related Construction storm damages, derive 
thereof further involving the Pro Se Plaintiff herein 
8. 
“To include but not limited to” the ” Actual Fraud”, upon the “Texas 
Department of Housing & Community Affairs” of Jefferson County Texas and 
“Federal Grants of $76,000 U.S. Dollars” derive thereof 
In Violations of Chapter 96 of Title 18, United State Code: (RICO) 
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), with “Actual Fraud(s)” Co-Defendant(s) 
“Joyce M. Guy” and “Edward McCray” conspiracies of mutable “Insurance 
Companies”, for primary fraud and scheme advantages during “Hurricane 
“Rita”, “Ike” and “Humberto ” related Construction storm damages, Involving
further The Pro Se Plaintiff herein as a “unwilling blind” party into this cold 
calculated fraudulent acts and action(s), and complex scheme of things to 
further fraud the “Texas Department of Housing & Community Affairs” of 
Jefferson County Texas and a “Federal Grants in excess of $76,000 U.S. Dollars” 
derived thereof 
9. 
“Actual Fraud”, upon the 58th Judicial Court of Jefferson County Texas and 
all records derive thereof, 
To include but not limited to Actual Fraud of Insurance Companies”, 
FEMA for primary monetary fraudulent acts and actions during “Hurricane 
“Rita”, “Ike” and “Humberto” related Construction storm damages, involving 
the Pro Se Plaintiff Louis Charles Hamilton II herein 
All this “Complex Mutable Grand Scheme of Things” committed By the 
Name Defendant Antoine L. Freeman J. D. a (Attorney at Law) (Active) in and for 
the State of Texas Bar No. 24058299 in collusion and conspiracies with Co- 
Defendant(s) “Joyce M. Guy” and “Edward McCray et al” corrupted activities 
fully designed prepared with an eye towards the “realistic possibility of 
impending litigation” by the Pro Se Plaintiff herein Defendant and Co- 
Defendant(s) commit to Grand (RICO) Fraud of The 58th Judicial District Court of 
Jefferson County thereof in this civil scheme of things. 
And the realistic object by all described Defendant and Co- Defendant(s) 
herein to further commit to Fraud for “monetary value gain in excess” of 
$87,024.00 U.S. Dollars, against the Pro Se Plaintiff Civil rights, peace, will and 
dignity 
10. 
With further combine conspiracy of fraudulent acts and actions by the 
Defendant and Co-Defendant(s) to plan a scheme of things in the Theft of Pro Se 
Plaintiff “Personal Property” herein against the Pro Se Plaintiff Louis Charles 
Hamilton II “Civil Rights”, “Peace”, and “Dignity” being wrongfully done within
the Jurisdiction of the “Honorable Justice” further causing the Pro Se Plaintiff 
herein to suffer “among other things” 
Extreme real life hardship, Extreme Intentional Infliction of emotional 
distress and mental anguish from all of the combine Defendant and Co- 
Defendant(s) among other things conspire in (RICO) “Racketeer Influenced and 
Corrupt Organizations Act”, 
“Fraud on the Court”, “Mail and Wire Fraud”, “Obstruction of Justice” 
“Direct Fraud” and “Constructive Fraud” of Jefferson County Texas 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 complaint herein. 
11. 
Pro Se Plaintiff herein States, Affirm and Declare before the Honorable 
Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 Violations of Chapter 96 of Title 18, United State Code: (RICO) 
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), Fraud upon the 58th Judicial District 
Court of Jefferson County Texas in connection with 
Falsification of “Material facts”, and Numerous Fraudulent Activities in 
the Capacity of a “Attorney at Law” cause Pro Se Plaintiff “Louis Charles 
Hamilton II” herein to suffer “actual damages” in excess of $336,000.00 U.S. 
Dollars and This “actual damages” is ongoing as of this undersigned date of this 
Complaint before the Honorable Court since date of injury November 17th 2007. 
12. 
Pro Se Plaintiff seeks Actual, accumulative, compensatory, consequential, 
continuing, expectation damages, foreseeable, Future, incidental, indeterminate, 
reparable, lawful, proximate, prospective, special, speculative, substantial,
Punitive, and Permanent damages; Pro Se Plaintiff seeks Actual Awards for 
Intentional Infliction of emotional distress and mental anguish. 
13. 
Pro Se Plaintiff herein States, Affirm and Declare before the Honorable 
Justice” this action was filed before this Honorable Court February 2, 2010 U.S. 
Docket No. 1:2010-CV-00055 and at that time frame Pro Se Plaintiff was under 
extreme mental stress caused by the many “acts and actions” of the primary 
Defendant in the capacity of a “Skilled Attorney of Law” no less a Officer of The 
State of Texas Court System and Co-Defendant(s) herein whom collectively 
together are responsible for the Pro Se Plaintiff suffrage of among other things 
“Mental Illness” and Living on SSI since date of injury… of 2007 as of this 
undersigned date. 
Pro Se Plaintiff further states, affirm and declare before the Honorable 
Justice” also at the time of filing the original complaint against the Described 
Defendant(s) herein 
(Plaintiff) U.S. Government and Federal Court Mail was being stolen, by 
among others 
(Thee) U.S. Attorney Office them self (Proof) already on Filed in this 
herein U.S. Federal Court Clerk Office in the matter of Hamilton Vs. United 
States of America, U.S. Attorney Eric Holder et al (1:2011-CV-00240) 
Plaintiff was also forced into a “State Hospital” for a period of time, 
accused of Violent Life Threaten Crimes” never being near of or a party thereof 
and Pro Se Plaintiff “mental state” being quite scary indeed in light of all the 
legal hostile activities ongoing against the Plaintiff will caused by each 
Defendant(s) herein. 
14. 
Pro Se Plaintiff herein States, Affirm and Declare further before the 
“Honorable Justice” this New Improved Complaint made against each 
Defendant(s) herein is still criminal/civil corrupted conduct being still quite
“civilly ongoing” against the “legal rights” of the Pro Se Plaintiff “Louis Charles 
Hamilton II 
As Defendant(s) combine further “Fraudulent activities” continue to cause 
the Pro Se Plaintiff to suffrage continually monetary damages in excess of 
$48,000.00 U.S. Dollars per year since 2007, as of this undersigned date of this 
complaint well into the future year of 2015. 
Further causing Pro Se Plaintiff a “limbo state” of extreme hardship, 
Intentional Infliction of emotional distress accompanying continue Gross state 
of complete “mental anguish” direct at the Defendant(s) from all of the 
numerous hostile corrupted acts and actions of the described Defendant(s) 
herein as this “Civil Matter” is unresolved before the Jurisdiction of this 
Honorable U.S. District Court which has real subject matter jurisdiction over all 
detail material facts being complained of respectfully before “Honorable 
Justice” 
15. 
Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable 
Justice” that his current “Mental State” is processing a bit better, as these 
causes of actions derived from Defendant Antoine L. Freeman J. D. Attorney at 
Law Texas Bar No. 24058299 direct criminal/civil illegal, hostile, corrupted 
conduct in collusion with Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” 
need to be legally address 
And Pro Se Plaintiff seeks a just proper legal, lawful respectable 
accountable end to this civil matter in which the above Honorable U.S. District 
Court has unfetter Judicial Subject matter over. 
16. 
Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable 
Justice” the Defendant(s) continue imposed mental suffrage, hardship, and 
Major Monetary losses caused by the described Defendant(s) collectively herein 
as Pro Se Plaintiff “Mental State” has improved slightly as of this undersigned
date to uncover all of the real in life cruel intentions scheme, facts and 
fraudulent circumstances of each described Defendant(s) acts and actions 
herein direct against the rights, will, peace and dignity of The Pro Se Plaintiff 
notably being on a Grand scale corrupted involvement 
To the point the once (crafty hidden) “Racketeer Influenced and Corrupt 
Organizations Act”, “Obstruction of Justice” 
“Fraud on the Court”, “Mail and Wire Fraud”, “Direct Fraud” and 
“Constructive Fraud” of Jefferson County Texas 58th District Court Records, 
Committed fully by Defendant Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 And precise fraud upon the 58th Judicial Court of Jefferson 
County Texas to now as of this undersigned date 
Being official new discovery in Jefferson County Texas Public records, 
quite correct and respectable evidence being complained of before the 
Honorable Justice” 
Now identified is this complaint in precise, sound proof calculations into 
each responsible direct “acts and actions” of each Defendant(s) exacts 
responsible & accountable “federal jurisdiction” conduct giving rise for a cause 
of “Justice” Before this “Honorable Justice” United States of America Court . 
17. 
Factual Background 
Co-Defendant(s) “Joyce Guy and Edward McCray” living at the dwelling 
(Blk. 172 Lt. 1-2) being located at 448 DeQueen Blvd. in Port Arthur Texas 
77640 knowingly collectively did enter into a Contract for the Amount of 
$10,850.00 for Construction following Hurricane Humberto damages. 
18. 
Co-Defendant(s) “Joyce Guy and Edward McCray” already received funds 
for repairs from the “Home Owner Insurance Company” in excess of $7000.00 
U.S. Dollars and unknown to the (Plaintiff) Co-Defendant(s) simply squander all
of these funds on them self and their quite “selfish needs other than making the 
repairs to the already seriously damaged home as required by the first 
installment Insurance Funds proceeds. 
At this point Co-Defendant(s) “Joyce Guy and Edward McCray” devised a 
financial “wicked plan” to fraudulently involving the Pro Se Plaintiff “Louis 
Charles Hamilton II” herein and his Construction contract $10,800.00 U.S. 
Dollars for Hurricane Damages in a continue “scheme of things” to obtain 
additional Funds from the same “Insurance Company”. 
19. 
Co-Defendant(s) “Joyce Guy and Edward McCray” Breach the Contract of 
the Pro Se Plaintiff on November 17, 2007 for the same scheme of things as 
being described in paragraph (18) above in addition Co-Defendant(s) collectively 
took possession, custody and complete control over all of the Plaintiff property 
Namely (Construction Tools) in excess of $3093.00 being Pro Se Plaintiff entire 
“Construction Business of tools”...! 
Wrongfully abducted and obtain in this “hostile takeover” to include Pro 
Se Plaintiff herein being “physically assaulted” by Co-Defendant “Edward 
McCray” while this same ongoing “criminal scheme of things” is in effect fully 
committed and directed, and orchestrate by Co-Defendant(s) “Joyce Guy and 
Edward McCray for the absolutely purpose to Fraud further of The “insurances 
companies “Repair Moneys” for Co-Defendant(s) collectively “personal 
monetary gain” other than making needed repairs 
As all described in paragraph (18 & 19) above involving The Pro Se 
Plaintiff Louis Charles Hamilton II and a Construction contract drafted by Pro Se 
Plaintiff for Co-Defendant(s) “Joyce Guy and Edward McCray” collective behalf 
for “monetary relief” by said “Insurance Companies” to cover dwelling located 
at 448 DeQueen Blvd. in Port Arthur Texas home structural repairs cost for 
Hurricane Humberto related storm damages. 
20.
Co-Defendant(s) “Joyce Guy and Edward McCray” for their combine 
corrupted conduct direct against the Plaintiff civil rights, peace, and dignity 
within Jefferson County Texas as being described in paragraph (17, 18, and 19) 
above 
Pro Se Plaintiff filed civil action in Jefferson County Texas 58th Judicial 
District Court, before the “Honorable Judge” Bob Wortham. 
Complaint Docket No. A-180805 filed on November 26th 2007 with the 
Jefferson County Clerk of Court office. And Co- Defendant(s) “Joyce Guy and 
Edward McCray” retain the Professional legal services of Defendant Antoine L. 
Freeman J. D. “Attorney at Law” Texas Bar No. 24058299 
Having “Two Legal Law Offices” in Port Arthur Texas, 3627 Professional 
Dr. Port Arthur Texas 77642 and 3723 Gulfway Dr. Port Arthur Texas 77642 
21. 
Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable 
Justice” because of the continue chief corrupted effects of Defendant Antoine L. 
Freeman J. D. Attorney at Law Texas Bar No. 24058299 Skilled Crafty Criminal 
Mutable Complex 
Violations of Chapter 96 of Title 18, United State Code: (RICO) 
Racketeering Influences Corruption Organization, Section 1341 (relating to mail 
fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and 
related activity in connection with identification documents), Section 
1503(relating to obstruction of justice), 
Falsification of “Material facts”, among other things committed by this 
Defendant with Fraud upon the 58th Judicial District Jefferson County Court and 
such Conspiracies involving the Pro Se Plaintiff herein,
The Civil action filed on November, 26th 2007 in 58th Judicial Court of 
Jefferson County Texas remain complexly ongoing well into December 17th 2014 
next court hearing, fully 
“Live” as of this undersigned date for a period well exceeding over (7) 
years and counting ongoing in the 58th Judicial District Court of Jefferson County 
Texas for a suit in “Common Law”. 
22. 
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 filed an original answer on behalf of the Co-Defendant(s) and then 
later making false discovery procedure claiming to the Honorable Judge Bob 
Wortham on or about 11th day of September 2009 in a reply motion for sanction 
against said “Attorney” for violations of Texas Rules of Civil Procedure 193.1 by 
failing to respond to Pro Se Plaintiff’s Discovery Request 
” Defendant Antoine L. Freeman J. D. Attorney at Law Texas further 
making factual material claims in court filed documents and before the 
Honorable Court in a hearing his only “Legal obligation” was to provide Co- 
Defendant(s) “Joyce Guy and Edward McCray” involving in this civil case A- 
180805 in Jefferson County Texas was to draft a (Simple) General denial on behalf 
of the described “Co-Defendants” behalf being filed on December 18th 2007 in 
Jefferson County Clerk of Court records in order Co-Defendant(s) collectively do 
not be filed for a default Judgment against them for the Civil Complaint. 
23. 
Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable 
Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 told a bald face “Lie” to “Judge Bob Wortham” to avoid “monetary 
sanctions” against him for his (Indeed) violate of Rule 193.1 
Defendant in his capacities as a “Attorney of Law” no less “kept secretly” 
in his possession, custody and Control for a period of over (3) years while being
actual the “Attorney of Record” in this civil matter safely Hidden from the 
“Honorable 58th Judicial Court” proceeding 
All of Pro Se Plaintiff first round of Chief Discovery request document(s) 
Request for Disclosure and “Request for Admissions” pursuant to Rule 198 of 
the Texas Rules of Civil Procedure to include Pro Se Plaintiff First set of 
Interrogatories” pursuant to 197 of the Texas Rules of Civil Procedure at which 
Defendant Antoine L. Freeman J. D. “Attorney at Law” Texas Bar No. 24058299 
finally admitted to the Pro Se Plaintiff (alone) 
The “actual physical existences” after 3 years and counting Defendant 
“Attorney at Law” omitted of being in such possession, custody and control while 
keeping such discovery request of the Pro Se Plaintiff secretly hidden from the 
“Court Proceedings” Moreover” especially Hidden From “Judge Bob Wortham” 
Judicial studying of the civil case at hand before his Honorable Court proceeding 
At which Defendant Antoine L. Freeman J. D. “Attorney at Law” providing 
proof of all discovery document and material facts derive thereof and their now 
existences being dated proof on or about October 14, 2009 when these discovery 
document(s) “Request for Admissions and “Interrogatories” among other legal 
documents was finally being place in the U.S. mail and forwarded back to the 
Pro Se Plaintiff herein who made the discovery request over 2 and ½ years ago. 
24. 
Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable 
Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 cleverly crafty abusing his “attorney/client privileges, all work 
doctrine documents derive thereof; 
And all known communications between “Attorney and Client” 
Namely Defendant Antoine L. Freeman J. D. and Co-Defendant(s) “Joyce 
Guy and Edward McCray” herein to “Grand style” deceive the “Honorable 
Court” from having any “Legal Knowledge Via Pro Se Plaintiff herein “direct
discovery request” and “Investigation” fully focus on among other things Co- 
Defendant(s) “Joyce Guy and Edward McCray” 
Collectively in the past did in fact submit numerous Hurricane relief 
damages claims being in the form of construction contractor’s estimates to their 
“Insurance Companies” and possibly FEMA for relief of damages caused by 
Hurricanes Rita, Humberto, and Ike for the property located at 448 DeQueen blvd. 
in Port Arthur, Texas. 
To include Property located at 5050 east 7th Street in Port Arthur Texas, and 
Property Located at Blk 4 Lot. 10 Lake View in Jefferson County Texas all own and 
in the possession, custody, and control of the Co-Defendant(s) 
As Pro Se Plaintiff making claims before the 58th Judicial District Honorable 
Court of Co-Defendant(s) “Joyce Guy and Edward McCray” past fraudulent 
“practice and patterns” thereof after the corrupted hostile “acts and actions” 
directed at the Pro Se Plaintiff herein as being described in paragraph (17-24) 
above. 
25. 
Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable 
Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 having full prior knowledge that existence of a “property lien” was 
enforced by SWMJ Construction Inc. filed on June 18th 2009 in Jefferson County 
Clerk Office 
Being against Co-Defendant(s) “Joyce Guy and Edward McCray” as it was 
relating to “among other things” “Material Evidence” Pro Se Plaintiff sought 
history showing Co-Defendant(s) making other Fraudulently scheme of things 
involving monetary relief of damages caused by Hurricanes Rita, Humberto, and 
Ike for the property located at 448 DeQueen blvd. in Port Arthur, Texas. There 
after already ripping off the Pro Se Plaintiff in 2007 storm season. 
26.
Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable 
Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 having a Profession eye on the civil damages this discovery would 
affect Defendant(s) presumed innocent standing before the Honorable Judge 
Bob Wortham conspire with “obstruction of Justice” to continue to commit to 
conceal this “material evidence” from the Plaintiff when it was required to be 
produce in Pro Se Plaintiff Discovery Request devise. 
27. 
Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable 
Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 also having “insider information and communications” with Co- 
Defendant(s) “Joyce Guy and Edward McCray” conspire further with 
“obstruction of Justice” to continue to commit to conceal this “material 
evidence” that Co-Defendant(s) “Joyce Guy and Edward McCray” was in fact in 
the legal process of having the old Home torn down while the ongoing civil 
actions was still pending before the 58th District Court of Jefferson County Texas 
to include Co-Defendant(s) “Joyce Guy and Edward McCray” 
Collectively having a “New Home” secretly being built at the cost of 
$76,000.00 U.S. Dollars on a “Federal Grant” kept 100% secret from the Pro Se 
Plaintiff Discovery and The State Court while this Civil Suit in common Law had 
commence in 2007 as was well ongoing out of control at this point under (RICO). 
As Defendant himself Antoine L. Freeman J. D. Attorney at Law Texas Bar 
No. 24058299 confirm and described in Pro Se Plaintiff First Set of 
“Interrogatories” the “Texas Department of Housing & Community Affairs” 
issuance of a “Housing Grant” in favor for the Co- Defendant(s) “Joyce Guy and 
Edward McCray” all of which in fact fraudulently obtain being in fact a “Federal 
Housing Grant” on the behalf of “Texas Department of Housing & Community 
Affairs” 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Co-Defendant(s) herein making further fraudulent claims
before said “Texas Department of Housing & Community Affairs” that Pro Se 
Plaintiff was the primary cause of damages to the old home derive thereof for Co- 
Defendant(s) “Joyce Guy and Edward McCray” needing a “New Home” based 
upon poor, Unsatisfactory contractor “workmanships” and “craftsmanship” being 
committed by Pro Se Plaintiff Louis Charles Hamilton II herein for the $10,800.00 
U.S. Dollars Contract already sub-mitted to previous “Insurance Company” by Co- 
Defendant(s) in regards to Hurricane Humberto storm related damages. 
28. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 having a Profession legal eye on the “civil damages” this Pro 
Se Plaintiff discovery request would affect Co- Defendant(s) “Joyce Guy and 
Edward McCray 
Presumed innocent standing before the Honorable Judge Bob Wortham 
clear back in 2008 long before Co-Defendant(s) “Joyce Guy and Edward McCray 
further fraudulently obtain a “New Home” secretly being built at the cost of 
$76,000.00 on a Federal Grant Defendant Antoine L. Freeman J. D. Attorney at 
Law conspire further with “obstruction of Justice” to conceal the destruction of 
the old home And the new home being built 
Defendant Antoine L. Freeman J. D. Attorney at Law further conspire and 
work in concert to assure no delays ever being a factor in the construction of the 
New Home” Located at 448 DeQueen Blvd. in Port Arthur Texas would be 
primary cause if the “Honorable Judge” Bob Wortham, of 58th Judicial District 
Court of Jefferson County Texas would in all facts and circumstances reach Pro 
Se Plaintiff discovery document(s) containing “Material Facts” of among other 
things while this ongoing civil suit still pending a “Property Lien” already 
previously in Forced against Co-Defendant(s) collectively as described in 
paragraph (25) above 
To include a “New Home” secretly being built under the noise of the Pro Se 
Plaintiff herein and the “Honorable Judge” Bob Wortham, during this pending
civil action Docket No. A-180805 at the cost of $76,000.00 on a “Federal Grant” 
as the secretly destruction of the older home took place once being 
“Official Dwelling” to this ongoing Civil Suit involving the dwelling in 2007 
located at 448 DeQueen Blvd. in Port Arthur Texas, Now secretly destroyed in 
2009 before the Honorable 58th Judicial District Court of Jefferson County, Texas 
ongoing civil court case. 
29. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Co-Defendant “Joyce Guy and Edward McCray” secretly 
filed on June 18th 2009 transfer of property over to the “Texas Department of 
Housing & Community Affairs” at the Jefferson County Clerk Office File 
#2009022762 during this ongoing civil action with the Defendant collusion to 
keep all of this absolutely secretly claiming under 
“Attorney/Client Privileges”, Product of Work Doctrine and 
Communications made between Attorney and Client absent the fact this is very 
material facts in a ongoing civil suit against the Co-Defendant(s) collectively 
under the legal defense of Attorney at Law criminally withhold such discovery as 
request to release such favorable Document, Material facts, and circumstances. 
30. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Co-Defendant “Joyce Guy and Edward McCray” secretly 
filed on June 18th 2009 Fraudulent “Financing Statement” at the Jefferson 
County Clerk Office File #2009022763 to obtain from “Texas Department of 
Housing & Community Affairs” $76,000.00 on a “Federal Grant” as the secretly 
destruction of the older home took place during this ongoing “Civil Suit” 
31. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” 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) 
To achieve the same fraudulently monetary objective(s) gain being 
$76,000.00 “New Home” on a “Federal Grant” shamefully submitted Before the 
“Texas Department of Housing & Community Affairs” by Co-Defendant(s) after 
already “Greedy Squandering” all of the Numerous Insurance Funding” from 
each previously Hurricane “Rita”, “Humberto”, and “IKE” related storm damages 
on the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 had a duty to disclose all material facts as described herein 
and regardless of his “Attorney/Client defense of the Co-Defendant(s) 
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 was obligated to conform with the Texas Rules of Civil procedures in 
Discovery phase of a Civil Suit in common law within the State of Texas 
Regardless of it criminal/civil fall out affect being properly in placement 
upon the Co-Defendant numerous fraudulent acts and actions discovery of a 
shocking further investigation involving “among other things” the actual 
designed “Fraud of Contractors” related to “Insurance Company” Scams and 
scheme of things the Co-Defendant(s) monetary calculated and concocted. 
32. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“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) . 
33. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Pro Se Plaintiff herein because of the many “hostile” acts 
and actions direct at the Pro Se Plaintiff civil rights, peace and dignity by the Co- 
Defendant(s) herein 
Pro Se Plaintiff conducted a Special Exclusive in-depth Investigation into 
the Co- Defendant(s) “Joyce Guy and Edward McCray” to provide the Honorable 
58th Judicial Court of Jefferson County Texas”, 
Solid proof of the Co-Defendant(s) collective History of corrupted 
“pattern and practices” involving “fraudulent monetary scheme of things 
Nature” to” legally discovery” all of the following ongoing corrupted in design 
acts and in one primary case being a actual “Illegal Medical Enterprise” for the 
elderly disable senior citizens within in Jefferson County Texas 
34. 
Co- Defendant(s) “Joyce Guy and Edward McCray” mutable business E and 
J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur Texas, J Can 
Company 1807 East 7th Street Port Arthur Texas, G and G Service Company P.O. 
Box 515, 416 DeQueen Blvd. in Port Arthur Texas and, “Cars and Pieces” Located 
in Beaumont Texas (Office) also located at 448 DeQueen Blvd. in Port Arthur 
Texas 77640 
Are all in fact legally owned by the Co-Defendant(s) collectively herein as 
records do in fact “indicate” and on file with the “Jefferson County clerk” 
35.
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” the Co-Defendant(s) “Joyce Guy and Edward McCray”, filed 
with the Jefferson County Clerk #2009022763 “Financing statement” to obtain 
the “Texas Department of Housing & Community Affairs” $76,000.00 on a “New 
Home Federal Grant” 
“However” Co-Defendant(s) “Joyce M. Guy” omitted and refused to provide 
correctly all factual income detail in this “Financing Statement” of the Assumed 
Name Business G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port 
Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640 
In which this is in facts and circumstances a “illegal medical business” for 
the disable elderly senior citizens of Jefferson County Texas has never had a 
HCSSA license on filed with the State of Texas nor was a HCSSA license ever 
attempted to be correctly filed with the State of Texas which all of this was 
ongoing from the dates of May 5th1997 throughout January 7th 2010 for a period 
of 13 years of “Earn Income” with cash being paid to all “employees” when it was 
order shut down by the State of Texas Department of Aging and Disability Services 
until a real licensed being obtain. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” on December 1st of 2009 is when the (Pro Se Plaintiff) filed a 
formal complaint with “Texas Department of Aging and Disability Services” in 
regard to this “Illegal” Medical Business” namely “G and G Service Company” 
P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas of Co-Defendant(s) 
“Joyce M. Guy” (Actually) this medical business operations of G and G Service 
Company being secretly conducted on a (Vacant Lot)  
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” as a result of Pro Se Plaintiff “Investigation” Co- 
Defendant(s) “Joyce M. Guy” was order in Person as Pro Se Plaintiff was on his 
cell phone by the “State of Texas” “Texas Department of Aging and Disability 
Services” to shut down said “Illegal medical business” until a real HCSSA license 
is obtain with the State of Texas. 
36.
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” at this time frame Defendant Antoine L. Freeman J. D. 
Attorney at Law Texas Bar No. 24058299 was fully aware of the “Texas 
Department of Aging and Disability Services shutting down said “Illegal medical 
business” 
“G and G Service Company” until a real HCSSA license is obtains with the 
State of Texas which Defendant Antoine L. Freeman J. D. “Attorney at Law” 
understood directly Pro Se Plaintiff himself being the direct cause for “Illegal 
medical business” G and G Service Company being closed against Co- 
Defendant(s) while this civil suit was ongoing in the 58th Judicial District Court of 
Jefferson County Texas 
Defendant (Attorney at Law) herein conspire further to protect the Co- 
Defendant(s) from any further civil/criminal fall outs there past history might 
dictate in Fraud scheme of things as described herein to the point Defendant 
conceal all of the Pro Se Plaintiff Discovery request document(s) throughout the 
years of 2007, 2008 and 2009 when Texas law of Civil procedure require a reply 
well within 30 days of receiving said discovery request. 
Defendant (Attorney at Law) herein told “Judge Bob Wortham” he was 
only retain to file a “General Denial” (Only) while secretly conceal all of the Pro 
Se Plaintiff Discovery request document throughout the years of 2007, 2008 and 
2009 to assure Co-Defendant(s) “Joyce Guy and Edward McCray” fully protected 
from any present and future civil/criminal fall outs occurring 
Based upon Pro Se Plaintiff Investigations into the Mutable Corrupted 
Business “patterns and practices of the Co-Defendant(s) herein to include but 
not limited to The Pro Se Plaintiff knew Co-Defendant “Edward McCray” 
seriously engage in “sales” of a “Crack Cocaine” Industry and having mutable 
arrest. 
37. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Special Exclusive in-depth Investigation into the Co- 
Defendant(s) “Joyce Guy and Edward McCray” further reveal J Can Company 
1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen Blvd. in
Port Arthur Texas 77640 being owned by the Defendant(s) “Joyce Guy and 
Edward McCray”, assumed name filed on April 11th 2008 Jefferson County Clerk 
records #72594 
1807 East 7th street in Port Arthur Texas is actually a “Vacant Lot” which 
has been raided by the PAPD Dept. (Police) several times for engaging in “illegal 
Scrap Industry” 
“Moreover” once all “Illegal Scrap Metal” other then used Cans being 
recycle and obtain in the City of Port Arthur Texas city limits by Defendant 
“Edward McCray”, by the business J Can Company being now introduced as 
“Scrap Metal” in connection with “Cars and Pieces” business Located in 
Beaumont Texas (Office) also located at 448 DeQueen Blvd. in Port Arthur Texas 
77640 
Making the final “Legal sales” of all “illegal scrap” obtain in the City of 
Port Arthur Texas city limits by Defendant “Edward McCray”, 
“Moreover” Pro Se Plaintiff Louis Charles Hamilton II herein (Fully) quite 
“elementary sure and certain” after prior raid by the (PAPD) Police into “illegal 
scrap” of J Can Company that this “many years of “baffling exchange” transfer 
rate of 
“Illegal scrap” from Port Arthur Texas City Limits has been confusing the 
(PAPD) Police in the exchange rate form now “legal scrap” derived in 
“Beaumont Texas” from J Can Company “Namely”, “Cars and Pieces” business in 
Beaumont Texas being now major illegal scrap metal “money laundering” “Earn 
Income” system for Co-Defendant (Edward McCray) derived from this “criminal 
endeavor. 
To include but not limited to, upon information, belief and personally 
witness Co-Defendant “Edward McCray” usage of “Vacant Lot” being J Can 
Company to secretly continue engaging in the sales of a “Crack Cocaine 
Industry”. 
38.
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendants Antoine L. Freeman, J.D. “Attorney at Law” at 
the very start clearly in December of 2007 was engaging in Professional Skills of a 
Attorney at Law” in a “Legal” ongoing court room obligations to defend this civil 
case A-180805 against Pro Se Plaintiff 
Defendant made Fraud upon the 58th Judicial Court claiming in a document 
filed by defendant his only legal job was to draft a (Simple) General denial on 
behalf of the Defendants filed on December 18th 2007, as such to avoid a default 
on behalf of Co-Defendant(s) by filing his original Answer and at that point his 
“Fiduciary Duty” to his clients and before the Court ended on that date December 
18th 2007 and was legally completely over, 
Which this is not the case as Defendant (Attorney at Law) Fully scuttles all 
discovery materials received from Plaintiff in this civil matter from December 18th 
2007- November 13th 2009 being the official day while in possession of Plaintiff 
request to disclose Pursuant to Rule 194 during the entire year of 2008-2009 
Defendant Antoine L. Freeman, J.D. “Attorney at Law fail well within (30) days of 
this request, for the information or material described in Rule 194.2: by a period 
of over (2) years past the (30) days requirement to answer not only Pro Se 
Plaintiff “Request to Disclose” Pursuant to Rule 194, 
Defendant (Attorney at Law) was also served Pursuant to Rule 198 of the 
Texas Rules of Civil Procedure Plaintiff Request for Admission(s) and Pursuant to 
Rule 197 of the Texas Rules of Civil Procedure Pro Se Plaintiff Set of 
Interrogatories all of which required a reply within (30) days of these request as 
Defendant a skilled (Attorney at Law) having full knowledge that a discovery 
phase process had commence in this civil legal matter refuse to submit any 
“response or reply” to all being described in paragraph (38) herein for a period of 
(1) year and (11) Months and Pro Se Plaintiff Filed “Motion for sanctions” against 
said Defendant (Attorney at Law) in violation of Rule 193.1 of the Texas Rules of 
Civil Procedure. 
39.
Defendant (Attorney at Law) in his defense of Plaintiff motion for Sanctions 
committed to the Following Fraudulent activities upon the 58th Judicial District 
Court of Jefferson County Texas and all court records derive thereof. 
a. Engage in having Co-Defendant “Joyce M. Guy” Subscribed and Sworn a 
Affidavit in Support of Defendant (Attorney at Law) dated September 
11, 2009 
b. File a Response to Plaintiff’s Motion For Sanctions also committed to the 
same act of having this document “Subscribed and Sworn on the 11th 
day of September 2009 
c. Submitted all fact therein as being true before a Court of Law. 
40. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Affidavit of Co-Defendant “Joyce M. Guy” admit Defendant 
(Attorney at Law) informed Co-Defendant between April 2nd, 2008 and April 
11th, 2008 about Pro Se Plaintiff “Discovery Request” providing proof that 
Defendant (Attorney at Law) was in fact in possession, custody, and control of 
said discovery request while representing to the “Honorable Court” this was not 
the case. 
41. 
Defendant (Attorney at Law) herein did not file any notice with the Pro Se 
Plaintiff or the District Court of Jefferson County Texas that he was not 
representing the legal interest of the Co-Defendant(s) “Joyce Guy and Edward 
McCray”, there after filing “the original answer” with the District Court back in 
December 18th of 2007 when Defendant (Attorney at Law) herein in fact stating 
having Pro Se Plaintiff Discovery in Defendant own Affidavit being in his 
possession as of April 2nd, 2008. 
42. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant (Attorney at Law) herein stated to the
Honorable 58th Judicial District Court also, that his only duty was to file a 
original general denial (only) and this was what his “Legal” services as a 
Attorney in this matter was only retain for in his defense for Sanctions against 
him as described herein this complaint.,” 
“However” Pro Se Plaintiff States”, “Affirm” and “Declare” and further 
maintain that Defendant Antoine L. Freeman J. D. “Attorney at Law” Texas Bar 
No. 24058299 did in fact make a court appearance in a hearing the Pro Se “set” 
before the Honorable 58th District Court 
Pro Se Plaintiff also filed a (TRO) “Temporary Restraining Order” in this 
same civil matter A-180805 against Co-Defendant “Joyce M. Guy” to protect her 
own “Mother” Norma Guy, and the resident living in that dwelling whom Co- 
Defendant (Guy) having “Power of Attorney” Over her Mother Legal Affairs, 
filed in Jefferson County #2010042042 at which during this same time frame Co- 
Defendant having process the same scheme and scam of things regarding 
Insurance and FEMA fraud of the property of 5050 East 7th street in Port Arthur 
Texas being Norma Guy Home Mother of the Co-Defendant (Guy). 
43. 
Defendant (Attorney at Law) made another court appearance and argued 
this issue of a (TRO) alone before the Honorable Judge Bob Wortham, and at no 
time was Defendant not acting in the capacity as “Attorney of Record” from the 
time of filing his notice of counsel until Defendant (Attorney at Law) filed 
Motion to withdraw as Attorney of Record. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant (Attorney at Law) herein sat on Pro Se Plaintiff 
entire Discovery Request in excess of 16 Months and refuse to file a reply, file 
any type notice with the court during this 16 Months time period while Texas 
Rules of Civil Procedure require 
Defendant a professional Attorney at Law Adhere to local rules of the 
Court System and reply within (30) days not on a time table of (16) later after 
service of Said Discovery request by Pro Se Plaintiff Louis Charles Hamilton II.
44. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant (Attorney at Law) herein, further state 
Defendant then took a even bolder set in “Obstruction of Justice” in that after 
(16) of scuttling Pro Se Plaintiff Discovery request to further Hide all of the 
corruption going on at present time in the destruction of the old home and the 
new one being built, during this ongoing Civil Suit and all of the inquiries being 
made by the Pro Se Plaintiff regarding Fraud relating to Insurance Companies 
Former Contractors, and Hurricane “Rita”, “Ike” and “Humberto”. 
Defendant (Attorney at Law) herein provided further Fraud upon the 
Court in Fraudulent Information in the Interrogatories, and Never Investigated 
the circumstances of the questions being raised surrounding the “Theft” of The 
Pro Se Plaintiff Construction Tools by the Co-Defendant(s) “Joyce M. Guy” and 
“Edward McCray”, 
Defendant (Attorney at Law) completely cover up the Co-Defendant(s) 
collective wrong doings from the Honorable Court per Pro Se Plaintiff Discovery 
Request being scuttled for (16) months time frame as being described in 
paragraph (43) above. 
45. 
Defendant (Attorney at Law) made as if no Construction tools where ever 
on the property of the Pro Se Plaintiff being complain of 
To include Defendant (Attorney at Law) supply false answer(s) in the 
same Interrogatories that the Co-Defendant “Edward McCray” never even 
meeting the Pro Se Plaintiff Step Father (Lewis Garza) whom actually help 
delivery all of Pro Se Plaintiff said in excess of $3000.00 U.S. Dollars in 
construction tools to the dwelling in his Truck to the Home of The Co- 
Defendant(s) “Joyce M. Guy” and “Edward McCray” on November 16th 2007. 
Defendant (Attorney at Law) did not Investigate any of these facts nor was he 
ever even concern to attempt to investigate into the issues of the were about of 
Pro Se Plaintiff Construction tools.
45. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” after Defendant (Attorney at Law) was officially no longer 
“Attorney of record” of the Civil action in Texas State Court from the time frame 
of December 18th 2007 – filing General Denial to November 13th 2009 when 
Defendant (Attorney at Law) filed with the Clerk of Court of Jefferson County 
Texas a Motion for Withdrawal of Counsel 
The Co-Defendant “Joyce M. Guy and Edward McCray” continue to refuse 
to turn over said “Discovery Request” of the Pro Se Plaintiff 
To the point a Court Order of the 58th Judicial District Court was obtain 
and enforced as Follows: 
46. 
Ordered that Co-Defendants “Joyce Guy and Edward McCray” shall 
produce copies of deeds, property deeds or any other such physical document in 
Defendants possession, custody or control that shows actual ownership of the 
property of the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas 
47. 
Ordered that Co-Defendants “Joyce Guy and Edward McCray” shall 
produce copies of any and all construction estimates for repairs in Defendants’ 
possession, custody or control in relationship to the damages caused by 
Hurricanes Rita, Humberto and Ike to the Property located at 448 DeQueen 
Blvd. in Port Arthur, Texas. 
As so Ordered on the 10th day of May 2010 by the 58th Judicial District 
Court of Jefferson County Texas filed at 11:46 am. 
48. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” that Co-Defendants “Joyce Guy and Edward McCray” 
remain in Hostile abscond scuttle refusal of the Honorable Court Order as of the
undersigned date in the Month of November 2014 of this Complaint being 
refilled in U.S. District Court. 
49. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” because of Defendant Antoine L. Freeman J. D. Attorney at 
Law Texas Bar No. 24058299 acting in his skilled profession to fraud the court 
and belittle the Pro Se Plaintiff and his discovery request for a period in excess 
of 16 months in possession thereof 
To include Defendant (Attorney at Law) herein unethical commitment to 
conspire further under the disguise of “Attorney/Client” privileges. Work 
Product doctrine, and all Communications thereof being secrete between the 
Defendant (Attorney at Law) and the Co-Defendant(s) “Joyce Guy and Edward 
McCray” 
To the point such Fraud commits by the Defendant (Attorney at Law) on 
the Jefferson County 58th Judicial District Court completely forced the Pro Se 
Plaintiff to be at an extreme “civil disadvantage” in the ongoing court 
proceeding in the time frame of 2007-2009 and present in 2014 throughout 
2015 
Based solely upon Defendant (Attorney at Law) Rouge (RICO) “obstruction 
of Justice” among other things being fully professional hire “Legal Gun” 
knowledge thereof to scuttle, omit, delay and fraudulently mishandling required 
duties to supply a honest, required respond to all of Pro Se Plaintiff discovery 
request in a timely fashion, within the (16) months being in possession, custody 
and control of said Pro Se Plaintiff Discovery request. 
50. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 retainer fees was solely paid to keep the Co-Defendant(s)
numerous discover fraud by the Pro Se Plaintiff absolutely 100% top secret from 
the 58th Judicial Court” 
while the other newer $76,000.00 U.S. Dollars “scheme of things” being in 
current play and process to now a ongoing (RICO) fraud the Co-Defendant(s) 
concocted involving Fraud (Now) The “Texas Department of Housing & 
Community Affairs” issuance of a “Housing Grant” in favor for the Co- 
Defendant(s) “Joyce Guy and Edward McCray” 
All of which in fact being fraudulently obtain from “Federal Housing 
Grant” on the behalf of “Texas Department of Housing & Community Affairs” 
while the civil suit is “Live” and pending” which Co-Defendant(s) conspire to 
keep this under wraps from any financial setback glitches being fully caused by 
The Pro Se Plaintiff bring this additional Fraudulent activities before The 
Honorable Court well deserved attention. 
51. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law 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 All of which Pro Se Plaintiff herein “States”, “Affirm” and “Declare” 
further before the “Honorable Justice” solely done by Defendant (Attorney at 
Law) (Only) to conspire in the illegal (RICO) aid to hide all of the Co-Defendant(s) 
“Joy M. Guy” and “Edward McCray” many corrupted Business Enterprises 
endeavors,
Mutable Counts of Fraudulent activities involving Hurricane “Rita”, “Ike” 
and Humberto” Monetary rip off scams against FEMA, Building Contractors 
estimate and invoices and Home Owner Insurances Companies repair funds 
Couple with the (Now) live ongoing new 2009 fraud activities of the Co- 
Defendant(s) “Joy M. Guy” and “Edward McCray” involving “Federal Housing 
Grant” on the behalf of “Texas Department of Housing & Community Affairs” in 
excess of $76,000.00 U.S. Dollars 
52. 
Defendant (Attorney at Law) herein known lying with a consciousness 
mind and disregard for the consequences for his actions in the “capacity as an 
Attorney of Law”, Antoine L. Freeman J. D. conspire to continue to use his legal 
lawyer skills” in the full “aid and abetting”, and commitment to “Obstruction of 
Justice” in the capacity of a Attorney at Law forthwith in providing his own 
numerous Attorney fraud legal commitment upon the 58th Judicial District of 
Court of Jefferson County Texas, the Court records thereof as being fully 
described in this U.S. District Court Complaint. 
And being in full criminal (RICO) concert, collusion, corruption and 
conspiracies thereof for all monetary fraudulent assets gains of the Co- 
Defendant(s) “Joy M. Guy” and “Edward McCray” 
Both being “ill-gotten pirate loot” from the “past” Hurricanes Seasons 
“Rita”, Ike” and “Humberto” and “present” pirate loot” “Federal Housing Grant” 
on the behalf of “Texas Department of Housing & Community Affairs” in excess 
of $76,000.00 U.S. Dollars of the Co-Defendant(s) “Joy M. Guy” and “Edward 
McCray” 
53. 
Fully affecting the Pro Se Plaintiff (Life) with “among other things” cause 
of action for “actual damages” being in excess of $336,000.00 U.S. Dollars in 
“lost wages” from 2007 – 2014 and “actual damages” in excess of “3093.00 U.S. 
Dollars in all of the Pro Se Plaintiff Construction tools causing the Plaintiff undue
unwanted extreme hardship, infliction of emotional distress and anguish in the 
“Theft of Pro Se Construction Profession” for a ongoing time frame over (7) 
years and still counting well into 2015 The Texas State Civil Suit is “Live” and 
ongoing due in large part to Defendant (Attorney at Law) herein 
Numerous (RICO) “acts and activities” to commit “among other things” a 
,complete assault of “Obstruction of Justice” and “Fraud upon a Court” in the 
58th Judicial District Court of Jefferson County Texas 
In a Suit in “Common Law” for the rouge disgrace benefit of his skilled 
profession as a “Attorney of Law” to skillfully cover up a Co-Defendant(s) “Joy 
M. Guy” and “Edward McCray” clients “Long Bogus Quite Profitable Crooked 
Road of “Fraudulent History” being described fully herein and direct against The 
civil rights, peace and dignity of the Pro Se Plaintiff herein. 
54. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 herein used his skills as a “Attorney of Law” to commit fully to 
“Obstruction of Justice” for (16) months in refusal to reply to Pro Se Plaintiff 
Discovery Request to “facilitate”, and “conceal” Co-Defendant(s) “Joyce M. Guy 
and Edward McCray” by provide (Attorney in Law) Professional Legal efforts to 
evade the 58th Judicial District Court of Jefferson County Texas proper 
administration of Justice in the complaint A-180805 against all of the Fraud 
activities already being described in said complaint against said Co-Defendant(s) 
herein. 
Furthermore Defendant (Attorney at Law) keeping the “Honorable Court” 
and The Pro Se Plaintiff isolated in 2008 while the ongoing (RICO) racket scheme 
of things currently ongoing fraudulent activities involving the secrete 
destruction of the old home located at 448 DeQueen Blvd. in Port Arthur Texas 
in exchange for a new one at the same location all of which being secretly done 
while the “older home” still being a civil issue of Fraud as described by the Pro 
Se Plaintiff before the “Honorable Court”.
55. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 herein “facilitate” all of his own “Fraudulent Activities” upon 
the Pro Se Plaintiff and fraud of the 58th Judicial District Court of Jefferson 
County Texas for the full benefit of hiding the Co-Defendant(s) “Joyce M. Guy” 
and “Edward McCray” numerous corruption activities with the usage of the 
“United States Mailing System” to further long this fraudulent “scheme of 
things” before a “Honorable Court of Law” within the State of Texas and further 
long this “civil scheme” against the Pro Se Plaintiff as being described herein this 
complaint. 
56. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 herein “facilitate” all of the Co-Defendant(s) “Joyce M. Guy” 
and “Edward McCray” described corruption(s) and fraudulent activities with the 
usage of the “United States Mailing System” to further long this fraudulent 
“scheme of things” before a “Honorable Court of Law” within the State of Texas 
and further long this “civil scheme” against the Pro Se Plaintiff as being 
described herein this complaint. 
57. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 herein “facilitate” all of his own “Fraudulent Activities” and 
that he further conspire to and did in all facts and circumstances “facilitate” 
provide concealment, evade Justice for all of the Co-Defendant(s) “Joyce M. 
Guy” and “Edward McCray” described corruption(s) and “fraudulent activities” 
with the usage of the Jefferson County “Clerk of Court” Office Computer System, 
electronic records, and filing system thereof to further long this fraudulent 
“scheme of things”
Before an “Honorable Court of Law” within the State of Texas and further 
long this “civil scheme” against the Pro Se Plaintiff as being described herein this 
complaint. 
58. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 herein “facilitate” and engage further in the usage of Extrinsic 
Fraud and tactics in the position as opposition counsel for the legal interest of 
Co-Defendant(s) “Edward McCray and Joyce M. Guy” to stop, conceal and 
hinder Pro Se Plaintiff from rightfully being involved in said discovery request, 
so Pro Se Plaintiff not being able to obtaining favorable evidence to use as a 
advantage to prosecute civilly against the Co-Defendant(s) “Joyce M. Guy” and 
“Edward McCray” in the civil suit in State Court. 
59. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” 
committed to defamation of the Pro Se Plaintiff as being a dishonest, unskilled, 
substandard Construction Contractor and Pro Se Plaintiff is the reasoning for the 
older home located at 448 DeQueen Blvd. in Port Arthur Texas being 
demolished for providing faulty contractor structural work and repairs being 
unskillfully provided by Pro Se Plaintiff herein. 
60. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” used 
the defamation of the Pro Se Plaintiff substandard construction performance 
tactics with their previously Home Owner Insurance Company to satisfied any 
suspicion concerning the $10,800.00 dollars already wrongfully squander by said 
Co-Defendant(s) herein.
To include Co –Defendant(s) “Joyce M. Guy and Edward McCray” herein 
used the same defamation of the Pro Se Plaintiff character against the “Texas 
Department of Housing & Community Affairs” claiming further Pro Se Plaintiff 
being a substandard contractor in construction performance by providing faulty 
contractor structural work and repairs skills to the dwelling of 448 DeQueen and 
Pro se Plaintiff being directly responsible for the need of destruction of the old 
dwelling thereof in Port Arthur Texas 
in order through this same wrongful scheme of defamation of the Pro Se 
Plaintiff contractor skills to obtain further a New Home with this scheme of 
things through the “Texas Department of Housing & Community Affairs” other 
than the Co-Defendant(s) own numerous actual fraudulent activities in engaging 
in squandering all of the funds paid out for actual repairs as a result of 
Hurricane “Rita”, “Ike” and “Humberto” being done to said home. 
61. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 herein “facilitate” the same defamation of the Pro Se Plaintiff 
as being a dishonest, unskilled, substandard Construction Contractor and Pro Se 
Plaintiff is the reasoning for the older home located at 448 DeQueen Blvd. in 
Port Arthur Texas being torn down and a new one being built. As described in 
paragraph (59 and 60) above. 
62. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” on or 
about the dates of April 2nd 2008 and or April 11th 2008 Co-Defendant(s) 
admitted collectively of the involvement to “Entice”, “Induce”, “Allure”, and 
“Ensnare” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 herein in his “Legal Capacities” as a “Attorney at Law” 
To commit to “Actual Fraud” of the 58th Judicial Court” of Jefferson 
County Texas For the (RICO) purpose of “delays”, “concealment”, “omitting”
and “hindering” all material facts, accounts, material circumstances both being 
past and present of the Co-Defendant(s) “corrupted enterprise activates” 
The Pro Se Plaintiff herein made numerous complaints thereof in Court 
filing records “Docket No. A-180805 and Before the State of Texas Investigation 
Services into the elderly 
As well as all “discovery investigations” Pro Se Plaintiff was pursuing 
presently during said State Court Civil Complaint involving Co –Defendant(s) 
“Joyce M. Guy and Edward McCray” herein 
In which further on or about April 2nd 2008 and or April 11th 2008 Co – 
Defendant(s) “Joyce M. Guy and Edward McCray” herein Fully Conspire, 
maneuver, pilot, manipulated, scheme and monetary paid and financially secure 
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 
herein in his “Legal Capacities” as a “Attorney at Law” throughout the dates of 
November 13th 2009 of his “paid in full legal services” for a total of (19) months 
to absolutely Violate Rule 193.1 Texas Civil Procedure in replying to the Pro Se 
Plaintiff Discovery request 
In order to fully engage in the covering up (RICO) collective scheme of 
things of Co-Defendant(s) “Joyce M. Guy and Edward McCray” having 
committed against The Pro Se Plaintiff, 
58th Judicial District Court, Insurances Companies, State of Texas, and The 
United States of America’, in a long criminal corrupted enterprise of “Fraud for 
Monetary Gain” of said Co-Defendant(s) collectively “rip off” activities being 
described herein now Before The above entitled “Honorable” United State 
Federal Court having subject jurisdiction matter over the” Defendant and Co- 
Defendant(s)”. 
63. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” on or
about the dates of April 2nd 2008 and or April 11th 2008 throughout the present 
date of this U.S. Civil Complaint being made in the year of 2014 (November) 
Said Co-Defendant(s) Collectively Promoted, Pilot, Scheme, Induce, 
Engaged, and fully Conspire with Defendant Antoine L. Freeman J. D. Attorney 
at Law Texas Bar No. 24058299 herein to obtain in his “Legal Capacities” as a 
“Attorney at Law” in concert Violations of Chapter 96 of Title 18, United State 
Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 
(relating to mail fraud), section 1343 (relating to wire fraud), section 
1028(relating to fraud and related activity in connection with identification 
documents), Section 1503(relating to obstruction of justice), Falsification of 
“Material facts”, 
Fraud upon the 58th Judicial District Jefferson County Court, Fraud on The 
State of Texas, and The United States of America in such “Monetary 
Conspiracies involving the Pro Se Plaintiff herein, and Hurricane “Rita”, 
Humberto” and “Ike” related storm damages with the usage of such numerous 
corrupted Fraudulent tooling maneuvers, and manipulated complex activities 
involving among other things 
All Jefferson County Clerk of Office records, 58th Judicial Court documents, 
electronic court filing transmission, court transcripts, and The United States 
Mailing System to promote, secure, and continue maintaining such (RICO) 
activities against the Pro Se Plaintiff Louis Charles Hamilton II herein 
With Co-Defendant(s) collectively Racketeering Influences Corruption 
Organization activities being described both past and present now in a further 
racketeering scheme of things involving a “Rouge Attorney” activities through 
Co-Defendant(s) “Joyce M. Guy and Edward McCray” paid for hire “legal expert 
services” of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 herein. 
64. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray”
promoted, conspire and secure (RICO) “Obstruction of Justice” activities of 
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 
herein against 58th Judicial District Court complaint made thereof 
For a Period of (19) months between on or about April 2nd 2008 and or 
April 11th 2008 throughout November 13th 2009 to continue well into 2015 such 
(RICO) activities having continual legal affects as being described herein this U.S. 
Civil Complaint against the Pro Se Plaintiff civil rights, peace, and dignity. 
65. 
Cause of Actions 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” a Cause of Actions exist against Defendant Antoine L. 
Freeman J. D. Attorney at Law Texas Bar No. 24058299 And Co-Defendant(s) 
“Joyce M. Guy and Edward McCray” 
Collectively for each Violations of Chapter 96 of Title 18, United State 
Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 
(relating to mail fraud), section 1343 (relating to wire fraud), section 
1028(relating to fraud and related activity in connection with identification 
documents), Section 1503(relating to obstruction of justice), 
(RICO) activities upon the 58th Judicial District Court of Jefferson County 
Texas, and all court records, court documents electronic transmission, court 
transcripts, to include but not limited to “(RICO)” activities committed against 
“The Honorable Bob Wortham” himself being presiding Judge of Docket No. A- 
180805 filed in Jefferson County Texas, (RICO) against Insurances Companies, 
State of Texas, and the United States of America FEMA and Federal Housing 
Grant agencies 
To include but not limited to (RICO) activities disguised in a 
Attorney/Client Privileges, work doctrine, and all communications derived 
thereof
All (RICO) involvements being wrongfully committed against the civil 
rights, peace, and dignity of the Pro Se Plaintiff Louis Charles Hamilton II herein 
before a civil suit in common law within the State of Texas. 
66. 
Cause of Actions 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” a Cause of Actions exist against Defendant Antoine L. 
Freeman J. D. Attorney at Law Texas Bar No. 24058299 And Co-Defendant(s) 
“Joyce M. Guy and Edward McCray” 
Collectively for “Actual Fraud” and the performance thereof in the 
capacity of a “Attorney of Law” to include constructive fraud, fraudulent intent, 
fraudulent pretense, fraudulent concealment, fraudulent misrepresentation, 
fraudulent conveyance, Extrinsic Fraud, Fraud in fact and Fraud in law, fraud in 
the execution of Plaintiff construction contract by Co-Defendant(s) “Joyce M. 
Guy and Edward McCray” for purpose to fraud “Insurance Company” 
To include collectively Fraud on the Court involving fraudulent activities 
upon the 58th Judicial District Court of Jefferson County Texas, and all court 
records, court documents, electronic transmission, court transcripts, and 
document thereof 
Fraud against Insurances Companies, State of Texas, and the United 
States of America FEMA and Federal Housing Grant agencies involving Past 
Hurricane storm related damages all of which being described in paragraph (66) 
herein involving the Pro Se Plaintiff herein being past, present, and future 
thereof to commit monetary Fraud gain in among other things Fraud of 
Insurances Companies, State of Texas, and the United States of America FEMA 
and Federal Housing Grant agencies involving the dwelling located at 448 
DeQueen Blvd. In Port Arthur Texas
Committed against the civil rights, peace, and dignity of the Pro Se 
Plaintiff Louis Charles Hamilton II herein before a civil suit in common law 
within the State of Texas. 
67. 
Cause of Actions 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” a Cause of Actions exist against Co-Defendant(s) “Joyce M. 
Guy and Edward McCray” for Defamation of The Pro Se Plaintiff reputation and 
his Profession in construction in connection with Co-Defendant(s) collectively 
fraudulently activities to obtain a New Home 
And Co-Defendant(s) collectively maintain such defamation acts to secure 
a 76,000.00 U.S. Dollars Federal Housing grant in that the Pro Se Plaintiff “Louis 
Charles Hamilton II” herein is the “direct cause” of the dwelling located at 448 in 
DeQueen Blvd. in Port Arthur Texas being un-inhabitable for human living 
conditions due primary for substandard faulty structural construction repairs of 
said dwelling being committed by Pro Se Plaintiff herein 
Whom never even made any such repairs on said home just (Pro Se 
Plaintiff) construction contract being executed and used to continue fraud the 
Insurance company for more monetary wrongful gain of “insurance Company 
repair funds 
other than Co-Defendant(s) actually fixing Hurricane Humberto storm 
dames to dwelling located at 448 DeQueen Blvd. in Port Arthur Texas as 
described in this complaint Co-Defendant(s) ) “Joyce M. Guy and Edward 
McCray” Committed against the civil rights, peace, and dignity of the Pro Se 
Plaintiff Louis Charles Hamilton II, herein. 
68. 
Cause of Actions
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” a Cause of Actions exist against Defendant Antoine L. 
Freeman J. D. Attorney at Law Texas Bar No. 24058299 for “Actual Damages” 
In this (RICO) and Fraudulent numerous conspiracy corrupted scheme of 
things and corrupted activities in concert, and full collusion being also brought 
and paid for to “expert cooking the “legal court books” of a Honorable 58th 
Judicial Court of Jefferson County Texas in Favor of the corrupted (RICO) 
described Co-Defendant(s) herein 
To further along promote and fully cover up all (RICO) activities, Fraud of 
Insurances companies, FEMA and Federal Housing Grants both being “past and 
present” mutable fraudulent activities of the Co- Defendant(s) “Joyce M. Guy 
and Edward McCray” herein involving the Pro Se Plaintiff Louis Charles Hamilton 
II “Among others” being fully described herein to include but not limited to 
69. 
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 (RICO) and Fraudulent numerous conspiracy corrupted scheme of 
things activities in concert, and full collusion in the capacity of a “Attorney of 
Law” against the Pro Se Plaintiff personal property namely “Construction tools” 
in excess of #3000.00 U.S. Dollars and lost wages at a minimums of $48,000.00 
U.S. dollars per year “lost wages” since date of injury of November 2007 
And Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 to “continue depriving” the Pro Plaintiff of his entire “Construction 
Trade” and “Profession” in such a complex illegal rooted (RICO) conspirer and 
fraud of the court system “scheme of things” being attached to the “Actual 
theft” of all of the Pro Plaintiff Construction tools and profession trade thereof 
for a period now exceed (7) years and counting well into 2015 
As “Defendant and Co-Defendant” collectively enjoys and having 
monetary gain collectively thereof from such wrongful ongoing (7) years “civil 
victory” and corrupted (RICO) Fraudulent advantages, corrupted acts, and 
actions over the Pro Se Plaintiff civil rights, peace and dignity, and fairness to
the Texas Civil Rules of Civil Procedures in a “civil suit” in “common law” as 
being described herein this complaint 
70. 
Further being described once before the same U.S. District Court of 
Eastern District of Texas when (Pro Se Plaintiff) filed his first original (RICO) 
complaint being legally made thereof and now no question beyond any doubt 
ever being so “crystal clear” in 2014 (November) the Pro Se Plaintiff confident in 
being precise, and having a “well understanding” into this well twisted, 
calculated, future plotted, manipulated, (RICO) mutable Fraudulent count 
enterprising “scheming activities” derive thereof and its involvement with 
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) herein to depriving the Pro Se Plaintiff of his “personal property” 
namely “Construction tools” in excess of $3000.00 U.S. Dollars and “lost wages” 
at a minimums of $48,000.00 U.S. Dollars 
Pro Se Plaintiff being an “Independent Construction Contractor” suffrage 
“lost wages” per (7) year since date of injury of November 2007 in the “Actual 
Theft” of Said Construction tools. With 6% interest incurred since date of injury 
being November 2007 into the future of 2015 as this Complaint being “examine 
and entertain” before the “Honorable Justice” of such “Actual Damages” 
71. 
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 herein so did in all facts, court records, and real life circumstances 
commit to, designed further to caused the Pro Se Plaintiff herein to suffer 
extreme “monetary hardship” in such lost of “Actual Damage” in excess of 
$336,000.00 U.S. Dollars in (7) years of “Lost wages” and counting into 2015 
This (RICO) scheme of things in still enforced, ongoing and very live 
against the Pro Se Plaintiff Louis Charles Hamilton II
As Defendant (Attorney at Law) herein (RICO) activities with the Co- 
Defendant(s) same (RICO) activities commit his (Attorney at Law) profession to 
commit to fraud of the Court “while” being in possession, custody, and control 
as a “Officer of said 58th Judicial District Court of Jefferson County Texas 
Further Defendant (Attorney at Law) herein (RICO) activities acts and 
actions fully continue to depriving both past and present causing the Pro 
Plaintiff to continue suffrage “Actual Damages” in excess of $3000.00 U.S. 
Dollars in Lost of said “Construction tools” and the “Profession Trade” thereof 
since November 2007 well into the future of 2015. 
72. 
Pro Se Plaintiff seeks same such “Actual Damages” exceeding (7) years Co- 
Defendant(s) “Edward McCray and Joyce M. Guy” herein depriving the Pro Se 
Plaintiff of his “personal property” namely “Construction tools” in excess of 
$3000.00 U.S. Dollars and “lost wages” at a minimums of $48,000.00 U.S. Dollars 
being a Independent Construction Contractor “lost wages” per (7) year ongoing 
lost since date of injury of November 2007 in the “Actual Theft” of Said 
Construction tools. 
With 6% interest incurred since date of injury being November 2007 being 
lost as being described in paragraph (68) herein Defendant (Attorney at Law) 
conspire (RICO) with the Co-Defendant(s) “Edward McCray and Joyce M. Guy” 
In the ongoing Civil Action suit in Texas State Court Docket No. A-180805 before 
the 58th Judicial District Court of Jefferson County Texas 
Pro Se Plaintiff seeks such actual damages in a “Summary Judgment 
motion” just filed in November of 2014 and being heard “oral and argue” before 
the “Honorable 58th Judicial District Court of Jefferson County Texas on 
December 17th 2014 at 8:30 am as this “Honorable 58th Judicial Court 
Having full ongoing expert “subject matter jurisdiction” over the Co- 
Defendant(s) “Joyce M. Guy” and “Edward McCray” and all “actual damages” 
Pro Se Plaintiff seeks therein “State Court”
73. 
Other than Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” 
Collectively ongoing (RICO) Fraudulent activities among other “Federal Subject 
matter jurisdiction” wrongful “acts and actions” being committed in concert, 
collusion, and enjoyed manipulation and monetary gain derived thereof with 
Defendant as the Pro Se Plaintiff herein “Federal Questions” being raised before 
the “Honorable Justice” as to the Defendant and Co-Defendant(s) collective 
criminal/civil corrupted scheming uncivil behavior being committed 
Against the Pro Se Plaintiff civil rights, peace, will, and dignity in a Civil 
Suit in common Law in connection with the Defendant Antoine L. Freeman J. D. 
Attorney at Law Texas Bar No. 24058299 defense thereof. 
which this “United States Eastern District Court of Texas having full expert 
“Honorable Justice” Subject Matter” over such among other things (RICO) 
activities described herein full 
And the further full knowledge Defendant (Attorney at Law) executed in 
full wrongful conspire involvement being of a “Legal expert” to commit to 
among other things “obstruction of justice”, corrupted, misleading, 
manipulation” and fraud commitment upon the 58th Judicial District Court of 
Jefferson County Texas in the public professional trade “among all things” 
The “fiduciary capacity” of a legal “Attorney at Law” and “Officer of the 
Court” in and For the State of Texas. 
74. 
Cause of Actions 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” a Cause of Actions exist for “Intentional Infliction of 
Emotional Distress” against Defendant Antoine L. Freeman J. D. Attorney at Law 
Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward 
McCray”.
Pro Se Plaintiff herein Incorporated and state all Defendant (Attorney at 
Law) and Co-Defendant(s) herein enjoyed collectively their “Intent” scheming 
fraudulent manufactory purpose in wanting the Pro Se Plaintiff herein to suffer, 
extreme agony, heartache, distraint, Accompany substantially massive 
monetary loss of “tools and services” in the Construction profession, 
75. 
Humiliation, Defamation, and crushing legal defeat to inflict “excessive 
mental anguish” as a result of their combine craft complex ongoing conspire 
(RICO) elements, and fraud on the court to execute the same (RICO) objective 
All of which being past, present, and further derive thereof Pro Se Plaintiff 
suffrage such future (7) years of ongoing “mental intent contempt” of the 
Defendant and Co-Defendant(s) enforced legal corrupted strong hold over the 
“common law” rights of the Pro Se Plaintiff 
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray”. 
Civilly accomplish with strong corrupted concealment motive not to be 
“confused or construed” with a simple attorney mistake by Defendant (Attorney 
at Law) a combine collective “cause of action” before the “Honorable Justice” 
for continual past, present, and future “Intentional Infliction of Emotional 
Distress”. 
76. 
Cause of Actions 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” a Cause of Actions exist for “Declaratory Judgment” of the 
Honorable Court against Defendant Antoine L. Freeman J. D. Attorney at Law 
Texas Bar No. 24058299 and against Co-Defendant(s) “Joyce M. Guy and Edward 
McCray” as to all of the “material subject matter” fully declared past, present 
and future Before the Honorable Justice herein
Of the Defendant and Co-Defendant(s) Collective conclusive, conspire, 
concert, agreements, engagement, and execution, pilot, maneuver, 
manipulated, scheme upon (RICO) actions and dealing, 
Among other extreme behavior in fraudulent Corruption of The 58th 
Judicial District Court System to induce, and perpetrate such Fraud upon the 
Court for a period in excess of (19) Months as each so stated, affirm, and 
declared statement of “material facts”, “events” and “circumstances” described 
fully herein this Complaint 
77. 
Put an end to a doubt as to the “gross civil intention” of “Antoine L. 
Freeman J. D. An “Attorney”, direct at the Pro Se Plaintiff “Civil Liberties” for a 
cause of action for “Declaratory Judgment” is made enter into the “Honorable 
Justice” decision, and final announcement of the Court Records against said 
Defendant. 
78. 
Put an end to a doubt as to the “gross civil intention” of “Joyce M. Guy” 
and “Edward McCray” and their extreme scheming corrupted fraudulent 
behavior in “patter and practices” of Mutable (RICO) Fraudulent Scheming 
Enterprising Endeavors 
Co-Defendant(s) Collective conclusive conspire agreements, engagement, 
and execution, pilot, maneuver, manipulated, scheme upon (RICO) actions and 
mutable fraudulent underhanded dealing(s), 
Among other extreme outrageous behavior in fraudulent Corruption of 
“among others” The 58th Judicial District Court System to induce, and perpetrate 
such Fraud upon the Court for a period in excess of (19) Months 
As each so stated, affirm, and declared statement of “material facts”, 
“events” and “circumstances” described fully herein this Complaint direct at the 
Pro Se Plaintiff “Civil Liberties” a cause of action for “Declaratory Judgment” is
made enter into the “Honorable Justice” decision, and final announcement of 
the Court Records against said Co-Defendant(s) Collectively. 
79. 
Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the 
“Honorable Justice” a Cause of Actions exist for ‘Treble Damages” made enter 
into the “Honorable Justice” decision, and final announcement of the Court 
Records against said Defendant 
Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co- 
Defendant(s) “Joyce M. Guy” and Edward McCray” Collectively for their 
combine “wicked”, monstrous, appalling, atrocious, disgraceful, corrupted 
behavior direct at the Pro Se Plaintiff “Civil Liberties” . 
80. 
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves 
the Honorable Court Justice, to Award to the Pro Se Plaintiff “Declaratory 
Judgment” against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” 
Collectively in favor of the Pro Se Plaintiff. 
81. 
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves 
the Honorable Court Justice, to Award to the Pro Se Plaintiff “Actual Damages” 
against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 for 
fraudulent conspire against Pro Se Plaintiff “personal property” namely 
“Construction Tools” Pro Se Plaintiff Personal property Lost in tool(s) is in excess 
of $3093.00 dollars 
Award further with full 6% interest rate incurred since date of injury from 
November 16th 2007 continual on into 2015 in excess of at a rate of (7) years and 
continual counting in favor of the Pro Se Plaintiff 6% interest incurring. 
82.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves 
the “Honorable Court Justice”, to Award to the Pro Se Plaintiff “Actual 
Damages” against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 for fraudulently conspire against Pro Se Plaintiff as described herein 
this complaint for “Actual Damages” of “Lost wages” and “Loss of earning 
capacity” incurred in the “Continual Actual Theft” and “further executed 
fraudulent conspirers activities 
Derive thereof” and fully committed, manipulated, scheme against by 
Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 
herein in the “expert legal professional capacity” as a “Attorney of Law” 
Civilly in a Suit in “common Law” against the Pro Se Plaintiff “personal 
property” namely “Construction tools”, involving Pro Se Plaintiff Special Trade, 
Skill and Profession thereof, in excess of $48,000.00 U.S. Dollars per year in lost 
wages Being a accumulated rate now in excess of $336,000.00 U.S. Dollars for 
the past (7) years “Lost wages” and “Lost earning capacity” Pro Se Plaintiff 
endure suffrage thereof. 
“Award” further with full 6% interest rate incurred since date of injury 
from November 16th 2007 continual on into 2015 in excess of at a rate of (7) 
years past and continual counting in favor of the Pro Se Plaintiff 6% interest 
incurring. 
83. 
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves 
the “Honorable Court Justice” for damages in the amount of the Honorable 
Court Justice for the Plaintiff suffrage of “Intentional Infliction of Emotional 
Distress” and “Mental Anguish” in Excess of the Jurisdictional amount of 
$75,000.00 U.S. Dollars against Antoine L. Freeman J. D. Attorney at Law Texas 
Bar No. 24058299 in Favor of the Pro Se Plaintiff. 
84.
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves 
the “Honorable Court Justice” for damages in the amount of the Honorable 
Court Justice for the Plaintiff suffrage of “Intentional Infliction of Emotional 
Distress” and “Mental Anguish” in Excess of the Jurisdictional amount of 
$75,000.00 U.S. Dollars against Co-Defendant(s) “Joyce M. Guy” and Edward 
McCray” in favor of the Pro Se Plaintiff. 
85. 
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves 
the “Honorable Court Justice” for Award of “Treble Exemplary Damages” Statue 
of the “Honorable Court Justice” against Defendant Antoine L. Freeman J. D. 
Attorney at Law Texas Bar No. 24058299 in favor of the Pro Se Plaintiff. 
86. 
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves 
the “Honorable Court Justice” for Award of “Treble Exemplary Damages” Statue 
of the “Honorable Court Justice” against Co-Defendant “Joyce M. Guy” and 
Edward McCray” Collectively in favor of the Pro Se Plaintiff. 
87. 
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves 
the “Honorable Court Justice” for damages in the amount of the Honorable 
Court Justice for the Plaintiff suffrage of Defamation of the Pro Se Plaintiff 
Construction Reputation in Excess of the Jurisdictional amount of $75,000.00 
U.S. Dollars against Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” 
collectively in favor of the Pro Se Plaintiff. 
88. 
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). 
89. 
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 Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 
24058299 in favor of the Pro Se Plaintiff for (RICO). 
90. 
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves 
the “Honorable Court Justice” for a Order the Defendant and Co-Defendant(s) 
collectively pay all court cost of this U.S. Civil Court Action. 
91 
Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves 
and Request the “Honorable Court Justice” for any further, Just, proper, 
Damages, Orders, and Awards The “Honorable Court Justice” Deems favorable 
for the behalf of Pro Se Plaintiff “Louis Charles Hamilton II” herein. 
By, _______________________________ 
Louis Charles Hamilton II 
Pro Se Plaintiff 
P.O. Box 17524 
Sugar Land Texas 77496

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

  • 1.
    In The UnitedStates District Court For The Eastern Division of Texas Beaumont Division Louis Charles Hamilton II Pro Se Plaintiff Vs. Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 Defendant Joyce M. Guy Edward McCray Co-Defendant(s) Civil Complaint Jury Demand Comes Now The Pro Se Plaintiff “Louis Charles Hamilton II” Pro Se Plaintiff files “Complaint” with the above Honorable U.S. District Court and for Just Cause, Plaintiff herein will show before the “Honorable Court” all facts, circumstances, detailing among other things (RICO) “Racketeer Influenced and Corrupt Organizations Act, Causes of “acts and actions” committed against the Pro Se Plaintiff herein “Will”, “Civil Rights”, “Peace” and “Dignity”. “United States of America” Not a Party to this Suit. 1.
  • 2.
    Parties. Pro Se,Louis Charles Hamilton II, African American Male, U.S. Navy Veteran, Pro Se Plaintiff , Louis Charles Hamilton II, African American Male, Permanently Disable Veteran protected under: (ADA) American with Disability Act; And also minorities persons cover under Title VII of the Civil Rights Act of 1964; Domiciliary State of Texas, P.O. Box 17524 Sugar Land, Texas 77496 2. Defendant(s) Antoine L. Freeman J. D. (Attorney at Law) (Active) in and for the State of Texas Bar No. 24058299 Has “Two Legal Law Offices” in Port Arthur Texas, 3627 Professional Dr. Port Arthur Texas 77642 and 3723 Gulfway Dr. Port Arthur Texas 77642 3. Co-Defendant(s) Joyce M. Guy and Edward McCray (Legally Married) has (5) business E and J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur Texas Information about E & J Collectibles E & J Collectibles is in the Used Merchandise Stores business and this category has 2 companies in Port Arthur Texas. J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640, G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640 and “Cars and Pieces” Located in Beaumont Texas (Office) also located at 448 DeQueen Blvd. in Port Arthur Texas 77640
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    4. Jurisdiction Jurisdictionis proper before the “Honorable Court” of Eastern District of Texas in that (Plaintiff) is always a resident of Jefferson County Texas, and all acts and actions described herein by all the Defendant(s) described herein fully occurred within the Jurisdiction of Eastern District of Texas Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 is a (Active) “Attorney at Law” for the State of Texas as described above in paragraph (2) Further said Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 was acting in his full capacities as an “License Attorney” on retainer for the legal behalf of (Co)-Defendant(s) “Joyce M. Guy” and “Edward McCray” in a Civil Action in The District Court 58th Judicial District of Jefferson County, Texas, Docket No. A-180805 When said Defendant herein in his fiduciary capacities as an “Attorney of Law” Antoine L. Freeman J. D.) Texas Bar No. 24058299 Committed to “among many other things” (RICO) “Racketeer Influenced and Corrupt Organizations Act”, Fraud on the Court “Mail and Wire Fraud”, “Direct Fraud” and “Constructive Fraud” in connection with Jefferson County Texas 58th District Court Records, and Fraud of Jefferson County Public Records 5. To include Defendant(s) and Co-Defendant(s) collectively in concert, and collaboration in violations of Title 18 U.S.C. § 1341, 1343 and 1349 “Mail and Wire Fraud”, Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299
  • 4.
    Aiding and abettingto commit to A Criminal Enterprise in “Racketeer Influenced and Corrupt Organizations Act” in his capacity as a Attorney of Law, against the rights, peace, and dignity, and civil rights of the Pr Se Plaintiff herein in suit in common law in Jefferson County Texas 58th Judicial District Court. "Computer Fraud and Abuse Act (CFAA) 18 U.S.C. § 1030 in connection with all criminal acts and actions, as described fully herein. Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 Fully Committed to among other things “Obstruction of Justice” in the capacity as an “Officer of the Court” and “Attorney of Law” for the State of Texas To commit and conspire to the same causes of all “acts and actions” in concert with the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Fully Described herein against the Pro Se Plaintiff, While further willfully Omitting to and Destruction thereof “Material Civil Evidences and Facts” before a ongoing “Civil Suit” in Common Law in Jefferson County Texas 58th Judicial District With “among other things” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Actual Fraud, upon the “Texas Department of Housing & Community Affairs” Jefferson County Texas and Federal Grants derived thereof in Connection with the Pro Se Plaintiff “Louis Charles Hamilton II” herein With “among other things” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” Actual Fraud of Insurance Companies”, for primary fraud during “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages, in connection with the Pro Se Plaintiff 6. Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” To commit to the same “Obstruction of Justice” of 58th Judicial District Court, for primary fraud during “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages,
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    Defendant(s) Antoine L.Freeman J. D. (Attorney at Law) (Active) in and for the State of Texas Bar No. 24058299 and in collusion with Co-Defendant(s) “Joyce M. Guy” and “Edward McCray et al” Conspiracies together to pursue the same Criminal (RICO) “Racketeer Influenced and Corrupt Organizations Act”, Fraud on the Court “Mail and Wire Fraud”, “Direct Fraud” and “Constructive Fraud” of Jefferson County Texas 58th District Court Records, Fraud of Jefferson County Public Records All “among other things” being done criminally/civilly against the Pro Se Plaintiff civil rights, peace, will, and dignity, During an ongoing “Civil Suit” of Common Law in Jefferson County Texas as described in paragraph 4 and 5 above. All being wrongfully and fully committed to Within the Jurisdiction The Eastern Division of Texas United States District Honorable Court. 7. Subject Matter Jurisdiction Venue Pro Se Plaintiff Louis Charles Hamilton II herein States, Affirm, and Declare Before the “Honorable Justice” Subject Matter Jurisdiction is proper before this U.S. District Court “primary exclusive many “federal Questions” involving among other things Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and related activity in connection with identification documents), Section 1503(relating to obstruction of justice), Falsification of “Material facts”, with Conspiracies by all described Defendant(s) to pursue to the same Criminal Monetary Objective(s) involving the Pro Se Plaintiff herein,
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    With mutable countsof constructive fraud activities “hiding behind” among other things “attorney-client privilege” and all “work-product doctrine” derive thereof, to include but not limited to all “communications” between an “Attorney and his client”, Namely Defendant Antoine L. Freeman J. D. (Attorney at Law) (Active) in and for the State of Texas Bar No. 24058299 in collusion and conspiracies with Co-Defendant(s) “Joyce M. Guy” and “Edward McCray et al” To Commit to Fraudulent acts in all “prepared legal court documents”, “affidavit(s)”, “interrogatories”, “request for admissions”, sign statements and all other materials of Jefferson County Court records, document(s) and materials facts in 58th Judicial District Court of Jefferson County Texas Court Docket No. A- 180805 “To include but not limited” to fraud upon the Honorable Judge Bob Wortham, and His Court Fraud in all records of the Jefferson County Clerk Office records involving financial records of “Insurance Companies”, “Financial Statements” for primary monetary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and “Humberto ” scheme of things related Construction storm damages, derive thereof further involving the Pro Se Plaintiff herein 8. “To include but not limited to” the ” Actual Fraud”, upon the “Texas Department of Housing & Community Affairs” of Jefferson County Texas and “Federal Grants of $76,000 U.S. Dollars” derive thereof In Violations of Chapter 96 of Title 18, United State Code: (RICO) 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), with “Actual Fraud(s)” Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” conspiracies of mutable “Insurance Companies”, for primary fraud and scheme advantages during “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages, Involving
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    further The ProSe Plaintiff herein as a “unwilling blind” party into this cold calculated fraudulent acts and action(s), and complex scheme of things to further fraud the “Texas Department of Housing & Community Affairs” of Jefferson County Texas and a “Federal Grants in excess of $76,000 U.S. Dollars” derived thereof 9. “Actual Fraud”, upon the 58th Judicial Court of Jefferson County Texas and all records derive thereof, To include but not limited to Actual Fraud of Insurance Companies”, FEMA for primary monetary fraudulent acts and actions during “Hurricane “Rita”, “Ike” and “Humberto” related Construction storm damages, involving the Pro Se Plaintiff Louis Charles Hamilton II herein All this “Complex Mutable Grand Scheme of Things” committed By the Name Defendant Antoine L. Freeman J. D. a (Attorney at Law) (Active) in and for the State of Texas Bar No. 24058299 in collusion and conspiracies with Co- Defendant(s) “Joyce M. Guy” and “Edward McCray et al” corrupted activities fully designed prepared with an eye towards the “realistic possibility of impending litigation” by the Pro Se Plaintiff herein Defendant and Co- Defendant(s) commit to Grand (RICO) Fraud of The 58th Judicial District Court of Jefferson County thereof in this civil scheme of things. And the realistic object by all described Defendant and Co- Defendant(s) herein to further commit to Fraud for “monetary value gain in excess” of $87,024.00 U.S. Dollars, against the Pro Se Plaintiff Civil rights, peace, will and dignity 10. With further combine conspiracy of fraudulent acts and actions by the Defendant and Co-Defendant(s) to plan a scheme of things in the Theft of Pro Se Plaintiff “Personal Property” herein against the Pro Se Plaintiff Louis Charles Hamilton II “Civil Rights”, “Peace”, and “Dignity” being wrongfully done within
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    the Jurisdiction ofthe “Honorable Justice” further causing the Pro Se Plaintiff herein to suffer “among other things” Extreme real life hardship, Extreme Intentional Infliction of emotional distress and mental anguish from all of the combine Defendant and Co- Defendant(s) among other things conspire in (RICO) “Racketeer Influenced and Corrupt Organizations Act”, “Fraud on the Court”, “Mail and Wire Fraud”, “Obstruction of Justice” “Direct Fraud” and “Constructive Fraud” of Jefferson County Texas 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 complaint herein. 11. Pro Se Plaintiff herein States, Affirm and Declare before the Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 Violations of Chapter 96 of Title 18, United State Code: (RICO) 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), Fraud upon the 58th Judicial District Court of Jefferson County Texas in connection with Falsification of “Material facts”, and Numerous Fraudulent Activities in the Capacity of a “Attorney at Law” cause Pro Se Plaintiff “Louis Charles Hamilton II” herein to suffer “actual damages” in excess of $336,000.00 U.S. Dollars and This “actual damages” is ongoing as of this undersigned date of this Complaint before the Honorable Court since date of injury November 17th 2007. 12. Pro Se Plaintiff seeks Actual, accumulative, compensatory, consequential, continuing, expectation damages, foreseeable, Future, incidental, indeterminate, reparable, lawful, proximate, prospective, special, speculative, substantial,
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    Punitive, and Permanentdamages; Pro Se Plaintiff seeks Actual Awards for Intentional Infliction of emotional distress and mental anguish. 13. Pro Se Plaintiff herein States, Affirm and Declare before the Honorable Justice” this action was filed before this Honorable Court February 2, 2010 U.S. Docket No. 1:2010-CV-00055 and at that time frame Pro Se Plaintiff was under extreme mental stress caused by the many “acts and actions” of the primary Defendant in the capacity of a “Skilled Attorney of Law” no less a Officer of The State of Texas Court System and Co-Defendant(s) herein whom collectively together are responsible for the Pro Se Plaintiff suffrage of among other things “Mental Illness” and Living on SSI since date of injury… of 2007 as of this undersigned date. Pro Se Plaintiff further states, affirm and declare before the Honorable Justice” also at the time of filing the original complaint against the Described Defendant(s) herein (Plaintiff) U.S. Government and Federal Court Mail was being stolen, by among others (Thee) U.S. Attorney Office them self (Proof) already on Filed in this herein U.S. Federal Court Clerk Office in the matter of Hamilton Vs. United States of America, U.S. Attorney Eric Holder et al (1:2011-CV-00240) Plaintiff was also forced into a “State Hospital” for a period of time, accused of Violent Life Threaten Crimes” never being near of or a party thereof and Pro Se Plaintiff “mental state” being quite scary indeed in light of all the legal hostile activities ongoing against the Plaintiff will caused by each Defendant(s) herein. 14. Pro Se Plaintiff herein States, Affirm and Declare further before the “Honorable Justice” this New Improved Complaint made against each Defendant(s) herein is still criminal/civil corrupted conduct being still quite
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    “civilly ongoing” againstthe “legal rights” of the Pro Se Plaintiff “Louis Charles Hamilton II As Defendant(s) combine further “Fraudulent activities” continue to cause the Pro Se Plaintiff to suffrage continually monetary damages in excess of $48,000.00 U.S. Dollars per year since 2007, as of this undersigned date of this complaint well into the future year of 2015. Further causing Pro Se Plaintiff a “limbo state” of extreme hardship, Intentional Infliction of emotional distress accompanying continue Gross state of complete “mental anguish” direct at the Defendant(s) from all of the numerous hostile corrupted acts and actions of the described Defendant(s) herein as this “Civil Matter” is unresolved before the Jurisdiction of this Honorable U.S. District Court which has real subject matter jurisdiction over all detail material facts being complained of respectfully before “Honorable Justice” 15. Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” that his current “Mental State” is processing a bit better, as these causes of actions derived from Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 direct criminal/civil illegal, hostile, corrupted conduct in collusion with Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” need to be legally address And Pro Se Plaintiff seeks a just proper legal, lawful respectable accountable end to this civil matter in which the above Honorable U.S. District Court has unfetter Judicial Subject matter over. 16. Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” the Defendant(s) continue imposed mental suffrage, hardship, and Major Monetary losses caused by the described Defendant(s) collectively herein as Pro Se Plaintiff “Mental State” has improved slightly as of this undersigned
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    date to uncoverall of the real in life cruel intentions scheme, facts and fraudulent circumstances of each described Defendant(s) acts and actions herein direct against the rights, will, peace and dignity of The Pro Se Plaintiff notably being on a Grand scale corrupted involvement To the point the once (crafty hidden) “Racketeer Influenced and Corrupt Organizations Act”, “Obstruction of Justice” “Fraud on the Court”, “Mail and Wire Fraud”, “Direct Fraud” and “Constructive Fraud” of Jefferson County Texas 58th District Court Records, Committed fully by Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 And precise fraud upon the 58th Judicial Court of Jefferson County Texas to now as of this undersigned date Being official new discovery in Jefferson County Texas Public records, quite correct and respectable evidence being complained of before the Honorable Justice” Now identified is this complaint in precise, sound proof calculations into each responsible direct “acts and actions” of each Defendant(s) exacts responsible & accountable “federal jurisdiction” conduct giving rise for a cause of “Justice” Before this “Honorable Justice” United States of America Court . 17. Factual Background Co-Defendant(s) “Joyce Guy and Edward McCray” living at the dwelling (Blk. 172 Lt. 1-2) being located at 448 DeQueen Blvd. in Port Arthur Texas 77640 knowingly collectively did enter into a Contract for the Amount of $10,850.00 for Construction following Hurricane Humberto damages. 18. Co-Defendant(s) “Joyce Guy and Edward McCray” already received funds for repairs from the “Home Owner Insurance Company” in excess of $7000.00 U.S. Dollars and unknown to the (Plaintiff) Co-Defendant(s) simply squander all
  • 12.
    of these fundson them self and their quite “selfish needs other than making the repairs to the already seriously damaged home as required by the first installment Insurance Funds proceeds. At this point Co-Defendant(s) “Joyce Guy and Edward McCray” devised a financial “wicked plan” to fraudulently involving the Pro Se Plaintiff “Louis Charles Hamilton II” herein and his Construction contract $10,800.00 U.S. Dollars for Hurricane Damages in a continue “scheme of things” to obtain additional Funds from the same “Insurance Company”. 19. Co-Defendant(s) “Joyce Guy and Edward McCray” Breach the Contract of the Pro Se Plaintiff on November 17, 2007 for the same scheme of things as being described in paragraph (18) above in addition Co-Defendant(s) collectively took possession, custody and complete control over all of the Plaintiff property Namely (Construction Tools) in excess of $3093.00 being Pro Se Plaintiff entire “Construction Business of tools”...! Wrongfully abducted and obtain in this “hostile takeover” to include Pro Se Plaintiff herein being “physically assaulted” by Co-Defendant “Edward McCray” while this same ongoing “criminal scheme of things” is in effect fully committed and directed, and orchestrate by Co-Defendant(s) “Joyce Guy and Edward McCray for the absolutely purpose to Fraud further of The “insurances companies “Repair Moneys” for Co-Defendant(s) collectively “personal monetary gain” other than making needed repairs As all described in paragraph (18 & 19) above involving The Pro Se Plaintiff Louis Charles Hamilton II and a Construction contract drafted by Pro Se Plaintiff for Co-Defendant(s) “Joyce Guy and Edward McCray” collective behalf for “monetary relief” by said “Insurance Companies” to cover dwelling located at 448 DeQueen Blvd. in Port Arthur Texas home structural repairs cost for Hurricane Humberto related storm damages. 20.
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    Co-Defendant(s) “Joyce Guyand Edward McCray” for their combine corrupted conduct direct against the Plaintiff civil rights, peace, and dignity within Jefferson County Texas as being described in paragraph (17, 18, and 19) above Pro Se Plaintiff filed civil action in Jefferson County Texas 58th Judicial District Court, before the “Honorable Judge” Bob Wortham. Complaint Docket No. A-180805 filed on November 26th 2007 with the Jefferson County Clerk of Court office. And Co- Defendant(s) “Joyce Guy and Edward McCray” retain the Professional legal services of Defendant Antoine L. Freeman J. D. “Attorney at Law” Texas Bar No. 24058299 Having “Two Legal Law Offices” in Port Arthur Texas, 3627 Professional Dr. Port Arthur Texas 77642 and 3723 Gulfway Dr. Port Arthur Texas 77642 21. Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” because of the continue chief corrupted effects of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 Skilled Crafty Criminal Mutable Complex Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and related activity in connection with identification documents), Section 1503(relating to obstruction of justice), Falsification of “Material facts”, among other things committed by this Defendant with Fraud upon the 58th Judicial District Jefferson County Court and such Conspiracies involving the Pro Se Plaintiff herein,
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    The Civil actionfiled on November, 26th 2007 in 58th Judicial Court of Jefferson County Texas remain complexly ongoing well into December 17th 2014 next court hearing, fully “Live” as of this undersigned date for a period well exceeding over (7) years and counting ongoing in the 58th Judicial District Court of Jefferson County Texas for a suit in “Common Law”. 22. Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 filed an original answer on behalf of the Co-Defendant(s) and then later making false discovery procedure claiming to the Honorable Judge Bob Wortham on or about 11th day of September 2009 in a reply motion for sanction against said “Attorney” for violations of Texas Rules of Civil Procedure 193.1 by failing to respond to Pro Se Plaintiff’s Discovery Request ” Defendant Antoine L. Freeman J. D. Attorney at Law Texas further making factual material claims in court filed documents and before the Honorable Court in a hearing his only “Legal obligation” was to provide Co- Defendant(s) “Joyce Guy and Edward McCray” involving in this civil case A- 180805 in Jefferson County Texas was to draft a (Simple) General denial on behalf of the described “Co-Defendants” behalf being filed on December 18th 2007 in Jefferson County Clerk of Court records in order Co-Defendant(s) collectively do not be filed for a default Judgment against them for the Civil Complaint. 23. Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 told a bald face “Lie” to “Judge Bob Wortham” to avoid “monetary sanctions” against him for his (Indeed) violate of Rule 193.1 Defendant in his capacities as a “Attorney of Law” no less “kept secretly” in his possession, custody and Control for a period of over (3) years while being
  • 15.
    actual the “Attorneyof Record” in this civil matter safely Hidden from the “Honorable 58th Judicial Court” proceeding All of Pro Se Plaintiff first round of Chief Discovery request document(s) Request for Disclosure and “Request for Admissions” pursuant to Rule 198 of the Texas Rules of Civil Procedure to include Pro Se Plaintiff First set of Interrogatories” pursuant to 197 of the Texas Rules of Civil Procedure at which Defendant Antoine L. Freeman J. D. “Attorney at Law” Texas Bar No. 24058299 finally admitted to the Pro Se Plaintiff (alone) The “actual physical existences” after 3 years and counting Defendant “Attorney at Law” omitted of being in such possession, custody and control while keeping such discovery request of the Pro Se Plaintiff secretly hidden from the “Court Proceedings” Moreover” especially Hidden From “Judge Bob Wortham” Judicial studying of the civil case at hand before his Honorable Court proceeding At which Defendant Antoine L. Freeman J. D. “Attorney at Law” providing proof of all discovery document and material facts derive thereof and their now existences being dated proof on or about October 14, 2009 when these discovery document(s) “Request for Admissions and “Interrogatories” among other legal documents was finally being place in the U.S. mail and forwarded back to the Pro Se Plaintiff herein who made the discovery request over 2 and ½ years ago. 24. Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 cleverly crafty abusing his “attorney/client privileges, all work doctrine documents derive thereof; And all known communications between “Attorney and Client” Namely Defendant Antoine L. Freeman J. D. and Co-Defendant(s) “Joyce Guy and Edward McCray” herein to “Grand style” deceive the “Honorable Court” from having any “Legal Knowledge Via Pro Se Plaintiff herein “direct
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    discovery request” and“Investigation” fully focus on among other things Co- Defendant(s) “Joyce Guy and Edward McCray” Collectively in the past did in fact submit numerous Hurricane relief damages claims being in the form of construction contractor’s estimates to their “Insurance Companies” and possibly FEMA for relief of damages caused by Hurricanes Rita, Humberto, and Ike for the property located at 448 DeQueen blvd. in Port Arthur, Texas. To include Property located at 5050 east 7th Street in Port Arthur Texas, and Property Located at Blk 4 Lot. 10 Lake View in Jefferson County Texas all own and in the possession, custody, and control of the Co-Defendant(s) As Pro Se Plaintiff making claims before the 58th Judicial District Honorable Court of Co-Defendant(s) “Joyce Guy and Edward McCray” past fraudulent “practice and patterns” thereof after the corrupted hostile “acts and actions” directed at the Pro Se Plaintiff herein as being described in paragraph (17-24) above. 25. Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 having full prior knowledge that existence of a “property lien” was enforced by SWMJ Construction Inc. filed on June 18th 2009 in Jefferson County Clerk Office Being against Co-Defendant(s) “Joyce Guy and Edward McCray” as it was relating to “among other things” “Material Evidence” Pro Se Plaintiff sought history showing Co-Defendant(s) making other Fraudulently scheme of things involving monetary relief of damages caused by Hurricanes Rita, Humberto, and Ike for the property located at 448 DeQueen blvd. in Port Arthur, Texas. There after already ripping off the Pro Se Plaintiff in 2007 storm season. 26.
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    Pro Se Plaintiffherein States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 having a Profession eye on the civil damages this discovery would affect Defendant(s) presumed innocent standing before the Honorable Judge Bob Wortham conspire with “obstruction of Justice” to continue to commit to conceal this “material evidence” from the Plaintiff when it was required to be produce in Pro Se Plaintiff Discovery Request devise. 27. Pro Se Plaintiff herein States, Affirm and Declare before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 also having “insider information and communications” with Co- Defendant(s) “Joyce Guy and Edward McCray” conspire further with “obstruction of Justice” to continue to commit to conceal this “material evidence” that Co-Defendant(s) “Joyce Guy and Edward McCray” was in fact in the legal process of having the old Home torn down while the ongoing civil actions was still pending before the 58th District Court of Jefferson County Texas to include Co-Defendant(s) “Joyce Guy and Edward McCray” Collectively having a “New Home” secretly being built at the cost of $76,000.00 U.S. Dollars on a “Federal Grant” kept 100% secret from the Pro Se Plaintiff Discovery and The State Court while this Civil Suit in common Law had commence in 2007 as was well ongoing out of control at this point under (RICO). As Defendant himself Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 confirm and described in Pro Se Plaintiff First Set of “Interrogatories” the “Texas Department of Housing & Community Affairs” issuance of a “Housing Grant” in favor for the Co- Defendant(s) “Joyce Guy and Edward McCray” all of which in fact fraudulently obtain being in fact a “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs” Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co-Defendant(s) herein making further fraudulent claims
  • 18.
    before said “TexasDepartment of Housing & Community Affairs” that Pro Se Plaintiff was the primary cause of damages to the old home derive thereof for Co- Defendant(s) “Joyce Guy and Edward McCray” needing a “New Home” based upon poor, Unsatisfactory contractor “workmanships” and “craftsmanship” being committed by Pro Se Plaintiff Louis Charles Hamilton II herein for the $10,800.00 U.S. Dollars Contract already sub-mitted to previous “Insurance Company” by Co- Defendant(s) in regards to Hurricane Humberto storm related damages. 28. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 having a Profession legal eye on the “civil damages” this Pro Se Plaintiff discovery request would affect Co- Defendant(s) “Joyce Guy and Edward McCray Presumed innocent standing before the Honorable Judge Bob Wortham clear back in 2008 long before Co-Defendant(s) “Joyce Guy and Edward McCray further fraudulently obtain a “New Home” secretly being built at the cost of $76,000.00 on a Federal Grant Defendant Antoine L. Freeman J. D. Attorney at Law conspire further with “obstruction of Justice” to conceal the destruction of the old home And the new home being built Defendant Antoine L. Freeman J. D. Attorney at Law further conspire and work in concert to assure no delays ever being a factor in the construction of the New Home” Located at 448 DeQueen Blvd. in Port Arthur Texas would be primary cause if the “Honorable Judge” Bob Wortham, of 58th Judicial District Court of Jefferson County Texas would in all facts and circumstances reach Pro Se Plaintiff discovery document(s) containing “Material Facts” of among other things while this ongoing civil suit still pending a “Property Lien” already previously in Forced against Co-Defendant(s) collectively as described in paragraph (25) above To include a “New Home” secretly being built under the noise of the Pro Se Plaintiff herein and the “Honorable Judge” Bob Wortham, during this pending
  • 19.
    civil action DocketNo. A-180805 at the cost of $76,000.00 on a “Federal Grant” as the secretly destruction of the older home took place once being “Official Dwelling” to this ongoing Civil Suit involving the dwelling in 2007 located at 448 DeQueen Blvd. in Port Arthur Texas, Now secretly destroyed in 2009 before the Honorable 58th Judicial District Court of Jefferson County, Texas ongoing civil court case. 29. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co-Defendant “Joyce Guy and Edward McCray” secretly filed on June 18th 2009 transfer of property over to the “Texas Department of Housing & Community Affairs” at the Jefferson County Clerk Office File #2009022762 during this ongoing civil action with the Defendant collusion to keep all of this absolutely secretly claiming under “Attorney/Client Privileges”, Product of Work Doctrine and Communications made between Attorney and Client absent the fact this is very material facts in a ongoing civil suit against the Co-Defendant(s) collectively under the legal defense of Attorney at Law criminally withhold such discovery as request to release such favorable Document, Material facts, and circumstances. 30. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co-Defendant “Joyce Guy and Edward McCray” secretly filed on June 18th 2009 Fraudulent “Financing Statement” at the Jefferson County Clerk Office File #2009022763 to obtain from “Texas Department of Housing & Community Affairs” $76,000.00 on a “Federal Grant” as the secretly destruction of the older home took place during this ongoing “Civil Suit” 31. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” 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
  • 20.
    destruction of theolder one and all circumstance involved thereof being secretly conspire further fraudulently in the capacitates of a “Attorney at Law” with the Co-Defendant(s) To achieve the same fraudulently monetary objective(s) gain being $76,000.00 “New Home” on a “Federal Grant” shamefully submitted Before the “Texas Department of Housing & Community Affairs” by Co-Defendant(s) after already “Greedy Squandering” all of the Numerous Insurance Funding” from each previously Hurricane “Rita”, “Humberto”, and “IKE” related storm damages on the dwelling located at 448 DeQueen Blvd. in Port Arthur Texas. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 had a duty to disclose all material facts as described herein and regardless of his “Attorney/Client defense of the Co-Defendant(s) Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 was obligated to conform with the Texas Rules of Civil procedures in Discovery phase of a Civil Suit in common law within the State of Texas Regardless of it criminal/civil fall out affect being properly in placement upon the Co-Defendant numerous fraudulent acts and actions discovery of a shocking further investigation involving “among other things” the actual designed “Fraud of Contractors” related to “Insurance Company” Scams and scheme of things the Co-Defendant(s) monetary calculated and concocted. 32. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “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
  • 21.
    involving withholding alldiscovery material during this entire (2) year time frame and shield all of Co-Defendant(s) mutable fraudulent indiscretions of Corrupted Illegal (RICO) Business dealing within Jefferson County Texas being instituted by the Co-Defendant(s) . 33. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Pro Se Plaintiff herein because of the many “hostile” acts and actions direct at the Pro Se Plaintiff civil rights, peace and dignity by the Co- Defendant(s) herein Pro Se Plaintiff conducted a Special Exclusive in-depth Investigation into the Co- Defendant(s) “Joyce Guy and Edward McCray” to provide the Honorable 58th Judicial Court of Jefferson County Texas”, Solid proof of the Co-Defendant(s) collective History of corrupted “pattern and practices” involving “fraudulent monetary scheme of things Nature” to” legally discovery” all of the following ongoing corrupted in design acts and in one primary case being a actual “Illegal Medical Enterprise” for the elderly disable senior citizens within in Jefferson County Texas 34. Co- Defendant(s) “Joyce Guy and Edward McCray” mutable business E and J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur Texas, J Can Company 1807 East 7th Street Port Arthur Texas, G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas and, “Cars and Pieces” Located in Beaumont Texas (Office) also located at 448 DeQueen Blvd. in Port Arthur Texas 77640 Are all in fact legally owned by the Co-Defendant(s) collectively herein as records do in fact “indicate” and on file with the “Jefferson County clerk” 35.
  • 22.
    Pro Se Plaintiffherein “States”, “Affirm” and “Declare” further before the “Honorable Justice” the Co-Defendant(s) “Joyce Guy and Edward McCray”, filed with the Jefferson County Clerk #2009022763 “Financing statement” to obtain the “Texas Department of Housing & Community Affairs” $76,000.00 on a “New Home Federal Grant” “However” Co-Defendant(s) “Joyce M. Guy” omitted and refused to provide correctly all factual income detail in this “Financing Statement” of the Assumed Name Business G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640 In which this is in facts and circumstances a “illegal medical business” for the disable elderly senior citizens of Jefferson County Texas has never had a HCSSA license on filed with the State of Texas nor was a HCSSA license ever attempted to be correctly filed with the State of Texas which all of this was ongoing from the dates of May 5th1997 throughout January 7th 2010 for a period of 13 years of “Earn Income” with cash being paid to all “employees” when it was order shut down by the State of Texas Department of Aging and Disability Services until a real licensed being obtain. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” on December 1st of 2009 is when the (Pro Se Plaintiff) filed a formal complaint with “Texas Department of Aging and Disability Services” in regard to this “Illegal” Medical Business” namely “G and G Service Company” P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas of Co-Defendant(s) “Joyce M. Guy” (Actually) this medical business operations of G and G Service Company being secretly conducted on a (Vacant Lot)  Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” as a result of Pro Se Plaintiff “Investigation” Co- Defendant(s) “Joyce M. Guy” was order in Person as Pro Se Plaintiff was on his cell phone by the “State of Texas” “Texas Department of Aging and Disability Services” to shut down said “Illegal medical business” until a real HCSSA license is obtain with the State of Texas. 36.
  • 23.
    Pro Se Plaintiffherein “States”, “Affirm” and “Declare” further before the “Honorable Justice” at this time frame Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 was fully aware of the “Texas Department of Aging and Disability Services shutting down said “Illegal medical business” “G and G Service Company” until a real HCSSA license is obtains with the State of Texas which Defendant Antoine L. Freeman J. D. “Attorney at Law” understood directly Pro Se Plaintiff himself being the direct cause for “Illegal medical business” G and G Service Company being closed against Co- Defendant(s) while this civil suit was ongoing in the 58th Judicial District Court of Jefferson County Texas Defendant (Attorney at Law) herein conspire further to protect the Co- Defendant(s) from any further civil/criminal fall outs there past history might dictate in Fraud scheme of things as described herein to the point Defendant conceal all of the Pro Se Plaintiff Discovery request document(s) throughout the years of 2007, 2008 and 2009 when Texas law of Civil procedure require a reply well within 30 days of receiving said discovery request. Defendant (Attorney at Law) herein told “Judge Bob Wortham” he was only retain to file a “General Denial” (Only) while secretly conceal all of the Pro Se Plaintiff Discovery request document throughout the years of 2007, 2008 and 2009 to assure Co-Defendant(s) “Joyce Guy and Edward McCray” fully protected from any present and future civil/criminal fall outs occurring Based upon Pro Se Plaintiff Investigations into the Mutable Corrupted Business “patterns and practices of the Co-Defendant(s) herein to include but not limited to The Pro Se Plaintiff knew Co-Defendant “Edward McCray” seriously engage in “sales” of a “Crack Cocaine” Industry and having mutable arrest. 37. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “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
  • 24.
    Port Arthur Texas77640 being owned by the Defendant(s) “Joyce Guy and Edward McCray”, assumed name filed on April 11th 2008 Jefferson County Clerk records #72594 1807 East 7th street in Port Arthur Texas is actually a “Vacant Lot” which has been raided by the PAPD Dept. (Police) several times for engaging in “illegal Scrap Industry” “Moreover” once all “Illegal Scrap Metal” other then used Cans being recycle and obtain in the City of Port Arthur Texas city limits by Defendant “Edward McCray”, by the business J Can Company being now introduced as “Scrap Metal” in connection with “Cars and Pieces” business Located in Beaumont Texas (Office) also located at 448 DeQueen Blvd. in Port Arthur Texas 77640 Making the final “Legal sales” of all “illegal scrap” obtain in the City of Port Arthur Texas city limits by Defendant “Edward McCray”, “Moreover” Pro Se Plaintiff Louis Charles Hamilton II herein (Fully) quite “elementary sure and certain” after prior raid by the (PAPD) Police into “illegal scrap” of J Can Company that this “many years of “baffling exchange” transfer rate of “Illegal scrap” from Port Arthur Texas City Limits has been confusing the (PAPD) Police in the exchange rate form now “legal scrap” derived in “Beaumont Texas” from J Can Company “Namely”, “Cars and Pieces” business in Beaumont Texas being now major illegal scrap metal “money laundering” “Earn Income” system for Co-Defendant (Edward McCray) derived from this “criminal endeavor. To include but not limited to, upon information, belief and personally witness Co-Defendant “Edward McCray” usage of “Vacant Lot” being J Can Company to secretly continue engaging in the sales of a “Crack Cocaine Industry”. 38.
  • 25.
    Pro Se Plaintiffherein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendants Antoine L. Freeman, J.D. “Attorney at Law” at the very start clearly in December of 2007 was engaging in Professional Skills of a Attorney at Law” in a “Legal” ongoing court room obligations to defend this civil case A-180805 against Pro Se Plaintiff Defendant made Fraud upon the 58th Judicial Court claiming in a document filed by defendant his only legal job was to draft a (Simple) General denial on behalf of the Defendants filed on December 18th 2007, as such to avoid a default on behalf of Co-Defendant(s) by filing his original Answer and at that point his “Fiduciary Duty” to his clients and before the Court ended on that date December 18th 2007 and was legally completely over, Which this is not the case as Defendant (Attorney at Law) Fully scuttles all discovery materials received from Plaintiff in this civil matter from December 18th 2007- November 13th 2009 being the official day while in possession of Plaintiff request to disclose Pursuant to Rule 194 during the entire year of 2008-2009 Defendant Antoine L. Freeman, J.D. “Attorney at Law fail well within (30) days of this request, for the information or material described in Rule 194.2: by a period of over (2) years past the (30) days requirement to answer not only Pro Se Plaintiff “Request to Disclose” Pursuant to Rule 194, Defendant (Attorney at Law) was also served Pursuant to Rule 198 of the Texas Rules of Civil Procedure Plaintiff Request for Admission(s) and Pursuant to Rule 197 of the Texas Rules of Civil Procedure Pro Se Plaintiff Set of Interrogatories all of which required a reply within (30) days of these request as Defendant a skilled (Attorney at Law) having full knowledge that a discovery phase process had commence in this civil legal matter refuse to submit any “response or reply” to all being described in paragraph (38) herein for a period of (1) year and (11) Months and Pro Se Plaintiff Filed “Motion for sanctions” against said Defendant (Attorney at Law) in violation of Rule 193.1 of the Texas Rules of Civil Procedure. 39.
  • 26.
    Defendant (Attorney atLaw) in his defense of Plaintiff motion for Sanctions committed to the Following Fraudulent activities upon the 58th Judicial District Court of Jefferson County Texas and all court records derive thereof. a. Engage in having Co-Defendant “Joyce M. Guy” Subscribed and Sworn a Affidavit in Support of Defendant (Attorney at Law) dated September 11, 2009 b. File a Response to Plaintiff’s Motion For Sanctions also committed to the same act of having this document “Subscribed and Sworn on the 11th day of September 2009 c. Submitted all fact therein as being true before a Court of Law. 40. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Affidavit of Co-Defendant “Joyce M. Guy” admit Defendant (Attorney at Law) informed Co-Defendant between April 2nd, 2008 and April 11th, 2008 about Pro Se Plaintiff “Discovery Request” providing proof that Defendant (Attorney at Law) was in fact in possession, custody, and control of said discovery request while representing to the “Honorable Court” this was not the case. 41. Defendant (Attorney at Law) herein did not file any notice with the Pro Se Plaintiff or the District Court of Jefferson County Texas that he was not representing the legal interest of the Co-Defendant(s) “Joyce Guy and Edward McCray”, there after filing “the original answer” with the District Court back in December 18th of 2007 when Defendant (Attorney at Law) herein in fact stating having Pro Se Plaintiff Discovery in Defendant own Affidavit being in his possession as of April 2nd, 2008. 42. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant (Attorney at Law) herein stated to the
  • 27.
    Honorable 58th JudicialDistrict Court also, that his only duty was to file a original general denial (only) and this was what his “Legal” services as a Attorney in this matter was only retain for in his defense for Sanctions against him as described herein this complaint.,” “However” Pro Se Plaintiff States”, “Affirm” and “Declare” and further maintain that Defendant Antoine L. Freeman J. D. “Attorney at Law” Texas Bar No. 24058299 did in fact make a court appearance in a hearing the Pro Se “set” before the Honorable 58th District Court Pro Se Plaintiff also filed a (TRO) “Temporary Restraining Order” in this same civil matter A-180805 against Co-Defendant “Joyce M. Guy” to protect her own “Mother” Norma Guy, and the resident living in that dwelling whom Co- Defendant (Guy) having “Power of Attorney” Over her Mother Legal Affairs, filed in Jefferson County #2010042042 at which during this same time frame Co- Defendant having process the same scheme and scam of things regarding Insurance and FEMA fraud of the property of 5050 East 7th street in Port Arthur Texas being Norma Guy Home Mother of the Co-Defendant (Guy). 43. Defendant (Attorney at Law) made another court appearance and argued this issue of a (TRO) alone before the Honorable Judge Bob Wortham, and at no time was Defendant not acting in the capacity as “Attorney of Record” from the time of filing his notice of counsel until Defendant (Attorney at Law) filed Motion to withdraw as Attorney of Record. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant (Attorney at Law) herein sat on Pro Se Plaintiff entire Discovery Request in excess of 16 Months and refuse to file a reply, file any type notice with the court during this 16 Months time period while Texas Rules of Civil Procedure require Defendant a professional Attorney at Law Adhere to local rules of the Court System and reply within (30) days not on a time table of (16) later after service of Said Discovery request by Pro Se Plaintiff Louis Charles Hamilton II.
  • 28.
    44. Pro SePlaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant (Attorney at Law) herein, further state Defendant then took a even bolder set in “Obstruction of Justice” in that after (16) of scuttling Pro Se Plaintiff Discovery request to further Hide all of the corruption going on at present time in the destruction of the old home and the new one being built, during this ongoing Civil Suit and all of the inquiries being made by the Pro Se Plaintiff regarding Fraud relating to Insurance Companies Former Contractors, and Hurricane “Rita”, “Ike” and “Humberto”. Defendant (Attorney at Law) herein provided further Fraud upon the Court in Fraudulent Information in the Interrogatories, and Never Investigated the circumstances of the questions being raised surrounding the “Theft” of The Pro Se Plaintiff Construction Tools by the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray”, Defendant (Attorney at Law) completely cover up the Co-Defendant(s) collective wrong doings from the Honorable Court per Pro Se Plaintiff Discovery Request being scuttled for (16) months time frame as being described in paragraph (43) above. 45. Defendant (Attorney at Law) made as if no Construction tools where ever on the property of the Pro Se Plaintiff being complain of To include Defendant (Attorney at Law) supply false answer(s) in the same Interrogatories that the Co-Defendant “Edward McCray” never even meeting the Pro Se Plaintiff Step Father (Lewis Garza) whom actually help delivery all of Pro Se Plaintiff said in excess of $3000.00 U.S. Dollars in construction tools to the dwelling in his Truck to the Home of The Co- Defendant(s) “Joyce M. Guy” and “Edward McCray” on November 16th 2007. Defendant (Attorney at Law) did not Investigate any of these facts nor was he ever even concern to attempt to investigate into the issues of the were about of Pro Se Plaintiff Construction tools.
  • 29.
    45. Pro SePlaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” after Defendant (Attorney at Law) was officially no longer “Attorney of record” of the Civil action in Texas State Court from the time frame of December 18th 2007 – filing General Denial to November 13th 2009 when Defendant (Attorney at Law) filed with the Clerk of Court of Jefferson County Texas a Motion for Withdrawal of Counsel The Co-Defendant “Joyce M. Guy and Edward McCray” continue to refuse to turn over said “Discovery Request” of the Pro Se Plaintiff To the point a Court Order of the 58th Judicial District Court was obtain and enforced as Follows: 46. Ordered that Co-Defendants “Joyce Guy and Edward McCray” shall produce copies of deeds, property deeds or any other such physical document in Defendants possession, custody or control that shows actual ownership of the property of the dwelling located at 448 DeQueen Blvd., Port Arthur, Texas 47. Ordered that Co-Defendants “Joyce Guy and Edward McCray” shall produce copies of any and all construction estimates for repairs in Defendants’ possession, custody or control in relationship to the damages caused by Hurricanes Rita, Humberto and Ike to the Property located at 448 DeQueen Blvd. in Port Arthur, Texas. As so Ordered on the 10th day of May 2010 by the 58th Judicial District Court of Jefferson County Texas filed at 11:46 am. 48. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” that Co-Defendants “Joyce Guy and Edward McCray” remain in Hostile abscond scuttle refusal of the Honorable Court Order as of the
  • 30.
    undersigned date inthe Month of November 2014 of this Complaint being refilled in U.S. District Court. 49. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” because of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 acting in his skilled profession to fraud the court and belittle the Pro Se Plaintiff and his discovery request for a period in excess of 16 months in possession thereof To include Defendant (Attorney at Law) herein unethical commitment to conspire further under the disguise of “Attorney/Client” privileges. Work Product doctrine, and all Communications thereof being secrete between the Defendant (Attorney at Law) and the Co-Defendant(s) “Joyce Guy and Edward McCray” To the point such Fraud commits by the Defendant (Attorney at Law) on the Jefferson County 58th Judicial District Court completely forced the Pro Se Plaintiff to be at an extreme “civil disadvantage” in the ongoing court proceeding in the time frame of 2007-2009 and present in 2014 throughout 2015 Based solely upon Defendant (Attorney at Law) Rouge (RICO) “obstruction of Justice” among other things being fully professional hire “Legal Gun” knowledge thereof to scuttle, omit, delay and fraudulently mishandling required duties to supply a honest, required respond to all of Pro Se Plaintiff discovery request in a timely fashion, within the (16) months being in possession, custody and control of said Pro Se Plaintiff Discovery request. 50. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 retainer fees was solely paid to keep the Co-Defendant(s)
  • 31.
    numerous discover fraudby the Pro Se Plaintiff absolutely 100% top secret from the 58th Judicial Court” while the other newer $76,000.00 U.S. Dollars “scheme of things” being in current play and process to now a ongoing (RICO) fraud the Co-Defendant(s) concocted involving Fraud (Now) The “Texas Department of Housing & Community Affairs” issuance of a “Housing Grant” in favor for the Co- Defendant(s) “Joyce Guy and Edward McCray” All of which in fact being fraudulently obtain from “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs” while the civil suit is “Live” and pending” which Co-Defendant(s) conspire to keep this under wraps from any financial setback glitches being fully caused by The Pro Se Plaintiff bring this additional Fraudulent activities before The Honorable Court well deserved attention. 51. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law 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 All of which Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” solely done by Defendant (Attorney at Law) (Only) to conspire in the illegal (RICO) aid to hide all of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray” many corrupted Business Enterprises endeavors,
  • 32.
    Mutable Counts ofFraudulent activities involving Hurricane “Rita”, “Ike” and Humberto” Monetary rip off scams against FEMA, Building Contractors estimate and invoices and Home Owner Insurances Companies repair funds Couple with the (Now) live ongoing new 2009 fraud activities of the Co- Defendant(s) “Joy M. Guy” and “Edward McCray” involving “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs” in excess of $76,000.00 U.S. Dollars 52. Defendant (Attorney at Law) herein known lying with a consciousness mind and disregard for the consequences for his actions in the “capacity as an Attorney of Law”, Antoine L. Freeman J. D. conspire to continue to use his legal lawyer skills” in the full “aid and abetting”, and commitment to “Obstruction of Justice” in the capacity of a Attorney at Law forthwith in providing his own numerous Attorney fraud legal commitment upon the 58th Judicial District of Court of Jefferson County Texas, the Court records thereof as being fully described in this U.S. District Court Complaint. And being in full criminal (RICO) concert, collusion, corruption and conspiracies thereof for all monetary fraudulent assets gains of the Co- Defendant(s) “Joy M. Guy” and “Edward McCray” Both being “ill-gotten pirate loot” from the “past” Hurricanes Seasons “Rita”, Ike” and “Humberto” and “present” pirate loot” “Federal Housing Grant” on the behalf of “Texas Department of Housing & Community Affairs” in excess of $76,000.00 U.S. Dollars of the Co-Defendant(s) “Joy M. Guy” and “Edward McCray” 53. Fully affecting the Pro Se Plaintiff (Life) with “among other things” cause of action for “actual damages” being in excess of $336,000.00 U.S. Dollars in “lost wages” from 2007 – 2014 and “actual damages” in excess of “3093.00 U.S. Dollars in all of the Pro Se Plaintiff Construction tools causing the Plaintiff undue
  • 33.
    unwanted extreme hardship,infliction of emotional distress and anguish in the “Theft of Pro Se Construction Profession” for a ongoing time frame over (7) years and still counting well into 2015 The Texas State Civil Suit is “Live” and ongoing due in large part to Defendant (Attorney at Law) herein Numerous (RICO) “acts and activities” to commit “among other things” a ,complete assault of “Obstruction of Justice” and “Fraud upon a Court” in the 58th Judicial District Court of Jefferson County Texas In a Suit in “Common Law” for the rouge disgrace benefit of his skilled profession as a “Attorney of Law” to skillfully cover up a Co-Defendant(s) “Joy M. Guy” and “Edward McCray” clients “Long Bogus Quite Profitable Crooked Road of “Fraudulent History” being described fully herein and direct against The civil rights, peace and dignity of the Pro Se Plaintiff herein. 54. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein used his skills as a “Attorney of Law” to commit fully to “Obstruction of Justice” for (16) months in refusal to reply to Pro Se Plaintiff Discovery Request to “facilitate”, and “conceal” Co-Defendant(s) “Joyce M. Guy and Edward McCray” by provide (Attorney in Law) Professional Legal efforts to evade the 58th Judicial District Court of Jefferson County Texas proper administration of Justice in the complaint A-180805 against all of the Fraud activities already being described in said complaint against said Co-Defendant(s) herein. Furthermore Defendant (Attorney at Law) keeping the “Honorable Court” and The Pro Se Plaintiff isolated in 2008 while the ongoing (RICO) racket scheme of things currently ongoing fraudulent activities involving the secrete destruction of the old home located at 448 DeQueen Blvd. in Port Arthur Texas in exchange for a new one at the same location all of which being secretly done while the “older home” still being a civil issue of Fraud as described by the Pro Se Plaintiff before the “Honorable Court”.
  • 34.
    55. Pro SePlaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein “facilitate” all of his own “Fraudulent Activities” upon the Pro Se Plaintiff and fraud of the 58th Judicial District Court of Jefferson County Texas for the full benefit of hiding the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” numerous corruption activities with the usage of the “United States Mailing System” to further long this fraudulent “scheme of things” before a “Honorable Court of Law” within the State of Texas and further long this “civil scheme” against the Pro Se Plaintiff as being described herein this complaint. 56. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein “facilitate” all of the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” described corruption(s) and fraudulent activities with the usage of the “United States Mailing System” to further long this fraudulent “scheme of things” before a “Honorable Court of Law” within the State of Texas and further long this “civil scheme” against the Pro Se Plaintiff as being described herein this complaint. 57. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein “facilitate” all of his own “Fraudulent Activities” and that he further conspire to and did in all facts and circumstances “facilitate” provide concealment, evade Justice for all of the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” described corruption(s) and “fraudulent activities” with the usage of the Jefferson County “Clerk of Court” Office Computer System, electronic records, and filing system thereof to further long this fraudulent “scheme of things”
  • 35.
    Before an “HonorableCourt of Law” within the State of Texas and further long this “civil scheme” against the Pro Se Plaintiff as being described herein this complaint. 58. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein “facilitate” and engage further in the usage of Extrinsic Fraud and tactics in the position as opposition counsel for the legal interest of Co-Defendant(s) “Edward McCray and Joyce M. Guy” to stop, conceal and hinder Pro Se Plaintiff from rightfully being involved in said discovery request, so Pro Se Plaintiff not being able to obtaining favorable evidence to use as a advantage to prosecute civilly against the Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” in the civil suit in State Court. 59. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” committed to defamation of the Pro Se Plaintiff as being a dishonest, unskilled, substandard Construction Contractor and Pro Se Plaintiff is the reasoning for the older home located at 448 DeQueen Blvd. in Port Arthur Texas being demolished for providing faulty contractor structural work and repairs being unskillfully provided by Pro Se Plaintiff herein. 60. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” used the defamation of the Pro Se Plaintiff substandard construction performance tactics with their previously Home Owner Insurance Company to satisfied any suspicion concerning the $10,800.00 dollars already wrongfully squander by said Co-Defendant(s) herein.
  • 36.
    To include Co–Defendant(s) “Joyce M. Guy and Edward McCray” herein used the same defamation of the Pro Se Plaintiff character against the “Texas Department of Housing & Community Affairs” claiming further Pro Se Plaintiff being a substandard contractor in construction performance by providing faulty contractor structural work and repairs skills to the dwelling of 448 DeQueen and Pro se Plaintiff being directly responsible for the need of destruction of the old dwelling thereof in Port Arthur Texas in order through this same wrongful scheme of defamation of the Pro Se Plaintiff contractor skills to obtain further a New Home with this scheme of things through the “Texas Department of Housing & Community Affairs” other than the Co-Defendant(s) own numerous actual fraudulent activities in engaging in squandering all of the funds paid out for actual repairs as a result of Hurricane “Rita”, “Ike” and “Humberto” being done to said home. 61. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein “facilitate” the same defamation of the Pro Se Plaintiff as being a dishonest, unskilled, substandard Construction Contractor and Pro Se Plaintiff is the reasoning for the older home located at 448 DeQueen Blvd. in Port Arthur Texas being torn down and a new one being built. As described in paragraph (59 and 60) above. 62. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” on or about the dates of April 2nd 2008 and or April 11th 2008 Co-Defendant(s) admitted collectively of the involvement to “Entice”, “Induce”, “Allure”, and “Ensnare” Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein in his “Legal Capacities” as a “Attorney at Law” To commit to “Actual Fraud” of the 58th Judicial Court” of Jefferson County Texas For the (RICO) purpose of “delays”, “concealment”, “omitting”
  • 37.
    and “hindering” allmaterial facts, accounts, material circumstances both being past and present of the Co-Defendant(s) “corrupted enterprise activates” The Pro Se Plaintiff herein made numerous complaints thereof in Court filing records “Docket No. A-180805 and Before the State of Texas Investigation Services into the elderly As well as all “discovery investigations” Pro Se Plaintiff was pursuing presently during said State Court Civil Complaint involving Co –Defendant(s) “Joyce M. Guy and Edward McCray” herein In which further on or about April 2nd 2008 and or April 11th 2008 Co – Defendant(s) “Joyce M. Guy and Edward McCray” herein Fully Conspire, maneuver, pilot, manipulated, scheme and monetary paid and financially secure Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein in his “Legal Capacities” as a “Attorney at Law” throughout the dates of November 13th 2009 of his “paid in full legal services” for a total of (19) months to absolutely Violate Rule 193.1 Texas Civil Procedure in replying to the Pro Se Plaintiff Discovery request In order to fully engage in the covering up (RICO) collective scheme of things of Co-Defendant(s) “Joyce M. Guy and Edward McCray” having committed against The Pro Se Plaintiff, 58th Judicial District Court, Insurances Companies, State of Texas, and The United States of America’, in a long criminal corrupted enterprise of “Fraud for Monetary Gain” of said Co-Defendant(s) collectively “rip off” activities being described herein now Before The above entitled “Honorable” United State Federal Court having subject jurisdiction matter over the” Defendant and Co- Defendant(s)”. 63. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray” on or
  • 38.
    about the datesof April 2nd 2008 and or April 11th 2008 throughout the present date of this U.S. Civil Complaint being made in the year of 2014 (November) Said Co-Defendant(s) Collectively Promoted, Pilot, Scheme, Induce, Engaged, and fully Conspire with Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein to obtain in his “Legal Capacities” as a “Attorney at Law” in concert Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and related activity in connection with identification documents), Section 1503(relating to obstruction of justice), Falsification of “Material facts”, Fraud upon the 58th Judicial District Jefferson County Court, Fraud on The State of Texas, and The United States of America in such “Monetary Conspiracies involving the Pro Se Plaintiff herein, and Hurricane “Rita”, Humberto” and “Ike” related storm damages with the usage of such numerous corrupted Fraudulent tooling maneuvers, and manipulated complex activities involving among other things All Jefferson County Clerk of Office records, 58th Judicial Court documents, electronic court filing transmission, court transcripts, and The United States Mailing System to promote, secure, and continue maintaining such (RICO) activities against the Pro Se Plaintiff Louis Charles Hamilton II herein With Co-Defendant(s) collectively Racketeering Influences Corruption Organization activities being described both past and present now in a further racketeering scheme of things involving a “Rouge Attorney” activities through Co-Defendant(s) “Joyce M. Guy and Edward McCray” paid for hire “legal expert services” of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein. 64. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” Co –Defendant(s) “Joyce M. Guy and Edward McCray”
  • 39.
    promoted, conspire andsecure (RICO) “Obstruction of Justice” activities of Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein against 58th Judicial District Court complaint made thereof For a Period of (19) months between on or about April 2nd 2008 and or April 11th 2008 throughout November 13th 2009 to continue well into 2015 such (RICO) activities having continual legal affects as being described herein this U.S. Civil Complaint against the Pro Se Plaintiff civil rights, peace, and dignity. 65. Cause of Actions Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 And Co-Defendant(s) “Joyce M. Guy and Edward McCray” Collectively for each Violations of Chapter 96 of Title 18, United State Code: (RICO) Racketeering Influences Corruption Organization, Section 1341 (relating to mail fraud), section 1343 (relating to wire fraud), section 1028(relating to fraud and related activity in connection with identification documents), Section 1503(relating to obstruction of justice), (RICO) activities upon the 58th Judicial District Court of Jefferson County Texas, and all court records, court documents electronic transmission, court transcripts, to include but not limited to “(RICO)” activities committed against “The Honorable Bob Wortham” himself being presiding Judge of Docket No. A- 180805 filed in Jefferson County Texas, (RICO) against Insurances Companies, State of Texas, and the United States of America FEMA and Federal Housing Grant agencies To include but not limited to (RICO) activities disguised in a Attorney/Client Privileges, work doctrine, and all communications derived thereof
  • 40.
    All (RICO) involvementsbeing wrongfully committed against the civil rights, peace, and dignity of the Pro Se Plaintiff Louis Charles Hamilton II herein before a civil suit in common law within the State of Texas. 66. Cause of Actions Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 And Co-Defendant(s) “Joyce M. Guy and Edward McCray” Collectively for “Actual Fraud” and the performance thereof in the capacity of a “Attorney of Law” to include constructive fraud, fraudulent intent, fraudulent pretense, fraudulent concealment, fraudulent misrepresentation, fraudulent conveyance, Extrinsic Fraud, Fraud in fact and Fraud in law, fraud in the execution of Plaintiff construction contract by Co-Defendant(s) “Joyce M. Guy and Edward McCray” for purpose to fraud “Insurance Company” To include collectively Fraud on the Court involving fraudulent activities upon the 58th Judicial District Court of Jefferson County Texas, and all court records, court documents, electronic transmission, court transcripts, and document thereof Fraud against Insurances Companies, State of Texas, and the United States of America FEMA and Federal Housing Grant agencies involving Past Hurricane storm related damages all of which being described in paragraph (66) herein involving the Pro Se Plaintiff herein being past, present, and future thereof to commit monetary Fraud gain in among other things Fraud of Insurances Companies, State of Texas, and the United States of America FEMA and Federal Housing Grant agencies involving the dwelling located at 448 DeQueen Blvd. In Port Arthur Texas
  • 41.
    Committed against thecivil rights, peace, and dignity of the Pro Se Plaintiff Louis Charles Hamilton II herein before a civil suit in common law within the State of Texas. 67. Cause of Actions Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist against Co-Defendant(s) “Joyce M. Guy and Edward McCray” for Defamation of The Pro Se Plaintiff reputation and his Profession in construction in connection with Co-Defendant(s) collectively fraudulently activities to obtain a New Home And Co-Defendant(s) collectively maintain such defamation acts to secure a 76,000.00 U.S. Dollars Federal Housing grant in that the Pro Se Plaintiff “Louis Charles Hamilton II” herein is the “direct cause” of the dwelling located at 448 in DeQueen Blvd. in Port Arthur Texas being un-inhabitable for human living conditions due primary for substandard faulty structural construction repairs of said dwelling being committed by Pro Se Plaintiff herein Whom never even made any such repairs on said home just (Pro Se Plaintiff) construction contract being executed and used to continue fraud the Insurance company for more monetary wrongful gain of “insurance Company repair funds other than Co-Defendant(s) actually fixing Hurricane Humberto storm dames to dwelling located at 448 DeQueen Blvd. in Port Arthur Texas as described in this complaint Co-Defendant(s) ) “Joyce M. Guy and Edward McCray” Committed against the civil rights, peace, and dignity of the Pro Se Plaintiff Louis Charles Hamilton II, herein. 68. Cause of Actions
  • 42.
    Pro Se Plaintiffherein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 for “Actual Damages” In this (RICO) and Fraudulent numerous conspiracy corrupted scheme of things and corrupted activities in concert, and full collusion being also brought and paid for to “expert cooking the “legal court books” of a Honorable 58th Judicial Court of Jefferson County Texas in Favor of the corrupted (RICO) described Co-Defendant(s) herein To further along promote and fully cover up all (RICO) activities, Fraud of Insurances companies, FEMA and Federal Housing Grants both being “past and present” mutable fraudulent activities of the Co- Defendant(s) “Joyce M. Guy and Edward McCray” herein involving the Pro Se Plaintiff Louis Charles Hamilton II “Among others” being fully described herein to include but not limited to 69. Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 (RICO) and Fraudulent numerous conspiracy corrupted scheme of things activities in concert, and full collusion in the capacity of a “Attorney of Law” against the Pro Se Plaintiff personal property namely “Construction tools” in excess of #3000.00 U.S. Dollars and lost wages at a minimums of $48,000.00 U.S. dollars per year “lost wages” since date of injury of November 2007 And Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 to “continue depriving” the Pro Plaintiff of his entire “Construction Trade” and “Profession” in such a complex illegal rooted (RICO) conspirer and fraud of the court system “scheme of things” being attached to the “Actual theft” of all of the Pro Plaintiff Construction tools and profession trade thereof for a period now exceed (7) years and counting well into 2015 As “Defendant and Co-Defendant” collectively enjoys and having monetary gain collectively thereof from such wrongful ongoing (7) years “civil victory” and corrupted (RICO) Fraudulent advantages, corrupted acts, and actions over the Pro Se Plaintiff civil rights, peace and dignity, and fairness to
  • 43.
    the Texas CivilRules of Civil Procedures in a “civil suit” in “common law” as being described herein this complaint 70. Further being described once before the same U.S. District Court of Eastern District of Texas when (Pro Se Plaintiff) filed his first original (RICO) complaint being legally made thereof and now no question beyond any doubt ever being so “crystal clear” in 2014 (November) the Pro Se Plaintiff confident in being precise, and having a “well understanding” into this well twisted, calculated, future plotted, manipulated, (RICO) mutable Fraudulent count enterprising “scheming activities” derive thereof and its involvement with 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) herein to depriving the Pro Se Plaintiff of his “personal property” namely “Construction tools” in excess of $3000.00 U.S. Dollars and “lost wages” at a minimums of $48,000.00 U.S. Dollars Pro Se Plaintiff being an “Independent Construction Contractor” suffrage “lost wages” per (7) year since date of injury of November 2007 in the “Actual Theft” of Said Construction tools. With 6% interest incurred since date of injury being November 2007 into the future of 2015 as this Complaint being “examine and entertain” before the “Honorable Justice” of such “Actual Damages” 71. Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein so did in all facts, court records, and real life circumstances commit to, designed further to caused the Pro Se Plaintiff herein to suffer extreme “monetary hardship” in such lost of “Actual Damage” in excess of $336,000.00 U.S. Dollars in (7) years of “Lost wages” and counting into 2015 This (RICO) scheme of things in still enforced, ongoing and very live against the Pro Se Plaintiff Louis Charles Hamilton II
  • 44.
    As Defendant (Attorneyat Law) herein (RICO) activities with the Co- Defendant(s) same (RICO) activities commit his (Attorney at Law) profession to commit to fraud of the Court “while” being in possession, custody, and control as a “Officer of said 58th Judicial District Court of Jefferson County Texas Further Defendant (Attorney at Law) herein (RICO) activities acts and actions fully continue to depriving both past and present causing the Pro Plaintiff to continue suffrage “Actual Damages” in excess of $3000.00 U.S. Dollars in Lost of said “Construction tools” and the “Profession Trade” thereof since November 2007 well into the future of 2015. 72. Pro Se Plaintiff seeks same such “Actual Damages” exceeding (7) years Co- Defendant(s) “Edward McCray and Joyce M. Guy” herein depriving the Pro Se Plaintiff of his “personal property” namely “Construction tools” in excess of $3000.00 U.S. Dollars and “lost wages” at a minimums of $48,000.00 U.S. Dollars being a Independent Construction Contractor “lost wages” per (7) year ongoing lost since date of injury of November 2007 in the “Actual Theft” of Said Construction tools. With 6% interest incurred since date of injury being November 2007 being lost as being described in paragraph (68) herein Defendant (Attorney at Law) conspire (RICO) with the Co-Defendant(s) “Edward McCray and Joyce M. Guy” In the ongoing Civil Action suit in Texas State Court Docket No. A-180805 before the 58th Judicial District Court of Jefferson County Texas Pro Se Plaintiff seeks such actual damages in a “Summary Judgment motion” just filed in November of 2014 and being heard “oral and argue” before the “Honorable 58th Judicial District Court of Jefferson County Texas on December 17th 2014 at 8:30 am as this “Honorable 58th Judicial Court Having full ongoing expert “subject matter jurisdiction” over the Co- Defendant(s) “Joyce M. Guy” and “Edward McCray” and all “actual damages” Pro Se Plaintiff seeks therein “State Court”
  • 45.
    73. Other thanCo-Defendant(s) “Joyce M. Guy” and “Edward McCray” Collectively ongoing (RICO) Fraudulent activities among other “Federal Subject matter jurisdiction” wrongful “acts and actions” being committed in concert, collusion, and enjoyed manipulation and monetary gain derived thereof with Defendant as the Pro Se Plaintiff herein “Federal Questions” being raised before the “Honorable Justice” as to the Defendant and Co-Defendant(s) collective criminal/civil corrupted scheming uncivil behavior being committed Against the Pro Se Plaintiff civil rights, peace, will, and dignity in a Civil Suit in common Law in connection with the Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 defense thereof. which this “United States Eastern District Court of Texas having full expert “Honorable Justice” Subject Matter” over such among other things (RICO) activities described herein full And the further full knowledge Defendant (Attorney at Law) executed in full wrongful conspire involvement being of a “Legal expert” to commit to among other things “obstruction of justice”, corrupted, misleading, manipulation” and fraud commitment upon the 58th Judicial District Court of Jefferson County Texas in the public professional trade “among all things” The “fiduciary capacity” of a legal “Attorney at Law” and “Officer of the Court” in and For the State of Texas. 74. Cause of Actions Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “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”.
  • 46.
    Pro Se Plaintiffherein Incorporated and state all Defendant (Attorney at Law) and Co-Defendant(s) herein enjoyed collectively their “Intent” scheming fraudulent manufactory purpose in wanting the Pro Se Plaintiff herein to suffer, extreme agony, heartache, distraint, Accompany substantially massive monetary loss of “tools and services” in the Construction profession, 75. Humiliation, Defamation, and crushing legal defeat to inflict “excessive mental anguish” as a result of their combine craft complex ongoing conspire (RICO) elements, and fraud on the court to execute the same (RICO) objective All of which being past, present, and further derive thereof Pro Se Plaintiff suffrage such future (7) years of ongoing “mental intent contempt” of the Defendant and Co-Defendant(s) enforced legal corrupted strong hold over the “common law” rights of the Pro Se Plaintiff Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray”. Civilly accomplish with strong corrupted concealment motive not to be “confused or construed” with a simple attorney mistake by Defendant (Attorney at Law) a combine collective “cause of action” before the “Honorable Justice” for continual past, present, and future “Intentional Infliction of Emotional Distress”. 76. Cause of Actions Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist for “Declaratory Judgment” of the Honorable Court against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and against Co-Defendant(s) “Joyce M. Guy and Edward McCray” as to all of the “material subject matter” fully declared past, present and future Before the Honorable Justice herein
  • 47.
    Of the Defendantand Co-Defendant(s) Collective conclusive, conspire, concert, agreements, engagement, and execution, pilot, maneuver, manipulated, scheme upon (RICO) actions and dealing, Among other extreme behavior in fraudulent Corruption of The 58th Judicial District Court System to induce, and perpetrate such Fraud upon the Court for a period in excess of (19) Months as each so stated, affirm, and declared statement of “material facts”, “events” and “circumstances” described fully herein this Complaint 77. Put an end to a doubt as to the “gross civil intention” of “Antoine L. Freeman J. D. An “Attorney”, direct at the Pro Se Plaintiff “Civil Liberties” for a cause of action for “Declaratory Judgment” is made enter into the “Honorable Justice” decision, and final announcement of the Court Records against said Defendant. 78. Put an end to a doubt as to the “gross civil intention” of “Joyce M. Guy” and “Edward McCray” and their extreme scheming corrupted fraudulent behavior in “patter and practices” of Mutable (RICO) Fraudulent Scheming Enterprising Endeavors Co-Defendant(s) Collective conclusive conspire agreements, engagement, and execution, pilot, maneuver, manipulated, scheme upon (RICO) actions and mutable fraudulent underhanded dealing(s), Among other extreme outrageous behavior in fraudulent Corruption of “among others” The 58th Judicial District Court System to induce, and perpetrate such Fraud upon the Court for a period in excess of (19) Months As each so stated, affirm, and declared statement of “material facts”, “events” and “circumstances” described fully herein this Complaint direct at the Pro Se Plaintiff “Civil Liberties” a cause of action for “Declaratory Judgment” is
  • 48.
    made enter intothe “Honorable Justice” decision, and final announcement of the Court Records against said Co-Defendant(s) Collectively. 79. Pro Se Plaintiff herein “States”, “Affirm” and “Declare” further before the “Honorable Justice” a Cause of Actions exist for ‘Treble Damages” made enter into the “Honorable Justice” decision, and final announcement of the Court Records against said Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co- Defendant(s) “Joyce M. Guy” and Edward McCray” Collectively for their combine “wicked”, monstrous, appalling, atrocious, disgraceful, corrupted behavior direct at the Pro Se Plaintiff “Civil Liberties” . 80. Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court Justice, to Award to the Pro Se Plaintiff “Declaratory Judgment” against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” Collectively in favor of the Pro Se Plaintiff. 81. Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the Honorable Court Justice, to Award to the Pro Se Plaintiff “Actual Damages” against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 for fraudulent conspire against Pro Se Plaintiff “personal property” namely “Construction Tools” Pro Se Plaintiff Personal property Lost in tool(s) is in excess of $3093.00 dollars Award further with full 6% interest rate incurred since date of injury from November 16th 2007 continual on into 2015 in excess of at a rate of (7) years and continual counting in favor of the Pro Se Plaintiff 6% interest incurring. 82.
  • 49.
    Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice”, to Award to the Pro Se Plaintiff “Actual Damages” against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 for fraudulently conspire against Pro Se Plaintiff as described herein this complaint for “Actual Damages” of “Lost wages” and “Loss of earning capacity” incurred in the “Continual Actual Theft” and “further executed fraudulent conspirers activities Derive thereof” and fully committed, manipulated, scheme against by Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 herein in the “expert legal professional capacity” as a “Attorney of Law” Civilly in a Suit in “common Law” against the Pro Se Plaintiff “personal property” namely “Construction tools”, involving Pro Se Plaintiff Special Trade, Skill and Profession thereof, in excess of $48,000.00 U.S. Dollars per year in lost wages Being a accumulated rate now in excess of $336,000.00 U.S. Dollars for the past (7) years “Lost wages” and “Lost earning capacity” Pro Se Plaintiff endure suffrage thereof. “Award” further with full 6% interest rate incurred since date of injury from November 16th 2007 continual on into 2015 in excess of at a rate of (7) years past and continual counting in favor of the Pro Se Plaintiff 6% interest incurring. 83. Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for damages in the amount of the Honorable Court Justice for the Plaintiff suffrage of “Intentional Infliction of Emotional Distress” and “Mental Anguish” in Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 in Favor of the Pro Se Plaintiff. 84.
  • 50.
    Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for damages in the amount of the Honorable Court Justice for the Plaintiff suffrage of “Intentional Infliction of Emotional Distress” and “Mental Anguish” in Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against Co-Defendant(s) “Joyce M. Guy” and Edward McCray” in favor of the Pro Se Plaintiff. 85. Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for Award of “Treble Exemplary Damages” Statue of the “Honorable Court Justice” against Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 in favor of the Pro Se Plaintiff. 86. Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for Award of “Treble Exemplary Damages” Statue of the “Honorable Court Justice” against Co-Defendant “Joyce M. Guy” and Edward McCray” Collectively in favor of the Pro Se Plaintiff. 87. Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for damages in the amount of the Honorable Court Justice for the Plaintiff suffrage of Defamation of the Pro Se Plaintiff Construction Reputation in Excess of the Jurisdictional amount of $75,000.00 U.S. Dollars against Co-Defendant(s) “Joyce M. Guy” and “Edward McCray” collectively in favor of the Pro Se Plaintiff. 88. 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.
  • 51.
    Dollars against Co-Defendant(s)“Joyce M. Guy” and “Edward McCray” collectively in favor of the Pro Se Plaintiff for (RICO). 89. 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 Defendant Antoine L. Freeman J. D. Attorney at Law Texas Bar No. 24058299 in favor of the Pro Se Plaintiff for (RICO). 90. Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the “Honorable Court Justice” for a Order the Defendant and Co-Defendant(s) collectively pay all court cost of this U.S. Civil Court Action. 91 Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves and Request the “Honorable Court Justice” for any further, Just, proper, Damages, Orders, and Awards The “Honorable Court Justice” Deems favorable for the behalf of Pro Se Plaintiff “Louis Charles Hamilton II” herein. By, _______________________________ Louis Charles Hamilton II Pro Se Plaintiff P.O. Box 17524 Sugar Land Texas 77496