1. The plaintiff filed a motion for sanctions against the defendants for failing to comply with a court order to produce documents related to property ownership and hurricane damage estimates. 2. The court had previously ordered the defendants to produce deeds, property records, and construction estimates for hurricane damage to a property by May 2010, but the defendants did not comply. 3. The plaintiff is requesting sanctions in the amount of $4,500 against the defendants for disregarding the court order from May 2010 through December 2014.

1. No. A-180805
Louis Charles Hamilton II INTHE DISTRICTCOURT
Plaintiff 58TH
JUDICIAL DISTRICT
V.
Joyce Guy & Edward McCray ET AL OF JEFFERSONCOUNTY, TEXAS
Defendants.
PLAINTIFF MOTIONFOR SANCTIONS
Motion before the HonorableCourt, For a Sanctions, being enforced
against the Defendant(s) and for just causethe Pro Se Plaintiff state as Follows:
Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This
Honorable58th
DistrictCourt of Jefferson County Texas on the 10th
day of May
2010 to produce copies of deeds, property deeds or any other suchphysical
document in Defendants’
Possession, custody or control that shows actual ownershipof the
property of the dwelling locatedat 448 DeQueenBlvd., inPort Arthur Texas and
fully failing to adhere to an Honorable Court Order.
Defendant(s) already refused completely discovery devises being numerous
requests of the Plaintiff threw the Crafty shady slights of hand acts and actions
Attorney of Record “Antoine L. Freeman, J.D. Texas Bar No. 24058299
Fully Committing to the same fraud in conspiring with the Defendant(s) to
with hold all records of to this civil action at any cost, considering the enforced
criminal penalties in light of the many frauds being committed againstInsurance
companies, and FEMA claims for damages, as a result of this History of Hurricane
Damages of related God Act’s as described by the Plaintiff his “Investigation
Concluded”

2. That Elementary Indeed, the Defendant(s) arequite crafty in hustling
numerous fakebusiness, to include but not limited to Defendant(s) engaging
illegal sales of a “Crack Industry” for which Defendant(Edward McCray) convicted
twice of Federal Traffic of Crack Cokecaine, serving two separate prison terms,
which Plaintiff also described before the HonorableCourtDefendant(s) business
of recycle of Cans, as resulting also raid by PAPD Dept. for the City of PortArthur
Texas engaging in “illegal scrap metal Industry”
While Defendant(s) “JoyceGuy” already committed for way to many
uncountless years of a undocumented “gruesome medical business”taking care
of the Poor elderly Senior Citizens not even having documented health Lic# or any
kind with the State of Texas or any kind of Insuranceon this medical business, or
proper personaldealing with Poor elderly Senior Citizens.
Pro Se Plaintiff moves respectfully beforethe HonorableCourt that these
Crude Defendant(s) bedealt there on devise
To include having a total disregard for the HonorableCourt, Plaintiff, Civil
Rights, Peace and Dignity
And an Ordered into these records for sanctions being fully merit against
the Defendant(s) “Joyce Guy” and “Edward McCray” for their collective refusalof
the 58th
DistrictCourtOrders attached herein with this Motion for sanctions
against the Defendant(s).
Defendant(s) having stolen the Plaintiff lively hood of Construction tools’ in
excess of $3093..00 dollars in their possession, custody and controlover now a
period of 7 years and counting.
Defendant and Defendant’s Attorney did in fact violated rule 193.1 by
failing to respond to Plaintiff’s discovery request AS Plaintiff files all Proof
attached to Plaintiff Motion for Final Summary Judgment
Defendant(s) continue to commit to the same, and refusalof a Court Order
to submit to Plaintiff Discovery Request
Court Order was enforced on the 10th
day of May 2010

3. Defendant(s) continualto commit to refusal of The Jefferson County 58th
District Judicial “CourtOrder” being now 4 years and 6 Months and counting
The Defendant(s) Extreme “Wicked” and “Hostile” unwanted actions
Directed at the Plaintiff “Civil Rights”, “Peace” and “Dignity” within Jefferson
County Texas with actual damages being in excess of the Amount of $11,024.00
combine for Defendant(s) “Breach of Contract” with full 6% interest rate incurred
since date of injury November 16th
2007
1.
Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves the
HonorableCourt to grant the Plaintiff attached joining motion for sanctions filed
herein with good “Merit” for the Discovery which was Order to be produced by
The Court
Defendant(s) “Joyce Guy and Edward McCray” Was so Order By This
Honorable58th
DistrictCourt of Jefferson County Texas on the 10th
day of May
2010 to produce copies of deeds, property deeds or any other suchphysical
document in Defendants’ possession, custody or control that shows actual
ownershipof the property of the dwelling locatedat 448 DeQueenBlvd., inPort
Arthur Texas
Defendant(s) Further Order to beproduced by The Court Defendant(s)
“Joyce Guy and Edward McCray” Was so Order By This Honorable58th
District
Court of Jefferson County Texas on the 10th
day of May 2010 to produce
Copies of any and all construction estimates for repairs inDefendants’
possession, custody or control inrelationshiptodamage causedby Hurricanes
Rita, Humbertoand Ike to the property locatedat 448 DeQueenBlvd. inPort
Arthur, Texas.
And apply civil sanctions againstthe Defendant(s) in excess of $1000.00
U.S. dollars per every year betweenthe dates of 2010-2014 theDefendant(s)
collectively being quite bold hostile disrespectfulfleeing absconded completely

4. fromthe civil actions as they were so required to producesuch discovery via the
HonorableCourt Order of the 58th
DistrictCourtof Jefferson County Texas.
2.
Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves the
HonorableCourt sanctions amountbeing granted in favor of the Plaintiff in the
amount of $4500.00 U.S. Dollars fromdates of 10th
day of May 2010 throughout
December 17th
2014
As undersigned date being before “OralArguments/Hearing” on the 17th
day of December 2014 at8:30 before the Court.
3.
Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves The
HonorableCourt for any further, Just, proper until this Civil Disputehas reach a
Full, Final and Complete Judgment of This Honorable58th
DistrictCourt of
Jefferson County Texas in Favor of the Pro Se Plaintiff.
By, _______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496