Pro se plaintiff, “louis charles hamilton ii”, co plaintiff(s) “united states of america” et al and co-plaintiff “state of texas” et al vs. chief defendant doctor dinesh chandra khare, and geeta international et al
U.S. Docket No. 15-MC-2283 Pro Se Plaintiff, “Louis Charles Hamilton II”, Co-Plaintiff(s) United States of America” et al, and Co-Plaintiff “State of Texas” et al, vs. Chief Defendant “Doctor Dinesh Chandra Khare”, Co-Defendant(s) “Geeta International” et al, Co-Defendant(s) “Geeta International Legal Division” et al, “Geeta International Co. Ltd.”, Co-Defendant(s) GEETA Group LLC et al, Co-Defendant Vipul Khare, Co-Defendant(s) “Rishu Khare” Plk LLC, And Co-Defendant(s) “Vijay Khare” Co-Defendant(s) “Greg Miller” of “Trillionaire Realty”, and “Trillionaire Assets”
Moo ha-ha-ha “cmdr. bluefin†halloween special iv… it’s bloody soakin...
Similar to Pro se plaintiff, “louis charles hamilton ii”, co plaintiff(s) “united states of america” et al and co-plaintiff “state of texas” et al vs. chief defendant doctor dinesh chandra khare, and geeta international et al
Similar to Pro se plaintiff, “louis charles hamilton ii”, co plaintiff(s) “united states of america” et al and co-plaintiff “state of texas” et al vs. chief defendant doctor dinesh chandra khare, and geeta international et al (20)
Andrea Hill Featured in Canadian Lawyer as SkyLaw Recognized as a Top Boutique
Pro se plaintiff, “louis charles hamilton ii”, co plaintiff(s) “united states of america” et al and co-plaintiff “state of texas” et al vs. chief defendant doctor dinesh chandra khare, and geeta international et al
1. In The UnitedStates District Court
For The SouthernDistrictof Texas
HoustonDivision
Louis Charles HamiltonII
Pro Se Plaintiff
And
Co- Plaintiff(s) “UnitedStates of America”et al
And
Co-Plaintiff(s) “State of Texas”et al
Vs.
Doctor DineshChandra Khare “Chief Defendant”
“Managing Director”
“GeetaInternational Co. Ltd.”
2194/48-50 Chareonkrung
BangkoholamBangkoholam
Bangkok 10120 Thailand
94/10 Phet Kasem3 Soi 2,
Vs.
“GeetaInternational” et al
94/10 Phet Kasem3 Soi 2, Co-Defendant(s)
Bang Khae Nuea,
2. Bang Khae,
Bangkok 10160, Thailand
Vs.
“GeetaInternational Legal Division”et al
94/10 Phet Kasem3 Soi 2, Co-Defendant(s)
Bang Khae Nuea,
Bang Khae,
Bangkok 10160, Thailand
Vs.
GEETA Group LLC
1600 River Pointe Dr. Apt. 812, Co-Defendant(s)
Conroe, Texas 77304
Vs.
VipulKhare
1600 River Pointe Dr. Apt. 812, Co-Defendant(s)
Conroe, Texas 77304
Vs.
RishuKhare
Plk LLC
3. 616 Bourne Ct. Co-Defendant(s)
Danville California 94506
Vs.
Vijay Khare
616 Bourne Ct. Co-Defendant(s)
Danville California 94506
Vs.
Trillionaire Assets et al
302 N. Houston#201 Co-Defendant(s)
Humble Texas, 77338
Vs.
Trillionaire Realty et al
302 N. Houston#201 Co-Defendant(s)
Humble Texas, 77338
Vs.
Greg Miller
302 N. Houston#201 Co-Defendant(s)
Humble Texas, 77338
Ph. (832) 928-8763
4. Civil Complaint
Jury Demand
Comes Now the Pro Se Plaintiff “Louis Charles HamiltonII” hereinfiles
“Civil Complaint”on behalf of himself in(Person) namely Pro Se Plaintiff “Louis
Charles HamiltonII”
Comes Now the Pro Se Plaintiff “Louis Charles HamiltonII” hereinfiles on
behalf of Co-Plaintiff(s) “UnitedStates of Americaet al”
And on behalf of Co-Plaintiff “State of Texas et al” Vs. Doctor DineshChandra
Khare, GeetaInternational et al, “GeetaInternational Legal Division”et al,
“GeetaInternational Co. Ltd.”,
GEETA Group LLC et al, Vipul Khare, Greg Miller, TrillionaireRealty et al”,
and Trillionaire Assets et al”, withinthe above Honorable U.S. District Court and
for Just Cause,
Pro Se Plaintiff hereinwill showbefore the “Honorable U.S. District
Court””Honorable Justice”Civil Cause of Actions, for
Specifically, “International RICO Racket”toDefraud“UnitedStates of
America”as a Whole”in Violationof 18 U.S.C. § 371 §371 withall (Defendant(s)
and Co-Defendant(s) committedto“Conspiracy tocommit offense or to defraud
UnitedStates”
Specifically of Title III of the. "USA Patriot Act"In connectionwitha
International (RICO) Cartel scheme of things engaging furtherance’s
Specifically, violationsof “18 USC § 1343 RICO Wire Fraud”, and
Specifically, violationsof RICO statute (18 U.S.C. § 1961(1) “Money
laundering”
Specifically, violationsof RICO statue “18 USC § 1341 “Mail Fraud”,
5. Specifically, violationsof 18 U.S. Code § 1028A
Specifically, violationsof 18 U.S. Code § 1001
Specifically, violationsof“18 USC § 1956 (A) (1)
Specifically, violationsof 18 U.S.C. 1028A - Aggravatedidentity theft
Specifically Computer Fraudand Abuse Act (CFAA) 18 U.S.C. §1030
Specifically, violationsof DeceptiveTrade Practices Acts, Brought in
conjunction with“Common law” Fraud, and “Breachof ConstructionContract”
committedagainst namely Pro Se Plaintiff “Louis Charles HamiltonII” herein
Specifically “Obstructionof Justice”, “Medical Battery”, Battery,
“Harassment”, “Public Nuisance”, “Civil Conspirer”, “Intent Gross Negligence”,
“Slander”, “Breachof Fiduciary Duty”,
“False Promise of Future Performance, Detrimental reliance’s”and
“Intentional inflictionof emotional distress
Committedby all describedDefendant(s) andCo-Defendant(s) above
collectively hereinagainst the ProSe Plaintiff “Louis Charles HamiltonII, herein
his (Person) and against his “Civil Rights”, “Will”, “Peace”and “Dignity”and
committedagainst Co- Plaintiff(s) “UnitedStates of America”et al and Co-
Plaintiff(s) “State of Texas”et al
Comes Now the Pro Se Plaintiff “Louis Charles HamiltonII” will showthe
“Honorable Justice as follows:
I.
Parties.
Pro Se Plaintiff, Louis Charles HamiltonII, and AfricanAmericanMale, U.S.
Navy Veteran, Permanently Disable Veteranprotectedunder: (ADA) American
withDisability Act;
6. And alsominorities persons cover under TitleVII of the Civil Rights Act of
1964; Domiciliary State of Texas, P.O. Box 17524 Sugar Land, Texas 77496
Chief Defendant “Doctor DineshChandraKhare”, “Managing Director of
(Geeta) International CoLtd.
Co-Defendant(s) “GeetaInternational”et al and GeetaInternational”Legal
Division” et al, Co-Defendant(s) “GeetaInternational Co. Ltd.”
Co-Defendant(s) GEETA GroupLLC. AndCo-Defendant(s) Vipul Khare
Business is listedas 1600 River Pointe Dr. Apt. 812, Conroe, Texas 77304
“Geeta”and “International Businessgroupbasedin“Thailand” and
Focusedon the retail and consumer packagedgoods segment covering
“Thailand” “UnitedStates”and “India”,
Co-Defendant(s) Greg Miller of Trillionaire Realty et al and Trillionaire Assets et
al of Humble Texas, 77338
II.
JurisdictionandVenue
This Honorable Court Has Subject Matter Jurisdictionover the Pro
Plaintiff Claims brought under Specifically, “International RICO Racket”to
Defraud“UnitedStates of America”as a
Whole” inViolationof 18 U.S.C. § 371 §371 withall Defendant(s) andCo-
Defendant(s) committedto“Conspiracy tocommit offense or to defraudUnited
States” inconnectionwith violations
Specifically of Title III of the. "USA Patriot Act" Inconnectionwitha
International (RICO) Cartel scheme of things engaging furtherance’s
Specifically, violationsof “18 USC § 1343 RICO Wire Fraud”, and
7. Specifically, violationsof RICO statute (18 U.S.C. § 1961(1) “Money
laundering”
Specifically, violationsof RICO statue “18 USC § 1341 “Mail Fraud”,
Specifically, violationsof 18 U.S. Code § 1028A
Specifically, violationsof 18 U.S. Code § 1001
Specifically, violationsof“18 USC § 1956 (A) (1)
Specifically, violationsof 18 U.S.C. 1028A - Aggravatedidentity theft
“18 USC § 1343 RICO Wire Fraud”,
This Honorable UnitedStates District Federal Court of the UnitedStates of
AmericaHas Subject Matter Jurisdictionover the Chief Defendant “Doctor
DineshChandra Khare” inthat a “International Diversity of Jurisdiction”exist
BetweenProSe Plaintiff
“Louis Charles HamiltonII” herein amount in controversy exceed
$75,000.00 U.S. Dollars andChief Defendant “Doctor DineshChandraKhare”,
“Managing Director of (Geeta) International CoLtd., Co-Defendant(s) “Geeta
International”et al and GeetaInternational”Legal Division” et al, Co-
Defendant(s) “GeetaInternational Co. Ltd.”, Co-Defendant(s) GEETA GroupLLC.,
And Co-Defendant(s) Vipul Khare are foreignNationals from “Thailand”.
Co-Defendant(s) Greg Miller of Trillionaire Realty et al and Trillionaire
Assets et al of Humble Texas, 77338 having (American) citizenship established
status withinthe State of Texas.
(1)
Pro Se Plaintiff “Louis Charles HamiltonII” “State, Declare andAffirm,
before the “Honorable UnitedStates Justice”onbehalf of his (Person)
8. And on Behalf of Co-Plaintiff(s) “UnitedStates of America”et al and Co-
Plaintiff(s) “State of Texas”et al further “State, Declare andAffirm, Before The
“Honorable UnitedStates Justice”
Chief Defendant “Doctor DineshChandra Khare”Co-Defendant(s) “Geeta
International”et al, Co-Defendant(s) “GeetaInternational Legal Division”et al,
Co-Defendant(s) GEETA GroupLLC et al, “GeetaInternational Co. Ltd.”, and Co-
Defendant Vipul Khare collectively herein
(2)
Having formulateda “International RICO Enterprise Racket”engaging in
among other things “Mutable Counts”of interstate“Mail andWire Fraud”, and
“International Mail andWire Fraud” scheme of things tooperate collectively as
a “Enterprise Racket”withinthe Co-Plaintiff “UnitedStatesof America”and Co-
Plaintiff(s) “State of Texas”Jurisdiction,
To include but not limitedtoupon further informationprovidedherein
and belief such“International RICO EnterpriseRacket”describedfully herein
having already beeninstitutedandfully commenced inthe “State of California,
“State of Florida” and the “State of NewYork” and the State of Texas ,
Further ProSe Plaintiff respectfully Assert, declareandconfirmbefore the
Honorable U.S. Justice inthat the Chief Defendant “Doctor DineshChandra
Khare”, hereinhaving “Legal Property Holdings andBanking accounts within
both “State of Californiaand the “State of NewYork” describedas follows:
A. Chief Defendant “Doctor DineshChandraKhare” Californiadriver
records maintainan address as listed616 Bourne Ct Danville CA 94506
withCell-Ph. (936) 900-7650
B. Further Chief Defendant “Doctor DineshChandraKhare”, herein
maintain an address as listed156 CoburnRoad Pennington, NJ08534
C. As Identifiedona Fraud (RICO) Check Scheme of things to advance said
Fraud against the Pro Se Plaintiff hereinwiththe financial usage
institutionof the “CitiBank N.A. BR. #128 37-57 74th
streetJackson
9. Heights, NY 11372andsame scheme of things with“CitiBank”branch
in The San FranciscoBay Area“California
(3)
Pro Se Plaintiff further respectfully Assert, declare andconfirmbefore the
Honorable U.S. Justice Chief Defendant “Doctor DineshChandraKhare” Co-
Defendant(s) “GeetaInternational”et al, Co-Defendant(s) “GeetaInternational
Legal Division”et al, Co-Defendant(s) GEETA GroupLLC et al, “Geeta
International Co. Ltd.”, and Co-Defendant Vipul Khare collectively herein
formulatedsaid
“International RICO EnterpriseRacket”engaging inamong other things
“Mutable Counts”of interstate“Mail andWire Fraud”, and “International Mail
and Wire Fraud” scheme of things tooperate collectively as a“Enterprise
Racket”as well withinthe “State of California, Texas, Florida, and the “State of
New York” as all being legally describedof sucha International and Interstate
(RICO) Mail and Wire Fraud” scheme of things.
(4)
Further Chief Defendant “Doctor DineshChandraKhare”Co-Defendant(s)
“GeetaInternational”et al, Co-Defendant(s) “GeetaInternational Legal
Division”et al, Co-Defendant(s) GEETA GroupLLC et al, “GeetaInternational Co.
Ltd.”, and Co-Defendant Vipul Khare collectively hereinhaving further
formulatedsaid“International RICO EnterpriseRacket”toengaging inamong
other scheme of things:
1. Conspirer tocommit structuring andmoney laundering “18 USC § 371
2. Money laundering by concealment “18 USC § 1956 (A) (1)
3. “Conspiracy to commit offense or to defraud Co-Plaintiff United
States”et al in violationof 18 U.S.C. § 371 §371
4. “Conspiracy to commit offense or to defraud Co-Plaintiff “State of
Texas”et al in violationof 18 U.S.C. § 371 §371
5. Conspirer tocommit cyber Identity theft Fraudand relatedactivity in
connectionwithidentificationdocuments, authenticationfeatures,
10. and information in violationof 18 U.S. Code § 1028 inconnectionand
concert with(RICO) “International Wire fraud”
6. Conspirer tocommit false statements, concealment against the civil
rights peace and dignity of ProSe Plaintiff “Louis Charles HamiltonII”
in violationof 18 U.S. Code § 1001
7. Conspirer tocommit false statements, concealment against the Co-
Plaintiff “UnitedStates of America”et al in violationof 18 U.S. Code §
1001
8. Conspirer tocommit false statements, concealment against the Co-
Plaintiff “State of Texas” et al in violationof 18 U.S. Code § 1001
9. Conspirer tocommit “Tax Evasion”on both Federal and State level
10.Aggravatedidentity theft(Physically) committedagainst the ProSe
Plaintiff “Louis Charles HamiltonII” Identity, Social Security Number
and Signatures by means of “Chief Defendant “Doctor DineshChandra
Khare”, Co-Defendant(s) “GeetaInternational”et al, Co-Defendant(s)
“GeetaInternational Legal Division”et al, “GeetaInternational Co.
Ltd.”, Co-Defendant(s) GEETA GroupLLC et al, and Co-Defendant Vipul
Khare collectively hereinhaving illegally gainsuchpossessionof ProSe
Plaintiff “Louis Charles HamiltonII” Identity, Social Security Number
and Signatures by means of “Interstate wire andInternational wire”,
fraud direct against ProSe Plaintiff “Louis Charles HamiltonII”in
violationof 18 U.S. Code § 1028A – in connectionwith interstate
“Wire Fraud”, and “International Wire Fraud”“International RICO
Enterprise Racket”scheme of things.
11.Conspirer tocommit Aggravatedcyber identity theftagainst other
similarly the same having “public business dealing”with GEETA Group
LLC et al, “Doctor DineshChandra Khare”, Vipul Khare, and the direct
usage of all business records, involving withCo-Defendant(s) GEETA
Group LLC et al, in a “International andInterstate (RICO) Wire Fraud
Scheme of things such(records, documents andpersonal information)
forwarding to “GeetaInternational”et al, “GeetaInternational Co.
Ltd.”,and Co-Defendant(s) “GeetaInternational Legal Division”et al,
having derive first inthe possession, custody andcontrol of by Chief
11. Defendant “Doctor DineshChandraKhare” and Co-Defendant “Vipul
Khare”. AndCo-Defendant(s) GEETA GroupLLC et al locatedat 1600
River Pointe Dr. Apt. 812, Conroe, Texas 77304,
12.Having (Already) conspirer toformulatedsaid“International RICO
Enterprise Racket”engaging in a well-establishedserviceof
“International Lawyers”tocommit to Conspirer tocommit Aggravated
cyber illegal transactions of ProSe Plaintiff business records, personal
information, social security number and“Signatures”toThird world
Countries namely “Thailand and India” among other “International
Community” for exploitationby way “International cyber Identity
Theft as well as “Chief Defendant “Doctor DineshChandraKhare”, Co-
Defendant(s) “GeetaInternational”et al, Co-Defendant(s) “Geeta
International Legal Division”et al, Co-Defendant(s) GEETA GroupLLC et
al, and Co-Defendant Vipul Khare collectively hereinhaving legal
standing, past, present andfuture possession, custody andcontrol to
commit toConspirer tocommit Aggravatedcyber identity theft against
all similarly the same
13.Having formulatedsaid“International RICO Enterprise Racket”
engaging in a well-establishedservice of “International Lawyers”to
facilitate illegal transactions inviolations onCo-Plaintiff “UnitedStates
of Americaand Co-Plaintiff(s) “State of Texas”Federal andState Laws.
14.Having formulatedsaid“International RICO Enterprise Racket”
engaging in a well-establishedservice of “International Lawyers”to
facilitates illegal transactions inviolations of ProSe Plaintiff Civil Rights
as a (American) Citizenandother similarly the same
15.Having formulatedsaid“International RICO Enterprise Racket”
engaging in a well-establishedservice of “International Lawyers”to
facilitates andregulate said(RICO) scheme of things to control over
Co-Plaintiff “UnitedStates of America”namely “InterstateCommerce”
in the NewHome Construction“Independent Contractor Labor prices
and wages and materials pricing control “scheme of things”
16. Having formulatedsaid“International RICO EnterpriseRacket”
engaging in a well-establishedservice of “International Lawyers”to
12. fully eliminate, facilitates, committedto“Obstructionof Justice”to
regulate bothCo-Plaintiff “UnitedStates of America”andCo-
Plaintiff(s) “State of Texas”Federal andState “Judicial Branch of
Government”against the ProSe Plaintiff “Louis Charles HamiltonII
hereinand other similarly the same inconnectiontofurtherance said
“International RICO EnterpriseRacket”withinthe Co-Plaintiff “United
States of America” and Co-Plaintiff “State of Texas” Jurisdiction
17.Having formulatedsaid“International RICO Enterprise Racket”
engaging in a well-establishedservice of “International Lawyers”to
fully eliminate, facilitates, andregulate bothCo-Plaintiff “United
States of Americaand Co-Plaintiff(s) “State of Texas”Federal andState
“Judicial Branch of Government”“Due Process clause”of The
AmericanConstitutionof the Co-Plaintiff(s) “UnitedStatesof America”
and fully eliminate, facilitates, andregulate “Due Process clause”of
the “State of Texas”Constitutionof the Co-Plaintiff(s) “State of Texas”
against the Pro Se Plaintiff “Louis Charles HamiltonII hereinand other
similarly the same inconnectionto furtherance said“International
RICO Enterprise Racket”withinthe Co-Plaintiff “UnitedStates of
America”and Co-Plaintiff “State of Texas”Jurisdiction
18.Having formulatedsaid“International RICO Enterprise Racket”
engaging in a well-establishedservice of “International Lawyers”to
fully eliminate, facilitates, andregulate bothCo-Plaintiff “United
States of Americaand Co-Plaintiff(s) “State of Texas”Federal andState
“Judicial Branch of Government”“Equal Protectionof the Law clause”
of The AmericanConstitutionof the Co-Plaintiff(s) “UnitedStatesof
America”and fully eliminate, facilitates, andregulate “Equal
Protectionof the Law clause”of the “State of Texas”Constitutionof
the Co-Plaintiff(s) “State of Texas”against the ProSe Plaintiff “Louis
Charles HamiltonII hereinand others similarly the same inconnection
to furtherance said“International RICO EnterpriseRacket”withinthe
Co-Plaintiff “UnitedStates of America”andCo-Plaintiff “State of
Texas”Jurisdiction.
13. 19.Having formulatedsaid“International RICO Enterprise Racket”
engaging in a well-establishedservice of “International Lawyers”to
“Exploit”Co-Plaintiff(s) “UnitedStatesof Americaet al” and Co-
Plaintiff(s) “State of Texas et al” lack thereof of Title VII of the Civil
Rights Act of 1964;and (ADA) AmericanwithDisability Act;full
protectionof Pro Se Plaintiff, Louis Charles HamiltonII, and African
AmericanMale, U.S. Navy Veteran, Permanently Disable Veteran
protectedunder:(ADA) AmericanwithDisability Act;andalso
minorities personscover under Title VII of the Civil Rights Act of 1964;
Domiciliary State of Texas, P.O. Box 17524 Sugar Land, Texas 77496 *A
“Independent ConstructionContractor whichChief Defendant “Doctor
DineshChandra Khare”, Co-Defendant(s) GEETA GroupLLC et al and
Co-Defendant Greg Millerof Trillionaire Realty et al”having fully
engage in suchhostile Discriminationpatternandpractices in
conjunctionwith “Medical Battery”, “Harassment”, and“Public
Nuisance”, tofurther provide advancement thereof andprotection
thereof said“International RICO Enterprise Racket”inconcert,
collusionwithall said describedDefendant(s) andCo-Defendant(s)
collectively hereinagainst ProSe Plaintiff “Louis Charles HamiltonII”
others similarly the same.
20.Having formulatedsaid“International RICO Enterprise Racket cartel”
engaging specifically inconspirer against TitleIII of the "USA Patriot
Act".
(5)
Pro Se Plaintiff Louis Charles HamiltonII herein“Declare”, State, and
Affirmbefore the “Honorable U.S. Justice” ProSe Plaintiff on his (Personal)
behalf and on the behalf of Co-Plaintiff(s) “UnitedStates of America”et al and
Co-Plaintiff(s) “State of Texas”et al in that
Chief Defendant “Doctor DineshChandraKhare”, hereinbeing first and
foremost “front man” on behalf of all describedCo-Defendant(s) collectively
herein
14. Betweenthe exact dates of June 25th
2015 andJuly 6th
7:20 pm 2015 Chief
Defendant “Doctor DineshChandraKhare” first approached(Pro Se Plaintiff)
hereinon behalf of himself and all the describedCo-Defendant(s) inparagraph
(1-4) above collectively hereinina half bake (RICO) combine “international
greedy racket enterprise” inassociationwith
Violations of “18 USC § 1343 Wire Fraud”, Interstate andInternational
“scheme of things”having accumulatedgradually past acquisitionof a simple
“Fraud and Breachof ConstructionContract”incommon law withinthe Co-
Plaintiff “State of Texas” Jurisdictioninthat “
(6)
Pro Se Plaintiff “Louis Charles HamiltonII” hereinfurtherance’s“Declare”,
“State”, and “Affirm”before the “Honorable U.S. Justice” for Pro Se Plaintiff
hereinon his (Personal) behalf and on the behalf of Co-Plaintiff(s) “United
States of America”et al and Co-Plaintiff(s) “State of Texas”et al in that Chief
Defendant “Doctor DineshChandraKhare”, Co-Defendant(s) “Geeta
International”et al, Co-Defendant(s) “GeetaInternational Legal Division”et al,
“GeetaInternational Co. Ltd.”, Co-Defendant(s) GEETA GroupLLC et al, and Co-
Defendant Vipul Khare
After sometime their after the meeting of the “Minds”of said
“International Racket cartel”Chief Defendant “Doctor DineshChandraKhare”
Co-Defendant(s) “GeetaInternational”et al, Co-Defendant(s) “Geeta
International Legal Division”et al, “GeetaInternational Co. Ltd.”,
Co-Defendant(s) GEETA GroupLLC et al, and Co-Defendant Vipul Khare
collectively hereinhaving further formulatedsaid
“International RICO EnterpriseRacket”toengaging andconspire inamong
other a “scheme of things”as describedinParagraph(4) 1-20 above, to
Furtherance’s exactly onor about the 12th
day of June 2015 as described
by the Co-Plaintiff (State of Texas) Secretary for the “State of Texas”createdan
empty shell company as follows:
15. *“GEETA GROUP LLC, FILE DATE 06/12/2015, FILING TYPE“CORPORATE”,
REGISTRATED AGENT“VIPUL KHARE” 1600 RIVER POINTEDR. APT 812, CONROE,
TEXAS 77304, MONTGOMERY COUNTY*
(7)
Pro Se Plaintiff “Louis Charles HamiltonII” hereinfurtherance’s“Declare”,
“State”, and “Affirm”before the “Honorable U.S. Justice” for Pro Se Plaintiff
hereinon (Personal) behalf and on the behalf of Co-Plaintiff(s) “UnitedStates of
America”et al and Co-Plaintiff(s) “State of Texas”et al
In that on or about the same 12th
day of June 2015 GeetaGroupLLC being
a said “Empty LLC Shell corporations”operating withinthe Co-Plaintiff “State of
Texas”Jurisdictionnamely Co-Defendant(s) “Geeta Group LLC”hereinwas
formedhaving a name similar toexisting name of that Co-Defendant(s)
“GeetaGroup International et al”base at 94/10 Phet Kasem3 Soi 2, Bang
Khae Nuea, Bang Khae, Bangkok 10160, Thailandand Co-Defendant(s)
“GeetaInternational et al”(IP) International Email address being
geetaint@loxinfo.co.th;
Physically the “exact same” email address for Co-Defendant(s) “GeetaLLC”
being 1 of 5 Business listedat 1600 River PointeDr. Apt. 812, Conroe, Texas
77304
WithCo-Defendant(s) “GeetaGroup LLC”operating withinthe Jurisdiction
of the Co-Defendant(s) “State of Texas”being 1 of 5 Business listedas 1600
River Pointe Dr. Apt. 812, Conroe, Texas 77304 (Legal) Business address for Co-
Defendant(s) “Geeta GroupLLC”herein.
(8)
Pro Se Plaintiff “Louis Charles HamiltonII” hereinfurtherance’s“Declare”,
“State”, and “Affirm”before the “Honorable U.S. Justice” for Pro Se Plaintiff
hereinon (Personal) behalf and on the behalf of Co-Plaintiff(s) “UnitedStates of
America”et al and Co-Plaintiff(s) “State of Texas”et al
16. That “However”Chief Defendant “Doctor DineshChandraKhare”, on July
8th
, 9th
, 12th
, 17th
, 26th
, and August 7th
and 23rd
in the year 2015 reasonably
foreseeable knewthat interstate wire communicationswouldbe used;and
“interstatewire communications”were infact used…
As describedinparagraph(9) belowto further this fraudulent
international (RICO) wire fraud“scheme of things” describedhereininaddition
to the numerous cell Phone call and (IM) instant messages”involved
notwithstanding U.S. Mail,
(9)
(July 8th
2015)
Dear Louis
Itwas nice wemet and discussed possiblebusiness. I amstudying your proposal
to constructcomplete houseof 1842 sqftof living area @$48/sqft. As discussed I
am attaching the softcopy of full plan set. This plan has not yet been submitted
to HOA and may vary slightly but basis will remain unchanged. Kindly send me
your address wherewecan meet next time when I come to south. you can
contact me at contacts given below
Regards
Dr. Khare
Disclaimer:
The study is with outa commitmentfrom either side and will become a
commitmentonly after contractis committed
(July 8th
2015)
hi you can meet me on job locations any time you call, I moving now as we are
build on 40 lots, and camping out to becauseof different job locations on the
outside of Houston area, fromLa Port- to Humble ..........I looking forward to
your project and consider renting in this location while projectbe fixed, the Lake
so nice to jet skion :) your project at $48 per sq. ft. for total of $88,416 is
17. good...butwilling to reduce to $46 per sq. ft on condition of starting the other
projectfoundations after another to speed up the build process for the next two
years of home construction....
and my goal is simple...to marry "MischellManeja" fromthe Philippines as I show
you her picture, I have everything I need in the United States, good skills, smart
company, and good family backing.... my goal is her being my future wife,
secured and happy so for her Love, (I) reduced my price to $46 dollars per sq. ft.
= $84,732 for thatproject and each and every one thereafter at $46 dollars
complete building project:) (Louis)
(July 8th
2015)
Thank you Louis. I appreciate your gesturein love for your Mischell. We shall let
you know. Haveyou worked with post tension foundations. Understand this is
posttension type foundation. We aretaking up with HOA & preparing paper work
Regards
Dr. Khare
GEETA Group LLC
E-mail: geetaint@loxinfo.co.th; dckhare@gmail.com
Tel: 9369007650
(July 8th
2015)
GEETA Group LLC
E-mail: geetaint@loxinfo.co.th; dckhare@gmail.com.
Tel: 9369007650
Hi Louis
Kindly find attached the draft agreement that will be required once we go ahead
of with the project. Kindly review and advisecomments, if any. Justto informyou,
18. design engineer could not complete the drawing work today. so could not go to
HOA.
Regards
Dr. Khare
Disclaimer:Thismail is just for reference and thereis no commitment till the
agreement is signed
(July 8th
2015)
Thanks
On Jul 8, 2015 9:21 PM, bluefinlch2@gmail.com wrote:
Yes.....ihave18 men crew ready juston foundation alone....any kind of
foundations.post.or beam.. plus.pier placements if needed....my framing crew is
16 men crew if needed....as i can build all 5 homes under 2 years...to almost18
MONTHS...completed.... thanks for ya warmwishes...and was niceLunch :-)
(July 9th
2015)
(I) already been doing commercial concrete at De Chavez Construction Co @
Bluejack National is a world-class privategolf club and community located in
historic Montgomery County near Houston. Comprised of 755 acres of rolling hills
and beautifully wooded countryside, Bluejack National provides the perfect
setting for a truly unique golf experience in the Texas market. as
seen http://houston.craigslist.org/sks/5073027272.html (Roads) to be exact :)
to include
http://houston.craigslist.org/sks/5053427519.html this account has custom
framing work on a large scale over 12,500 sq. ft. Home plus foundation all dry in
for $35.00 per sq. ft. as you see me in the
photo's http://houston.craigslist.org/sks/5045456672.html
19. OK my company offer to you is $46.00 dollars entireprojectincluding the same
price for all 5 homes you required built , that will secure me being free from
looking for work for a shortbit I been giving this some study,
and whatmakes wantthis is simple as I stated "Mischell", i ready for a real wife
:) :) and family again...xoxoxoxo plus all of The Lakes in the Area, and I am
consider moving to "Montgomery Texas (USA) and build my home on lake front,
as this is better then living out on 40 lot's in the middle of know where.....but
there (I) can haveplus a boat dock
as D.C.Khare...
.I am a Navy Vet actually secrete (Commander) as seen on my Google Profile
https://plus.google.com/photos/109749112725064370937/albums/59009693891
62880081
Louis Charles Hamilton a/k/a "Cmdr. Bluefin (United States Navy Seal) :) :) :)
must dash off to work, took the time to give you our Company profile.....you have
some of my construction profile and Navy Profile and my continue wishes we
doing business, I havethe entire Construction team in place, VIP and ready :)
thanks for such a sweet offer and hope we can work together (Louis) ....xoxoxoox
(I) looking forward to Retire soon with nice Future :)
(July 9th
2015)
Thank you Louis. Do you havea crew for land clearing... We have to clear land
before we can start work. You said you can organizeland clearing., though not
included in your scope. Kindly advise
(July 9th
2015)
20. Yes.....that.s easy...and iwas with my chief construction engineer and explain your
entire raw layout....and knowing wecan include land clearing.....justneeding to
put each location to. a price.....itnot a issue....and already havetrucks and
equipment in place.....as ya seeing in attached photo's .....ishall send ya pictures
from.my other cell as thid Tree cutting job was done in fact Montgomery
Texas.....this land clearing phase.....can bedone under me....again. :-)
(July 12th
2015)
D. C. Khare
for your request here is my information as follows:
1. for the especially the hard liners at the HOA and Insuranceneeds and Banking
needs (Please) use "Bustos Framing" , Alejandro Bustons" 27151Hilland Dale
Acres Spelndora Texas 77372 they ask for Charles if needed (832-344-7134)
Infiniti InsuranceServices 2129 FM2920 Rd. ste,. 220, Spring Texas 77388
#ARKGC42011 "ThePolicy"
2. For agreed contract between D.C. Khareet al and Me...... "Louis Hamilton"
mailing address is P.O. Box 17524 Sugar Land Texas 77496-7524 HomeAddress is
6403 Miners Bend Lane Richmond Texas 77469
but will discuss in person paymentand detail plan at later date in a agreed detail
construction contract
it is bestthat for 100% secured with the HOA in Montgomery Texas, and your
banking needs that I used the framing company , profile
so you face no reject or delays, as described aboveto include I have two different
construction "Hispanic primary crew" thathas no need to be involved in this
process to include our professional"Bustos Framing" company
record will with stand checks in the build industry becauseof the volume of high
dollar end homes built and good community standings......
as agreed I shallmaintaining and progress your entireconstruction project(s)
fromclearing the land to the foundation, framing, and entire full complete
21. packagefinished homes to include landscaping details within reason.... our crew
is ready, and you have the lay out of your request (Thanks) (Louis)
(July 12th
2015)
These are the latest pic from the recent Job you saw....
(July 17th
2015)
D.C. Khare, Here is pictures posting up date from the Home Project as posted
on "Craiglslist" (Louis)
http://houston.craigslist.org/sks/5126957218.html
(July 17th
2015)
Thanks Louis. I havegone California on three days holiday. Shall speak to you on
return Monday or Tuesday
Sent frommy iPhone
(July 17th
2015)
Have safetrip :-)
(July 20th
2015)
Good Morning....ihavenow work my self out of employment....Today.as my
curruentwork load ended this Sunday...which icompleted the small garage
roofing, lighting. and painting, clean up..there after already framing & concrete..in
hopes of starting as fresh off for new construction employment....this early in the
week.....wishing to hear back from you when your free...on your plans...for new
construction.....Louis.....haveno new projects...as of yet.....hoping wecan finished
your proposal...........thanks..
(July 26th
2015)
22. here is the Concrete ProjectYou visited Today Pictures Posted, (Online) justclick
the link....... :) Louis
http://houston.craigslist.org/sks/5095789619.html
(July 26th
2015)
Dear Louis
Waiting for details of your subcontractor for
Foundation
FrameWork
Sheathing & Sheetrock
Plumber
Electrical
Carpenter
Any other
We Would like name & contact details of these people. We would also like to
have your ID card detail & adress to put in contract.
As promised attach kindly find break up of drawdown ateach stage. Kindly advise
the changes in list if any.
(July 27th
2015)
here is my info.....Louis Charles Hamilton II is my legal name (SS #) is 467-35-
****, home address is 6403 Miners Bend Ct Richmond Texas 77469,
(Mailing address) is P.O. Box 17524 Sugar Land Texas 77496 832-894-9465 (Cell),
713,497-7924, and 832,344-7134
Alex- Framer- 281-467-6656
Ray-Concrete-713-539-8577
Melvin-Plumber-713-534-2368
23. Carlos -Electrical-832-707-6180
as for your proposalpaymentplan I need to look at it closer as I been studying it
with the Blueprints".. will submitmy requestchanges tonight (Louis)
thanks.............
(August 7th
2015)
Hi Louis
Kindly find attached the draft agreement that will be required once we go ahead
of with the project. Kindly review and advisecomments, if any. Justto informyou,
design engineer could not complete the drawing work today. so could not go to
HOA.
Regards
Dr. Khare
Disclaimer:Thismail is just for reference and thereis no commitment till the
agreement is signed
GEETA Group LLC
E-mail: geetaint@loxinfo.co.th; dckhare@gmail.com
Tel: 9369007650
(August 10th
2015)
D.C. Khare...thefollowing changes need to be corrected as i forward.
attachment... the first draw...is actually $1693 vs. $1000 as outline in the
contract. vs. payment plan layout you supplied herein...second the additional
$600.00 additional adjustmentyou agreed upon to cover the real diffucultcost of
hauling off on cleary this property has not been added to this
contract..$84,640,,,,which should refectactually $85,240...other wise...your
contract with the exeception as described aboved of me siging it...i am in full
agreement after said corrections.... Been made....and my sub,s contractors
24. looking for new blueprints..updates..asap..Thanks...in other news Doctor as i
explain me desire for such a contract is ..
.I havemy baby..MischellPassportcompleted in the philippines...it will released
September 15., as i am working for both her and our future...together....these
construction projectwill secureour plans....Thanks...Louis"
(August 23rd
2015)
GEETA Group LLC
E-mail: geetaint@loxinfo.co.th; dckhare@gmail.com
Tel: 9369007650
Mr Louis
We are not sureif you can clear the lot & cut the tree out professionally. In view
before we agree & permit you to clear the lot we would like to have at least three
references where you have cut the tree and cleared the lot. Kindly provide
references urgently to evaluate.
Regards
Dr. Khare
GEETA Group LLC
E-mail: geetaint@loxinfo.co.th; dckhare@gmail.co
Tel: 9369007650
(August 24th
2015)
Doc....whileyou concern about the trees...i havebeen with Energy...and
Foundation...plus Framing.....you need 70-75 yards of concrete....as for
electrical....you may be delay...by 1-2 months in having electrical installed.for this
backwayards designed project.
25. .as My Electrical having now secured a date detail today justfor the high tech
engeener from Entergy to described their plans to physically putin power on that
entire end of the lots.
...as for the trees...i not going to get into a fuss.....when your budgetof $850 for
this is not whats needed for a professional.to do the trees as you saying..plus..a
out doors toilet...plus insurances...plus...clear thelot and haul all of this away on
same $850 budget.
.when next your draw plan for foundation...cause for 70-80 yards of concreteat a
cost of $100- $120 a yard = aprox$9600 justin Concrete material alone for this
job..
.this do not countfor rebar..postwire..wooden forms...and largeLabor...crew
needed to providefull complete foundation..
,.when you have a payment plan that will not even cover the simple payment of
the concrete foundation...materials let alone the labor. ..they will not work for
free.ok...
.as for electrical...you wanted this in your duties...iagree...butyou knew...this is a
enourmus ordeal....as ispent all day. with each chief staff member
...framing..electrical...and concrete..on each of their professionaljob
locations...putting your project...to the correctcalulations needed in materials
alone
...as your plan do not even cover release of funds to effect a building of a
foundation..in a proper manner.ok.to include a dumpster as required on the Job
site justto clear the property...what...used thetrees as toilet...?
..as for the clearing of the land....call whomever....itrying to salvagea contract
designed for failure...under my name.
...which...if you did as i was saying at first..with proper budget then a dumb
$850...to effectall as described herein...heavy equipment...and man power...gas
and travel for a week..on..$859
i can have manage more personalman power...to effectall of the above..butwith
what....$850
26. ,do not even cover a weeks labor for 1 labor...letalone heavy equipment...tree
cutting ..hauling..heavy equipment.boxblade to cutt back the soil...and bobcat to
move all of this earth and Debrys...and my fee.....whats leftfor me
on...$850....ok.iwork for free....?
,,So we all agree...you need to rethink...your building project....stop holding back
on money...as my team dont work for free...and spent..many man hours today as
a favor to me to figure whatis really wrong on Nottingham Ln. ok
...realsimple...whomever designed that pay plan lost in reality of construction in
2015 ..
we do not even have cost to cover...thepermit for electrical....while...you Doc.... i
figure assumei am Nego...i dont know no better in these construction facts...?
well i enclosed ..frommoreprofessionallarger construction job site.today..my
mexican construction team photos of today jobs.being included and ...10 xthe
sizeof your simple job...
.they will not work for free...or in any formslow or stupid...ok,,,,,,neither ami.
Doc....ok...
.whomever got this twisted ...talk with them and yourself....thetrees...and lot
clearing sub it out...i do not care
...i am tired...ready to build a home...and the man power is ready too...to work for
you today...
and i broughtboth teams lunch...getting your job layed out. and secured
Enegery tech.to get every thing offically correct instead of being blind
as your missing a lot of facts...especially...i. foundation..and electrical.and starting
budget
..Louis...iwill not proceed until advised...butwill continue collect correctdata for
my interest.hopewe dont have any formal complications...tired of legal and Court
drama
you...simply.going.off...and chocking your job...being cheap...!.
27. .please dont belittle me...and my professionalteamwith your ceap budget
plan..crap..and whats needed to really clear this land in once again..being
cheap...witholding operational funds until after the fact
.and dontbelittle me and my construction team abilities to get this done....we
have everything you need...but not sufficentdeposited on starting such a small
job... Louis...and takenote...they all working currenton jobs...10xyour simple
home... Da
(August 26th
2015)
We spoken last night....as i trying to explain...what is correct...for this Job...as
required....by Law....ok....and ihaveno roomfor mistakes.., and wrong handling
of the $85,000 .Projectbudget....being with held and controled by you...(Doctor)
You paid out $850. and this was design by you to clear the land. , cutting of trees.,
haul away all of this debry.. pay labor. that do not include me being paid
...when i Louis Charles Hamilton II sign a contract which also required..i
.purchase.of a porta potty on site restroom...costfor 1stmonth $164.99...store
temporary electrical power....which iput up $500. DEPOSIT...with electrican from
the original $850. to get this electrical process started...and having now a
electrical account set up at Enegery #4320314Skew #107 and buy a $200 chain
saw...leaving $150. to continue on ward fromthe date i sign said contract...on a
operational limit of $150 ,,notwithstanding gas for transportation back and forth
fromHouston Texas to Montgomery. Texas to the physicalJob site
to include the builders Rick Insurancepolicy....$720.00 for sixmonths you wanting
on this Job site....for all in the origanaldraw of a simple $850. U.S dollars.. when
all construction contractors reciving no less then 13 down on a project that
required labor and materials which you should havehanded over...a minum of
$28,300. US dollars..
.which would cover the electrical deposit of $5500. down for theelectrican and
his crew....to installtemporary power..do under ground digging.., get account set
up with Enegery...havea tech fromEnegery install a transformer...so thejob site
alone having power as required by same contract you designed....for a simple
$850
28. when i am paying out already $500 in deposit for electrical. from your Cheap
$850.and $50 for 1 day labor.... and buy a $200 chain saw
...leaving $100.00 U.S. dollars to cut down all the required trees and hauled away
all debry with a dumpster at a normalcost..no less than $1500. US. dollars... plus
normal costof $600.00 U.S. dollars to havea box blade scrapeback all the soild
on this lot...to be ready for grading for concrete foundation. forming which you
do even not know whatthe hell a box blade is or how it even work as the date
was set for this Sunday..
.but belittle me as in now wanting 3 refferances to clear this lot...for now your
ungodly in the United States of America $850. cheap startup budget of a
remaining. Sumof $150 U.S. dollars
..to include with the sameremain $150.00 U.S.dollarscutdown all the tress. haul
away all debrys...haveinsurance...storeelectrical power...buy porta potty..and
rental of a box blade...to include pay labors to performed the task at hand. of
building a $85,000 homeon a start up.money out line of ... a crapy cheap
$850.budget..
now the electrical calling cus he has a date with engery....and dontwork for
free....as i attached his messageto which he needs deposittoday...for $5000. as i
agreed in sign contractto even haveelectrical phasestarted with the job site and
entergy...plus pullpermits....and already gave him $500 fromyour cheap
budget....theaccount number is temporary set up in builders name which is
me....#4320314 Sku #107
as you now ready to complicate matter morewith Engery in a silly inquiry ...which
you hire me to achive this...now asking why it not in your name...atEnegery.....to
include ready to belittle me more about the Risk insurancefor the Job.site being
endorsein your name.... when in fact it is being broughtfor your simple job under
builders name which once again in me....and the costof this $720. 00 U.S.
dollars...butyou only providing $850....to startthis job....which requires... @ a
whole lot more then $850 which doinot even cover the electrical staff
wages...which you metat your property working for me... nor cover
insurances...porta potty.., boxblade...cuttting trees down...hauling away all
debrys...,my labor staff weekly wages...as wellas me tbe builder having funds in
tbis same startup cheap crap of $850
29. i agreed to do this home for you and because of the sizeof your project...could
not take on any other employment...which i lost...two contracts 1. for $14,800.00
and 1.$2500.00 to accomnidate you. and now broketurning down work...to build
your home...to be free to complete it in 120 as the contract required. .buti in
delays by your cheap $850 budget....treating melike somebrokestreet trash
negro..instead of a contractor....!!!which you came to my physicaljob sites to
inspect said projects...beforeyou even decided to award me this $85,000
contract...ok. thosetwo project put up 1/3 deposit on tbe entire projects...and it
was staff with over 12 men which we completed that. two jobs in under 10 days
..Yet i give up $16,200in work orders to startbuild this home and 4 other back to
back..and on a funky startup budget which was $1680 and you reduced that to
nothing but $850.00. to do all as required as stated here in
..and i can not even have a normaloperational strating fee...or havethe electrical
staff paid proper which they alread commence work on your property....and now
you ready to have ne work brokefurther....and you Doctor forcing now your very
on cheap breach of construction contract..
to include..even piss off..theteam of builders .trying to work for you...and you
dont even respect...thatmoney needing to be released fast....withoutdelay and
hassel...and your confused complications...in whats proper to startbuilding a
home....ineed this corrected to be expidted fast.
...Enegery is soon on the way and you will have my Electrical staff quitting before i
can even have power broughtby Enegery...let alone the Box blade....porta
potty...risk insurance....dumpster to clear this site...and or dump trucks...and tree
cutting.....this messagehas been forward to my Attorney...and staff at De Chavez
Construction.for records..keeping..if wehaving problems...ipaying out of my own
pocket to continue for a week. .becauseyour cheap budget of $850 is burnt
up....too kow to even startbuild a out housetoilet.. let alone...$85,000New
Home Construction project....ok...this is almost2016 gas it at $2.35- $2.25 a
gallon...pricerange....this is not a way to manage build a new home on any
level....and
..i need to meet with you asap..liketoday..and get the proper funds to do this
job..reimburstback my $500 depositfor ekectrical.withoutbeing held back...and
at a state of being poor caused by you...being selfish., and cheap...to take on the
30. task of building this new home under contract with me... Louis Charles Hamilton
II. Doctor...you havenoteven provided me with a copy of rhe contract and all
documents you had me signed at the contact signing day...a week ago....ok....and
you question me....?
(August 26th
2015)
Gregory Miller <greg_miller_realtor@outlook.com>
Aug
26
to me
Hi Louis,
To make surewe move as fast as possibleand payment be made on time, could
you send paymentschedules as soon as convenient? Dr Kharewants it to be
reviewed.
Also, Dr Khare was taking care of methods of payment and perhaps looking to
open up a chaseliquid card.
If need any help or have any questions let me know available anytime.
Sincerely,
Greg
Ps: sorry aboutthis, is your name louis or Lewis ?
Sent from my iPhone
(August 26th
2015)
31. Louis Hamilton <bluefinlch2@gmail.com>
Aug
26
to Gregory
Louis..and thanks...itbedone asap.....could notcash that check...his bank been
closed...itin New Jersey...timeZone...pks. adviseDoc heneed to clear this in
moring when i try again......also...theporta potty....need to be finished which they
have night servicefor this....ireally dont care who.namego.on a toilet
contract...ok...wejustneeds this done....asap....
(10)
Pro Se Plaintiff “Louis Charles HamiltonII” hereinfurtherance’s“Declare”,
“State”, and “Affirm”before the “Honorable U.S. Justice” for Pro Se Plaintiff
hereinon (Personal) behalf and on the behalf of Co-Plaintiff(s) “UnitedStates of
America”et al and Co-Plaintiff(s) “State of Texas”et al
Not Just any “Interstate wirecommunication”via the “Internet” was
being usedon July 8th
, 9th
, 12th
, 17th
, 26th
, and August 7th
and 23rd
in the year
2015 inthat
Chief Defendant “Doctor DineshChandraKhare”, hereinwas providing
“among other things”ProSe Plaintiff “Louis Charles HamiltonII”Construction
business details, personal informationandU.S. Citizenship“Social security
number” and signature inthis International (RICO) Wire FraudScheme of Things
in direct concert, collusionwithCo-Defendant(s) GEETA GroupLLC. Business
listedat 1600 River Pointe Dr. Apt. 812, Conroe, Texas 77304 via
“International Wire Services”toCo-Defendant(s) “GEETA International
Group ” Namely Co-Defendant(s) “GeetaInternational et al”and Co-
Defendant(s) “GeetaInternational Legal Division”et al, “GeetaInternational
Co. Ltd.”, from the (IP) email address listedoneachemail sent toPro Se Plaintiff
32. hereinas describedinparagraph (9) belowclearly showing Co-Defendant(s)
GEETA Group LLC.
(IP) * E-mail: geetaint@loxinfo.co.th; address listedin“Thailand”while
physically Co-Defendant(s) GEETA GroupLLC. Business is listedas 1600 River
Pointe Dr. Apt. 812, Conroe, Texas 77304 withinthe Jurisdictionof Co-Plaintiff(s)
“State of Texas”
(12)
Pro Se Plaintiff “Louis Charles HamiltonII” hereinfurtherance’s“Declare”,
“State”, and “Affirm”before the “Honorable U.S. Justice” for Pro Se Plaintiff
hereinon (Personal) behalf and on the behalf of Co-Plaintiff(s) “UnitedStates of
America”et al and Co-Plaintiff(s) “State of Texas”et al
In that Chief Defendant “Doctor DineshChandraKhare”, hereinonJuly
8th
, 9th
, 12th
, 17th
, 26th
, and August 7th
and 23rd
in the year 2015
1. Did infacts and legal terms refer tohimself as “Regards Dr. Khare” on
July 8th
, 9th
, 12th
, 17th
, 26th
, and August 7th
and 23rd
in the year 2015
2. Did infacts and legal terms refer to“We”as a group when sending all
terms and conditions of the ConstructionContract inall “International
wire communication”and “interstate wire communications” as
describedinparagraph(9) above clearly showing
3. Co-Defendant(s) GEETA GroupLLC Business addresslistedas 1600
River Pointe Dr. Apt. 812,Conroe, Texas 77304as describedby the
Secretary for the “State of Texas”
4. “GEETA GROUP LLC, FILE DATE 06/12/2015, FILING TYPE
“CORPORATE”, REGISTRATED AGENT“VIPUL KHARE” 1600 RIVER
POINTEDR. APT 812, CONROE, TEXAS 77304, MONTGOMERYCOUNTY.
5. Texas Business Registrationrecord“GEETA GroupLLC” Business
address listedas 1600 River Pointe Dr. Apt. 812,Conroe, Texas 77304
as 1 of 5 Business listedas 1600 RiverPointe Dr. Apt. 812,Conroe,
Texas 77304
33. 6. Co-Defendant(s) GEETA GroupLLC locatedat 1600 River Pointe Dr. Apt.
812,Conroe, Texas 77304 andCo-Defendant(s) “GeetaInternational et
al” locatedat 94/10 Phet Kasem3 Soi 2, Bang Khae Nuea, Bang Khae,
Bangkok 10160, Thailandbothhaving the same “International Email
address namely geetaint@loxinfo.co.th;
(13)
Pro Se Plaintiff Louis Charles HamiltonII herein“Declare”, State, and
Affirmbefore the “Honorable U.S. Justice” ProSe Plaintiff on his (Personal)
behalf and on the behalf of Co-Plaintiff(s) “UnitedStates of America”et al and
Co-Plaintiff(s) “State of Texas”et al states, declare andAffirm
In that Chief Defendant “Doctor DineshChandraKhare”, hereinonthe
exact dates of February 22nd
2008 petitionfor and receivedaDMVCalifornia
Driver License #E2336392, having already inplacement asaving and checking
Banking account with“Citibank”San FranciscoBay area Branchwithhome
address (Identified) as 616 Bourne Ct. Danville California94506
(14)
Pro Se Plaintiff, Louis Charles HamiltonII Co-Plaintiff(s) United States of
America”et al and Co-Plaintiff “State of Texas”et al herein“Declare”, State, and
Affirmbefore the “Honorable U.S. Justice”that on or about in the year of 1995
Co-Defendant(s) GeetaInternational et al andCo-Defendant(s) “Geeta
International “Legal Division”et al”was incorporated.
“Geeta”and “International Businessgroupbasedin“Thailand and
Focusedon the retail and consumer packagedgoods segment covering
“Thailand”, Co-Plaintiff(s) “UnitedStates of America”and“India”.
Withcorporate matters listing as describedinparagraph(14) below
(15)
Corporate Matters
34. GEETA brandedWholesale DistributionandInternational Trading
2194/48-49 Bang Koh Laem,
Bangkok - 10120 Thailand
Tel: (+662) 291-1968
Fax: (+662) 688-1146
Email: contact@geetaint.com
GeetaFoods - California, USA Satellite Office
Danville, CA 94506
Tel: +1-925-282-3482
Fax: +1-682-292-2887
Email: info-feedback@geetaint.com
GeetaFoods - NewYork, USA SatelliteOffice
Jackson Heights, NY
Tel: +1-917-573-1923
Fax: +1-413-581-7495
Email: info@geetaint.com
Retail Supermarkets
Value Mart Co Ltd.
Soi 20 Central Sukhumvit
Bangkok, Thailand
Tel: (+662) 261-5955
Fax: (+662) 261-5859
Email: info@geetaint.com
Restaurants:
Soi 12, SukhumvitRoad,
Bangkok, Thailand
Tel: (+662) 653-1171
Tel: (+662) 653-1173
Fax: (+662) 663-3721
Email: info@geetaint.com
Home Delivery:
Tel: (+662) 291-1968
Email: info@geetaint.com
35. (16)
Pro Se Plaintiff, “Louis Charles HamiltonII”, Co-Plaintiff(s) UnitedStates
of America”et al, and Co-Plaintiff “State of Texas”et al, herein“Declare”, State,
and Affirmbefore the “Honorable U.S. Justice”
In that Chief Defendant “Doctor DineshChandraKhare”, hereinht. 5ft. 5”
wt. 160 (Lbs) eyes (Black) borninthe 1940’s January 31st
as so claimedwith
DMVfor State of Californiawiththe usage of the “Title” Dr. Khare
Did inall factual circumstance andevents withinthe Co-Plaintiff(s)
“UnitedStates of America”Jurisdiction, Chief Defendant “Doctor Dinesh
Chandra Khare”, PurchasedLot 6621 know tobe (616) Bourne Ct. Danville CA.
94506 andin 1998 built 3460 sq. ft. NewConstructionsingle family home having
4 bedrooms and 3 bathrooms which was last soldfor $1,075,000.00
(17)
Pro Se Plaintiff, “Louis Charles Hamilton II”, Co-Plaintiff(s) UnitedStates
of America”et al, and Co-Plaintiff “State of Texas”et al, herein“Declare”, State,
and Affirmbefore the “Honorable U.S. Justice”
In that Chief Defendant “Doctor DineshChandraKhare”, on the exact
date of “August 22nd
2015 issuedaPersonal check toPro se Plaintiff “Louis
Charles HamiltonII” hereininthe Amount in excess of $1,350.00 U.S. Dollars
and in the present of the “Citibank” inMontgomery County Conroe Texas
Branch
Chief Defendant “Doctor DineshChandraKhare”, further withdrewvia
live banking (Teller) (ATM) account withdrawal inthe amount inexcess of
$500.00 U.S. Dollars making first install payment toProSe Plaintiff for New
Constructionas agreedupon in signcontract as detail in Co-Defendant(s) Geeta
Group LLC (Agreement) withChief Defendant “Doctor DineshChandraKhare”,
fully the front man.
(18)
Pro Se Plaintiff, “Louis Charles HamiltonII”, Co-Plaintiff(s) UnitedStates of
America”et al, and Co-Plaintiff “State of Texas”et al, herein“Declare”, State,
36. and Affirmbefore the “Honorable U.S. Justice”the Check was process at PLS
Check Cashers 5823 Gulf Freeway HoustonTexas 77023viatheir “Wire Services”
on behalf of the Pro Se Plaintiff “Louis Charles HamiltonII herein
Pro Se Plaintiff, “Louis Charles HamiltonII”, “Declare”, State, andAffirm
before the “Honorable U.S. Justice”under any circumstances would Chief
Defendant “Doctor DineshChandraKhare”, hereinallow PLS Check Cashers
5823 Gulf Freeway HoustonTexas 77023 viatheir “Wire Services”tocashsuch
Chief Defendant “Doctor DineshChandraKhare”, personal check which PLS
Check Cashers first rancheck through their electronic checking devise,
Secondly “PLS Check Cashers”called “Citibank”inthe presence of the Pro
Se Plaintiff “Louis Charles HamiltonII” hereintoverify Chief Defendant “Doctor
DineshChandra Khare”, hereinfully having sucha “Live”account with
“Citibank”as this was verifiedtobe true
“However” “PLS Check Cashers”needed Chief Defendant “Doctor Dinesh
Chandra Khare”, to verify his last (4) digits of his social security number viathe
“PLS Check Cashers”phone line in order to further proceeding incashing said
check drawn in the amount of $1, 350.00 U.S. Dollars.
(19)
Pro Se Plaintiff, “Louis Charles HamiltonII”, Co-Plaintiff(s) UnitedStates of
America”et al, and Co-Plaintiff “State of Texas”et al, herein“Declare”, State,
and Affirmbefore the “Honorable U.S. Justice”the Check of Chief Defendant
“Doctor DineshChandra Khare”, that was (legally) process at PLS Check Cashers
5823 Gulf Freeway HoustonTexas 77023 viatheir “Wire Services”onbehalf of
the Pro Se Plaintiff “Louis Charles HamiltonII herein
a. Said Personal check of Chief Defendant “Doctor DineshChandra
Khare”, hereinissuedfrom“Citibank”was Drawn on the exact
same address of (616) Bourne Ct. Danville CA. 94506 toahome
which was sold on January 2006 for $1,075,000.00 but saidcheck
for “Constructionservices”was made out on August 22nd
2015..
To ProSe Plaintiff “Louis Charles HamiltonII…herein..?
b. Said check was made out from a sold resident said Chief
Defendant “Doctor DineshChandraKhare”, herein“assuming”
having no (legal) control over in2015… since saidproperty
37. namely “Material facts”supporting that (616) Bourne Ct.
Danville CA. 94506 was soldinJanuary 2006 for $1,075,000.00
c. The exact address of (616) Bourne Ct. Danville CA. 94506 is listed
on Chief Defendant “Doctor DineshChandra Khare”, hereinDMV
CaliforniaDriver License #E2336392,
d. Co-Defendant(s) GeetaInternational et al andCo-Defendant(s)
GeetaInternational “Legal Division”et al collectively having
placement of GeetaFoods - California, USA (Secrete) Satellite
Office located in namely “Danville, CA 94506” Tel: +1-925-282-
3482 Fax: +1-682-292-2887 Email: info feedback@geetaint.com
e. ” Tel: +1-925-282-3482 is a none working number while being
currently advertised on the internet as Co-Defendant(s) Geeta
Foods - California, USA SatelliteOffice.
f. In January 2006 for $1,075,000.00 Chief Defendant “Doctor
DineshChandra Khare”, hereinDMVCaliforniaDriver License
#E2336392 having inexcess of $1,075,000.00U.S. Dollars in
“Citibank”under account for the address of (616) Bourne Ct.
Danville CA. 94506 whichChief Defendant “Doctor Dinesh
Chandra Khare” continue writing checks drawntosaid sold
property locatedat (616) Bourne Ct. Danville CA. 94506 in(2015)
g. DMVCaliforniaDriver License #E2336392 filedas ProSe Plaintiff,
“Louis Charles HamiltonII”, Co-Plaintiff(s) UnitedStatesof
America”et al, and Co-Plaintiff “State of Texas”et al, herein
exhibit (A) insupport of this complaint made hereinshowing
address (616) Bourne Ct. Danville CA. 94506whichChief
Defendant “Doctor DineshChandraKhare” continue writing
checks drawn tosaid “soldproperty”locatedat (616) Bourne Ct.
Danville CA. 94506 in(2015)..?
(20)
Pro Se Plaintiff, “Louis Charles HamiltonII”, Co-Plaintiff(s) UnitedStates
of America”et al, and Co-Plaintiff “State of Texas”et al, herein“Declare”, State,
and Affirmbefore the “Honorable U.S. Justice”
In that Chief Defendant “Doctor DineshChandraKhare”, hereinht. 5ft. 5”
wt. 160 (Lbs) eyes (Black) borninthe 1940’s January 31st
as so claimedwith
DMVfor State of Californiawiththe usage of the “Title” Dr. Khare
38. Did inall factual circumstance andevents withinthe Co-Plaintiff(s)
“UnitedStates of America”Jurisdiction, Chief Defendant “Doctor Dinesh
Chandra Khare”, in the same patternand practice describedinparagraph(17,18,
and 19) above purchasedonce again Real estate Properties inthe “NewJersey”-
Hopewell “Township”know to be properties Namely 156 CoburnRoad
Pennington, NJ08534
(21)
Pro Se Plaintiff, “Louis Charles HamiltonII”, Co-Plaintiff(s) UnitedStates
of America”et al, and Co-Plaintiff “State of Texas”et al, herein“Declare”, State,
and Affirmbefore the “Honorable U.S. Justice”
In that Chief Defendant “Doctor DineshChandraKhare”, on the exact
date of “August 26th
2015 issuedanother Personal check drawnonCitibank
N.A. BR # 128 37-57 74th
Street JacksonHeights, NewYork 11372 account #
021000098:9947509687:0121
To Prose Plaintiff “Louis Charles HamiltonII” hereininthis time in the
amount of the Amount of $1,220.00U.S. Dollars:
a. Chief Defendant “Doctor DineshChandraKhare”, hereinfurther
providedsaidcheck datedAug 26th
2015 fromthe Newaddress 156
Coburn Road Pennington, NJ08534 drawnonce again from “Citibank”
b. the secondCheck of Chief Defendant “Doctor DineshChandraKhare”,
hereinwritten for $1,220.00 U.S. Dollars was once again process at PLS
Check Cashers 5823 Gulf Freeway HoustonTexas 77023viatheir “Wire
Services”onbehalf of the Pro Se Plaintiff “Louis Charles HamiltonII
herein
c. “However”this time on27th
of August 2015 inthe am hour PLS Check
Cashers at 5823 Gulf Freeway HoustonTexas 77023 toldProSe
Plaintiff “Louis Charles Hamilton”hereinafterPLS Check Cashers first
ran secondcheck through their electronic checking devise, that their
district manger statedthey wouldnot be cashing said secondCheck of
Chief Defendant “Doctor DineshChandraKhare”, hereinwritten for
$1,220.00U.S. Dollars
d. the Newaddress locatedat 156 Coburn Road Pennington, NJ08534
under direct ownershipof Chief Defendant “Doctor DineshChandra
39. Khare”, hereinandon April 19th
, 2013 “Doctor DineshChandraKhare”,
hereinfully once again soldsaid property 156 CoburnRoad
Pennington, NJ08534 this time for $365,000.00U.S. Dollars as
describedinthe Personal Check filedas Pro Se Plaintiff, “Louis Charles
HamiltonII”, Co-Plaintiff(s) UnitedStatesof America”et al, and Co-
Plaintiff “State of Texas” et al, hereinexhibit (B) insupport of this
complaint made herein
e. Said Personal check of Chief Defendant “Doctor DineshChandra
Khare”, hereinissuedfrom“Citibank”was Drawn on the exact same
address of 156 CoburnRoad Pennington, NJ08534 toa home which
was soldon “April 19th
, 2013 for $365,000.00 U.S. Dollars “However”
but saidcheck for “Constructionservices”was made out on August
22th
2015.. To Pro Se Plaintiff “Louis Charles HamiltonII…herein..?
f. Said check was made out from a sold resident said Chief Defendant
“Doctor DineshChandra Khare”, herein“assuming”having no (legal)
control over (once) again in 2015… since saidproperty namely
“Material facts”supporting that “April 19th
, 2013 156 CoburnRoad
Pennington, NJ08534 for $365,000.00 U.S. Dollars
g. Co-Defendant(s) GeetaInternational et al andCo-Defendant(s) Geeta
International “Legal Division”et al collectively having placement of
GeetaFoods - NewYork, USA SatelliteOffice Jackson Heights, NYTel:
+1-917-573-1923 Fax: +1-413-581-7495Email: info@geetaint.com
h. Jackson Heights, NY
i. Co-Defendant(s) GeetaInternational et al and Co-Defendant(s) Geeta
International “Legal Division”et al “GeetaFoods - NewYork, USA
Satellite Officeis in the same Location City) for Citibank N.A. BR # 128
37-57 74th
Street JacksonHeights, NewYork 11372account #
021000098:9947509687:0121 which Chief Defendant “Doctor Dinesh
Chandra Khare”, providedsaidcheck dated Aug 26th
2015 fromthe
Newaddress 156 CoburnRoad Pennington, NJ08534 drawnonce again
from “Citibank”from a soldresident said Chief Defendant “Doctor
DineshChandra Khare”, herein“assuming”having no (legal) control
over (once) again in 2015… since saidproperty namely “Material facts”
supporting that “April 19th
, 2013 156 CoburnRoadPennington, NJ
08534 Property was soldfor $365,000.00 U.S. Dollars whichsaid Chief
Defendant “Doctor DineshChandraKhare”, hereinin2015 once again
writtencheck froma Property sold…..?
40. (22)
Pro Se Plaintiff Louis Charles HamiltonII hereinfurtherance’s “Declare”,
State, and Affirmbefore the “Honorable U.S. Justice” ProSe Plaintiff on his
(Personal) behalf and on the behalf of Co-Plaintiff(s) “UnitedStatesof America”
et al and Co-Plaintiff(s) “State of Texas”et al states, declare andAffirm
That all factual circumstances andextreme sound“logical circumstance”
and events adding (Pro Se Plaintiff) personal dealing withChief Defendant
“Doctor DineshChandra Khare”, hereininthat
Chief Defendant “Doctor DineshChandraKhare”, (whom) actually
whomever he maybe hereinis “actually physically”one in the same “Gaeta
International et al” a International (RICO) EnterpriseCartel based in Bangkok ,
Thailand
(23)
Pro Se Plaintiff Louis Charles HamiltonII hereinfurtherance’s “Declare”,
State, and Affirmbefore the “Honorable U.S. Justice” ProSe Plaintiff on his
(Personal) behalf and on the behalf of
Co-Plaintiff(s) “UnitedStatesof America”et al and Co-Plaintiff(s) “State of
Texas”et al states, declare andaffirms that
Co-Defendant(s) GEETA GroupLLC (Email) address namely
geetaint@loxinfo.co.th; is the direct email Link to a International (RICO)
Enterprise Cartelbased in Bangkok , Thailand
In comparison to:
GEETA brandedWholesale DistributionandInternational Trading
2194/48-49 Bang Koh Laem, Bangkok - 10120 Thailand Tel : (+662) 291-1968Fax:
(+662) 688-1146Email: listed as: contact@geetaint.com
Retail SupermarketsValueMart Co Ltd. Soi 20 Central SukhumvitBangkok ,
Thailand Tel: (+662) 261-5955 Fax: (+662) 261-5859 Email: Listed as:
info@geetaint.com
41. Restaurants: Soi12, SukhumvitRoad, Bangkok , Thailand Tel: (+662) 653-
1171 Tel: (+662) 653-1173Fax:(+662) 663-3721Email: Listed as:
info@geetaint.com
(24)
Pro Se Plaintiff Louis Charles HamiltonII hereinfurtherance’s “Declare”,
State, and Affirmbefore the “Honorable U.S. Justice” ProSe Plaintiff on his
(Personal) behalf and on the behalf of Co-Plaintiff(s) “UnitedStatesof America”
et al and Co-Plaintiff(s) “State of Texas”et al states, declare andAffirmthat
Chief Defendant “Doctor DineshChandraKhare”, having beenfurtherance said
Specifically, “International RICO Racket” toDefraud“UnitedStates of
America”as a Whole”in Violationof 18 U.S.C. § 371 §371 withall (Defendant(s)
and Co-Defendant(s) collectively committedto“Conspiracy tocommit offense
or to defraudUnitedStates”
Specifically, violationsof “18 USC § 1343 RICO Wire Fraud”, and
Specifically, violationsof RICO statute (18 U.S.C. § 1961(1) “Money
laundering”
Specifically, violationsof RICO statue “18 USC § 1341 “Mail Fraud”,
To (Now) added that Chief Defendant “Doctor DineshChandra Khare”,
Co-Defendant(s) GeetaInternational et al andCo-Defendant(s) “Geeta
International “Legal Division”et al” Co-Defendant(s) “GeetaInternational Co.
Ltd.”, Co-Defendant(s) GeetaGroupLLC and Co-Defendant(s) Vipul Khare herein
engaging fully in collusion, concert andconspirer against Co-Plaintiff “United
States of America”et al Title III: International Money Laundering Abatement
and Financial Anti-TerrorismAct of 2001.
(25)
Pro Se Plaintiff Louis Charles HamiltonII hereinfurtherance’s “Declare”,
State, and Affirmbefore the “Honorable U.S. Justice” for Pro Se Plaintiff on his
42. (Personal) behalf and on the behalf of Co-Plaintiff(s) “UnitedStatesof America”
et al and Co-Plaintiff(s) “State of Texas”et al
States, Declare andAffirmthat Co-Defendant(s) GeetaInternational et al
and Co-Defendant(s) “GeetaInternational “Legal Division”et al” GeetaFoods -
California, USA Satellite Office andGeetaFoods - NewYork, USA SatelliteOffice
GeetaFoods - California, USA Satellite Office
Danville, CA 94506
Tel: +1-925-282-3482
Fax: +1-682-292-2887
Email: info-feedback@geetaint.com
GeetaFoods - NewYork, USA SatelliteOffice
Jackson Heights, NY
Tel: +1-917-573-1923
Fax: +1-413-581-7495
Email: info@geetaint.com
Having been(Physically) usedinpast, present to“facilitateand
formulated”withinCo-Plaintiff “UnitedStates of America”et al Jurisdictionsaid
“International RICO EnterpriseRacket”engaging in“among other things”
“Mutable Counts”of interstate“Mail andWire Fraud”, and “International Mail
and Wire Fraud”,
International Money Laundering, scheme of things tooperate collectively
as a (secret) “EnterpriseRacket”withinthe Co-Plaintiff “UnitedStatesof
America”Jurisdictionviainadditiona (RICO) scheme of things through
“Satellite Transmission”
(26)
Pro Se Plaintiff Louis Charles HamiltonII hereinfurtherance’s “Declare”,
State, and Affirmbefore the “Honorable U.S. Justice” for Pro Se Plaintiff on his
(Personal) behalf and on the behalf of
43. Co-Plaintiff(s) “UnitedStatesof America”et al and Co-Plaintiff(s) “State of
Texas”et al in that Chief Defendant “Doctor DineshChandraKhare” hereinon
the exact time frame of July 17th
as describedinparagraph(9) above:
(July 17th
2015)
Thanks Louis. I havegone California on three days holiday. Shall speak to you on
return Monday or Tuesday
Sent frommy iPhone
(July 17th
2015)
Have safetrip :-)
Chief Defendant “Doctor DineshChandra Khare”hereinfully engage in
same continuance (RICO) “scheme of things throughtoinclude “Satellite
Transmission”withinthe Co-Plaintiff(s) Jurisdictionwithinthe State of
Californiaat Co-Defendant(s) GeetaInternational et al andCo-Defendant(s)
“GeetaInternational “Legal Division”et al”undisclosed“Satellite Transmission”
location.
(27)
(July 17th
2015)
Thanks Louis. I havegone California on three days holiday. Shall speak to you on
return Monday or Tuesday
Sent frommy iPhone
(July 17th
2015)
Have safetrip :-)
(28)
44. Pro Se Plaintiff “Louis Charles HamiltonII” hereinfurther “Declare”,
“State”, and “Affirm”before the “Honorable U.S. Justice”for his own personal
behalf as follows:
a. Chief Defendant “Doctor DineshChandra Khare” hereinlegally with
property holdings at 156 CoburnRoad Pennington, NJ08534, 616 BourneCt
Danville CA 94506, 3429 NottinghamLninMontgomery, Texas 77356 andthe
fourthproperty alsolocatedin Montgomery, Texas ina private gated
community on a golf course on a (Nice) Lake in which Chief Defendant “Doctor
DineshChandra Khare” didin fact took ProSe Plaintiff to, (2) properties onthe
exact date of “July 7th
2015 12:00 (Noon) amhour namely
3429 NottinghamLninMontgomery, Texas 77356 and*Photos on file
withChief Defendant “Doctor DineshChandra Khare present onproperty
located in Montgomery, Texas ina private gatedcommunity on a golf course on
a (Nice) Lake in saidphotos.
(29)
As one suchproperty namely 3429 NottinghamLninMontgomery, Texas
77356 already under contract signedby the ProSe Plaintiff “Louis Charles
HamiltonII” on the exact time frame of 12:10 am hour at “The HiltonHotel”
locatedat 12400 Greens point Dr. HoustonTexas 77060
On the 22nd
day of August 2015 (all) being physically conductedon “video
surveillance”of the “HiltonHotel”as well as on photos on file withthe Pro Se
Plaintiff hereinandChief Defendant “Doctor DineshChandra Khare”, in said
photos
To include Chief Defendant “Doctor DineshChandraKhare”, on the
exact time frame of 12:10 am hour CaliforniaDriver License #E2336392 Expire
01-31-2018home address at 616 Bourne Ct Danville CA 94506 was (Photocopy)
and Phone Message wire Communication(IM) acopy to saidChief Defendant
“Doctor DineshChandra Khare”, himself at the exact time frame of 12:10 am
witha photoattachedof the ProSe Plaintiff Louis Charles HamiltonII”herein
U.S. veteranphotoI.D.
45. b. Chief Defendant “Doctor DineshChandra Khare”, first stepcommitted
to “Medical Battery”tosubmitting ProSe Plaintiff Louis Charles HamiltonII
hereintoa unwanted secretly “Forensic Mental Evaluation” over aperiodof
several claimbusiness meeting dinners inMontgomery Texas startfirst
occurredon the exact date of “July 7th
2015
After the enhancement barging planof showing off the Nice (2) properties
as describedinparagraph28(a) above Chief Defendant “Doctor DineshChandra
Khare”, hereinwiththe false, fraudulent pretenses, representations of material
facts that there are indeed(3) other properties locatedinMontgomery Texas
for a total of (5) being a party tothis Business dealings on“July 7th
2015 whicha
constructionbusinessnegations didinfact assumedat a India Restaurant in
Montgomery Texas whichthe Chief Defendant “Doctor DineshChandraKhare”,
hereinfurther with
“Intent”false, fraudulent pretenses, representations of material facts
statedof having a Builder submitting abid of $56 per sq. ft. for complete
constructionplanon all (5) properties locatedin Montgomery Texas for a total
cost of $103,1523429 being the unidentifiedContractor bidfor start upNew
Constructionon3429 NottinghamLninMontgomery, Texas 77356
c. Chief Defendant “Doctor DineshChandraKhare” hereinlegally never
made any “formal discussionor notice or legal rebuttal”of material facts
concerning the ProSe Plaintiff Louis Charles HamiltonII hereinand all acting
subs-contractors as being described
Alex- Framer- 281-467-6656
Ray-Concrete-713-539-8577
Melvin-Plumber-713-534-2368
Carlos -Electrical-832-707-6180
being not involvedinthe Constructionof (5) propertieslocatedin
Montgomery Texas whichall said Sub Contractor lower there combine labor
cost to accommodate Defendant and Co-Defendant(s) collectively
46. (30)
Pro Se Plaintiff further Assert, declareandaffirmbefore the “Honorable
Justice”Chief Defendant “Doctor DineshChandraKhare” and Co-Defendant(s)
GeetaGroupLLC et al, hereinlegally was fully aware, with intent knowledge to
engage in deceiving , trickery, directedat ProSe Plaintiff “Louis Charles
HamiltonII” construction negations base on$46. Per sq. ft. (RICO) price fixing
scheme of things for total constructionof
(5) properties withafuture cost inexcess of $425,000.00 U.S. Dollars
under the fully false, fraudulent pretenses, representations of “material facts”
that there are indeed(5) properties locatedin Montgomery Texas andready for
“New Home Construction”whichinfact was false, and Materially bogus,
Pro Se Plaintiff showsuch Chief Defendant “Doctor DineshChandra
Khare” Co-Defendant(s) GeetaGroupLLC et al, hereinlegally was fully aware,
withintent knowledge todeceive, trickery, as described transmits or causes to
be transmittedby means of phone communications, including
“Internet wire”(emails) andPhone Message wire Communication(IM)
and “Satellite Transmission” withCo-Defendant(s) TrillionaireAssetset al, Co-
Defendant(s) Trillionaire Realty et al, Co-Defendant(s) andCo-Defendant(s) Greg
Miller fully conspire involvedintent knowledge todeceive, trickery, andcausing
his Personal added
“Deceptive Trade Practices Acts, Broughtinconjunctionwith“Common
law” Fraud and Breachof Contract, and “Tortious InterferencewithExisting
Contract”,
(31)
Pro Se Plaintiff Louis Charles HamiltonII herein furtherance’s “Declare”,
State, and Affirmbefore the “Honorable U.S. Justice” for Pro Se Plaintiff “Louis
Charles HamiltonII” herein onhis (Personal) behalf and on the behalf of
47. Co-Plaintiff(s) “UnitedStatesof America” et al and Co-Plaintiff(s) “State of
Texas”et al in that Chief Defendant “Doctor DineshChandraKhare” hereinon
the exact time frame of the Monthof “June”, “July” and “August”of 2015
Chief Defendant “Doctor DineshChandraKhare”, Co-Defendant(s) Geeta
International et al and Co-Defendant(s) “GeetaInternational “Legal Division”et
al”, Co-Defendant(s) “GeetaInternational Co. Ltd.”, Co-Defendant(s) Geeta
Group LLC, and Co-Defendant(s) Vipul Khare hereinengaging fully incollusion,
concert and conspirer
Subjecting the ProSe Plaintiff “Louis Charles HamiltonII” a naturalized
citizenof “UnitedStates of America”and many, many, others similarly same
qualify under “Constitute Citizenship”guaranteedprotectionof the judicial
branch of the
Co-Plaintiff(s) “UntiedStatesof America” et al “judicial branch” of
government and the Pro Se Plaintiff “Louis Charles HamiltonII” a naturalized
citizenof “UnitedStates of America”and many, many, others similarly same
qualify under “Constitute Citizenshipguaranteedprotectionof Co-Plaintiff(s)
“State of Texas”et al Judicial branchof government
Which ProSe Plaintiff “Louis Charles HamiltonII” being a (USN) Veteran
should100% add such qualify “Constitute Citizenshipguaranteedprotectionof
the judicial branch of the Co-Plaintiff(s) “UntiedStates of America”et al Judicial
Government and the Co-Plaintiff(s) “State of Texas”et al Judicial Branch of
Government
(32)
The Pro Se Plaintiff “Louis Charles HamiltonII” a naturalizedcitizenof
“UnitedStates of America”and many, many, others similarly same qualify
under “Constitute Citizenshipguaranteedprotectionof the “Judicial Branches”
of The Co-Plaintiff(s) “UnitedStatesof America”et al and the Co-Plaintiff(s)
“State of Texas”et al
48. However Chief Defendant “Doctor DineshChandra Khare”, Co-
Defendant(s) GeetaInternational et al and Co-Defendant(s) “Geeta
International “Legal Division”et al”, “Co-Defendant(s) GeetaInternational Co.
Ltd.”, Co-Defendant(s) GeetaGroupLLC and Co-Defendant(s) Vipul Khare herein
Engaging further fully incollusion, concert andconspirer against The Pro
Se Plaintiff “Louis Charles HamiltonII” a naturalizedcitizenof “UnitedStates of
America”and many, many, others similarly same qualify under
“Constitute Citizenshipguaranteedprotectionof the “Judicial Branches”
of The Co-Plaintiff(s) “UnitedStatesof America”et al and the Co-Plaintiff(s)
“State of Texas”et al in that
Chief Defendant “Doctor DineshChandraKhare”, Co-Defendant(s) Geeta
International et al and Co-Defendant(s) “GeetaInternational “Legal Division”et
al”, Co-Defendant(s) “GeetaInternational Co. Ltd.”, Co-Defendant(s) Geeta
Group LLC, and Co-Defendant(s) Vipul Khare herein deniedDue process of the
law and equal protectionof the law of The Co-Plaintiff(s) “UnitedStatesof
America”et al and the Co-Plaintiff(s) “State of Texas”et al in this
“International RICO Cartel Enterprise Racket” of “Deceptive Trade
Practices Acts, anddidin all factual circumstances obtain, concealedand
destroyeda“ConstructionContract”of the Pro Se Plaintiff “Louis Charles
HamiltonII hereinwithinthe
“International Jurisdiction”of Chief Defendant “Doctor DineshChandra
Khare”, Co-Defendant(s) GeetaInternational et al and Co-Defendant(s) “Geeta
International “Legal Division”et al”, Co-Defendant(s) “GeetaInternational Co.
Ltd.”, Co-Defendant(s) GeetaGroupLLC, and Co-Defendant(s) Vipul Khare
herein Namely “Thailand” fully deniedProSe Plaintiff “Due process andEqual
Protectionof The Co-Plaintiff(s) “UnitedStates of America”et al and the Co-
Plaintiff(s) “State of Texas”et al Constitutional rightsover said
Pro Se Plaintiff “Louis Charles HamiltonII” a naturalizedcitizenof “United
States of America”and many, many, others similarly same qualify under
“Constitute Citizenshipguaranteedprotectionof the “Judicial Branches”of The
49. Co-Plaintiff(s) “UnitedStatesof America”et al and the Co-Plaintiff(s) “State of
Texas”et al having business dealing withthis
“International RICO Cartel Enterprise Racket”describedfully herein
having already beeninstitutedandfully commenced inthe “State of California”
The State of Texas, “The State of NewYork” and (Now) upon informationand
strong belief, Co-Defendant(s) “GeetaInternational, Co-Defendant(s) “Geeta
International “Legal Division”et al”, Co-Defendant(s) GeetaGroupLLC also
knows tobe “GEETA International Co. Ltd.” , Co-Defendant Vipul Khare And
Chief Defendant “Doctor DineshChandraKhare”,
Operating in(RICO) same “patternand practice”scheme of things for
sometime inthe “prime real-estatearea”of “Bogota Florida”whichSecretary
for the “State of Florida”records indicating showing “GEETA International Co.
Ltd.” Having so physically operating for a time in Co-Plaintiff “UnitedStates of
America“Jurisdictionnamely the “State of Florida”operating under the “Title”
“GEETA International Co. Ltd.”
As describedinparagraph (33) below Chief Defendant “Doctor Dinesh
Chandra Khare”, “GEETA International Co. Ltd.” “Managing Director”, location
“Bangkok Metropolitanarea, Thailand, “Industry “Food and Beverages” with
Co-Defendant(s) GeetaInternational et al “Logo”making “GEETA International
Co. Ltd.” AlsoCo-Defendant(s) anda official party to this “International RICO
Cartel EnterpriseRacket” against ProSe Plaintiff Louis Charles HamiltonII, Co-
Plaintiff(s) “UnitedStates of America”et al and Co-Plaintiff(s) “State of Texas”
et al herein.
(33)
50. Dr. D.C. Khare
Managing Director
Location
Bangkok Metropolitan Area, Thailand
Industry
Food & Beverages
Current
Websites
(34)
Pro Se Plaintiff Louis Charles HamiltonII, Co-Plaintiff(s) “United
States of America”et al and Co-Plaintiff(s) “State of Texas”et al herein
furtherance’s “Declare”, State, andAffirmbefore the
“Honorable U.S. Justice” Chief Defendant “Doctor DineshChandraKhare”,
Co-Defendant(s) GeetaInternational et al andCo-Defendant(s) “Geeta
International “Legal Division” et al”, Co-Defendant(s) GeetaGroupLLC, Co-
Defendant(s) “GEETA International Co. Ltd.”
And Co-Defendant(s) Vipul Khare conspirer withextreme andhostile acts
and event to FraudCo-Plaintiff(s) “UnitedStates of America”et al and did in
factual circumstance subject ProSe Plaintiff “Louis Charles HamiltonII”herein,
and many, many, others
Similarly same having (American) “businessdealing”with Co-
Defendant(s) GeetaGroupLLC locatedat 1600 River Pointe Dr. Apt. 812, in
51. Conroe, Texas 77304 toa foreignlegal rules andregulationJurisdictionstatusof
“Thailand”
Further this “International RICO CartelEnterpriseRacket”, conspireto,
and in fact did “Subjecting”the ProSe Plaintiff Louis Charles HamiltonII, herein
and many, many, others similarly same to “foreigncorruption”inbusiness
dealing,
Furtherance’s “Subjecting”the ProSe Plaintiff Louis Charles HamiltonII,
hereinto “Cyber Fraud” and “aggravated Identity Theft” being conducted in
“Thailand” secretly far away from the “Judicial Branch” of Government of
the Co-Plaintiff(s) “UnitedStatesof America”et al and Judicial Branchof
Government of Co-Plaintiff(s) “State of Texas”et al herein “equal protectionof
the law and due process, for all (American) citizens of the Co-Plaintiff(s) United
States of America and Co-Plaintiff(s) “State of Texas” fully enjoyment and
protectionthereof.
(35)
Pro Se Plaintiff Louis Charles HamiltonII, Co-Plaintiff(s) “UnitedStates of
America”et al herein onthe Behalf of Co-Plaintiff(s) “State of Texas”et al
furtherance’s “Declare”, State, andAffirmbefore the “Honorable U.S. Justice”
Chief Defendant “Doctor DineshChandraKhare”, Co-Defendant(s) Geeta
International et al and Co-Defendant(s) “GeetaInternational “Legal Division”et
al”, Co-Defendant(s) GeetaGroupLLC, Co-Defendant(s) “GEETA International
Co. Ltd.” and Co-Defendant(s) Vipul Khare collectively hereinhaving for
sometimes having as a Whole” International RICO Enterprise Cartel”being in
Violationof 18 U.S.C. § 371 §371 withall Defendant(s) andCo-Defendant(s)
committedto“Conspiracy to commit offense or todefraud UnitedStates”
(36)
Further this “International RICO Cartel EnterpriseRacket”, conspireto
defraud “United States” is alsobasedupon the International currency exchange
rate”of the Co-Plaintiff “UnitedStates of America”U.S. Dollars in that for each
52. conspirer committedandachieved todefraud “United States”this
“International RICO Cartel Enterprise Racket”,
Gaining a larger “monetary value”once depositing all illegal Money
laundering scheme of thing into eachforeign“International RICO Cartel
Enterprise Racket”, foreigncurrency exchange rate toshore up
Chief Defendant “Doctor DineshChandraKhare”, Co-Defendant(s) Geeta
International et al and Co-Defendant(s) “GeetaInternational “Legal Division”et
al”, Co-Defendant(s) GeetaGroupLLC, Co-Defendant(s) “GEETA International
Co. Ltd.” AndCo-Defendant(s) Vipul Khare “Local and mainly “foreignAssets”
collectively inthis “International RICO CartelEnterpriseRacket”, conspire to
defraud“United States”
(37)
*For example (A) before the “Honorable Justice”
Said Personal check of Chief Defendant “Doctor DineshChandraKhare”,
hereinissuedfrom“Citibank”was Drawn on the exact same address of (616)
Bourne Ct. Danville CA. 94506 toa home whichwas soldon January 2006 for
$1,075,000.00inJanuary 2006
$1,075,000.00 U.S. Dollars worth(today) in Thai Baht exchange rates
“Thailand” 38874150.00 Thai Baht
*For example (B) before the “Honorable Justice”
Said check datedAug 26th
2015 fromthe Newaddress 156 CoburnRoad
Pennington, NJ08534 drawnonce again from “Citibank” from a soldresident
said Chief Defendant “Doctor DineshChandraKhare”, herein“assuming”having
no (legal) control over (once) again in 2015…
Since saidproperty namely “Material facts”supporting that “April 19th
,
2013 156 CoburnRoad Pennington, NJ08534 Property was soldfor $365,000.00
U.S. Dollars
$365,000.00U.S. Dollars worth(today) in Thai Baht exchange rates
“Thailand” 13202780.00Thai Baht
53. *For example (C) before the “Honorable Justice”
Said Personal check of Chief Defendant “Doctor DineshChandraKhare”,
hereinissuedfrom“Citibank”was Drawn on the exact same address of (616)
Bourne Ct. Danville CA. 94506 toa home whichwas soldon January 2006 for
$1,075,000.00inJanuary 2006
$1,075,000.00 U.S. Dollars worth(today) in Indian Rupee exchange rates
“Thailand” 70976875.00IndianRupee
*For example (D) before the “Honorable Justice”
Said check datedAug 26th
2015 fromthe Newaddress 156 CoburnRoad
Pennington, NJ08534 drawnonce again from “Citibank” from a soldresident
said Chief Defendant “Doctor DineshChandraKhare”, herein“assuming”having
no (legal) control over (once) again in 2015…
Since saidproperty namely “Material facts”supporting that “April 19th
,
2013 156 CoburnRoad Pennington, NJ08534 Property was soldfor $365,000.00
U.S. Dollars
$365,000.00U.S. Dollars worth(today) in exchange IndianRupee
exchange rates “India”24099125.00 IndianRupee
(38)
Which “Pro Se Plaintiff “Louis Charles Hamilton“ hereinfurtherance’s
“Declare”, State, andAffirmbefore the “Honorable Justice”onbehalf of Co-
Plaintiff(s) “UnitedStates of America”et al and Co-Plaintiff(s) “State of Texas”
et al this “International RICO Cartel Enterprise Racket”, scheme of things in
conspire todefraud
“UnitedStates”is alsobased “among other things” the “International
currency exchange rate”of the Co-Plaintiff “UnitedStates of America”U.S.
Dollars and that “Thai Baht” exchange rates “Thailand” and that “Indian Rupee”
exchange rates “India”which
Chief Defendant “Doctor DineshChandraKhare”, Co-Defendant(s) Geeta
International et al and Co-Defendant(s) “GeetaInternational “Legal Division”et
54. al”, Co-Defendant(s) GeetaGroupLLC, Co-Defendant(s) “GEETA International
Co. Ltd.” and Co-Defendant(s) Vipul Khare
Collectively hereinhaving “Monetary ForeignHoldings, Assets, properties,
Corporations, Business, Companies, Retails, shops, import andexport, stores,
homes, cars, chattel ect… basedin“Thailand and “India” in that for each (RICO)
conspire committedandachievedtodefraud “UnitedStates”as a whole
Chief Defendant “Doctor DineshChandraKhare”, Co-Defendant(s) Geeta
International et al and Co-Defendant(s) “GeetaInternational “Legal Division”et
al”, Co-Defendant(s) GeetaGroupLLC, Co-Defendant(s) “GEETA International
Co. Ltd.” and Co-Defendant(s) Vipul Khare
Collectively hereinhaving “Mutable Monetary ForeignHoldings, Assets,
properties, Corporations, Business, Companies, Retails, shop, import and
export, stores, homes, cars, chattel ect…is being (officially) financial shoredup
and monetary secured onsaidexchange rate from (Financial Global) marketing
collapsing disastersby focusing on “among other things”a scheming
“International RICO Cartel Enterprise Racket”, of Chief Defendant “Doctor
DineshChandra Khare”, Co-Defendant(s) GeetaInternational et al and Co-
Defendant(s) “GeetaInternational “Legal Division”et al”,
Co-Defendant(s) GeetaGroupLLC, Co-Defendant(s) “GEETA International
Co. Ltd.” and Co-Defendant(s) Vipul Khare todefraud Co-Plaintiff(s)
“UnitedStates of America”et al in a fraudulent “patternand practice”
fully up to date currently engaging inamong other things a(RICO) scheme of
things inprime real-estate now (active) infraudactivates engagedinCo-
Plaintiff(s) Jurisdictionnamely
(Texas) in a International “Money Laundering “scheme of things”within
the Jurisdictionof Co-Plaintiff(s) “United Statesof America”et al and withinthe
JurisdictionCo-Plaintiff(s) “State of Texas”et al Jurisdiction collectively
Committedtoand engaging in conspirer by all Chief Defendant “Doctor
DineshChandra Khare”, Co-Defendant(s) GeetaInternational et al and
Co-Defendant(s) “GeetaInternational “Legal Division”et al”, Co-
Defendant(s) GeetaGroupLLC,
55. Co-Defendant(s) “GEETA International Co. Ltd.”and Co-Defendant(s) Vipul
Khare collectively conspire toFraud said“UnitedStates of America” and Texas
Namely Co-Plaintiff “UnitedStates of America”et al and namely Co-
Plaintiff “State of Texas” et al herein
(39)
Pro Se Plaintiff Louis Charles HamiltonII, Co-Plaintiff(s) “UnitedStates of
America”et al hereinonthe Behalf of Co-Plaintiff(s) “State of Texas”et al
furtherance’s “Declare”, State, andAffirmbefore the “Honorable U.S. Justice”
Chief Defendant “Doctor DineshChandraKhare”, Co-Defendant(s) Geeta
International et al and Co-Defendant(s) “GeetaInternational “Legal Division”et
al”, Co-Defendant(s) GeetaGroupLLC, Co-Defendant(s) “GEETA International
Co. Ltd.” and Co-Defendant(s) Vipul Khare collectively hereinhaving intheir
“International RICO Cartel”
Namely GeetaInternational Co. Ltd. “Shipping & Marine Supplier”based
in “Bangkok “Thailand” among other “International (Locations) Geeta
International Co. Ltd. “Shipping & Marine Supplier”having Internationally
foreignshipping assets and making such“Port of Calls”
Pro Se Plaintiff Louis Charles HamiltonII, hereinfurtherance’s “Declare”,
State, and Affirmbefore the “Honorable U.S. Justice”
Namely Co-Defendant(s) GeetaInternational Co. Ltd. “Shipping & Marine
Supplier” Having formulated additional “International RICO Enterprise Racket”
scheme fully engaging in among other things “Mutable Counts” inHiding,
obscuring, and transporting (American) goods revivedinthis Money launder
(RICO) scheme of things back to Chief Defendant “Doctor DineshChandra
Khare”, Co-Defendant(s) GeetaInternational et al and
Co-Defendant(s) “GeetaInternational “Legal Division”et al”, Co-
Defendant(s) GeetaGroupLLC, Co-Defendant(s) “GEETA International Co. Ltd.”
and Co-Defendant(s) Vipul Khare “International RICO Cartel”, mutable
Monetary ForeignHoldings, Assets, properties, Corporations, Business,
Companies, Retails, shops, import andexport business, stores, and homes.
56. (40)
Pro Se Plaintiff Louis Charles HamiltonII, Co-Plaintiff(s) “UnitedStates of
America”et al and Co-Plaintiff(s) “State of Texas”et al furtherance’s “Declare”,
State, and Affirmbefore the “Honorable U.S. Justice” this “International RICO
Cartel EnterpriseRacket”, schemeof things inconspire todefraud
“UnitedStates” upon informationand belief Chief Defendant “Doctor
DineshChandra Khare”, Co-Defendant(s) GeetaInternational et al and
Co-Defendant(s) “GeetaInternational “Legal Division”et al”, Co-
Defendant(s) GeetaGroupLLC, Co-Defendant(s) “GEETA International Co. Ltd.”
and Co-Defendant(s) Vipul Khare “International RICO Cartel”,
Having furtherance devisedaformulation, structure, monetary laundering
(RICO) systemwithinthe Co-Plaintiff(s) UnitedStates of America”et al
Jurisdictioninthat as follows:
1. The exact same address of (616) Bourne Ct. Danville CA. 94506 toa
home whichwas sold on January 2006 for $1,075,000.00 but saidcheck
for “Constructionservices”was made out on August 22nd
2015..And
the Personal Check filedas ProSe Plaintiff, “Louis Charles HamiltonII”,
Co-Plaintiff(s) UnitedStatesof America”et al, and Co-Plaintiff “State of
Texas”et al, hereinexhibit (B) insupport of this complaint made
herein
2. And SaidPersonal check of Chief Defendant “Doctor DineshChandra
Khare”, hereinissuedfrom“Citibank” which was Drawn on the exact
same address of 156 Coburn Road Pennington, NJ08534 toa home
which was sold on “April 19th
, 2013 for $365,000.00 U.S. Dollars
“However” but said check for “Constructionservices”was made out on
August 22th
2015…
3. $1,075,000.00+$365,000.00 =$1.44 (Million) U.S. Dollars ina
“International RICO Cartel”, property scam(among others) inwhich
said Chief Defendant “Doctor DineshChandraKhare”, Co-Defendant(s)
GeetaInternational et al and Co-Defendant(s) “GeetaInternational
“Legal Division”et al”, Co-Defendant(s) GeetaGroupLLC, Co-
Defendant(s) “GEETA International Co. Ltd.”and Co-Defendant(s) Vipul
Khare “International RICO Cartel”, racket hereinhaving “Soldsaid
57. property “among others”toinclude but not limitedtonone other
collectively “themselves”inthis (RICO) racket tofurtherance’s commit
fraud of the Co-Plaintiff “The UnitedStates of America”et al and Co-
Plaintiff(s) “State of Texas”et al in the past, present andfuture
obscuring, hiding, laundering sucha well integratedconglomerateof
“International Business inits owntax free have zone hiddenwell
within Co-Plaintiff (UnitedStates of America) scheme of things being
namely a International Corporationof mutable business legal as such
however well as facts proving hereina turn intoa well formulated
“International RICO EnterpriseRacket”basedin“Thailand”
4. Namely Chief Defendant “Doctor DineshChandraKhare”, Co-
Defendant(s) GeetaInternational et al and Co-Defendant(s) “Geeta
International “Legal Division”et al”, Co-Defendant(s) GeetaGroupLLC,
(40)
Pro Se Plaintiff Louis Charles HamiltonII, Co-Plaintiff(s) “UnitedStates of
America”et al and Co-Plaintiff(s) “State of Texas”et al furtherance’s “Declare”,
State, and Affirmbefore the “Honorable U.S. Justice” inthat
Namely Chief Defendant “Doctor DineshChandraKhare”, hereinhaving
“Possibly”toaid furtherance’s ainternational (RICO) scheme of things against
the Pro Plaintiff “Louis Charles HamiltonII”, Co-Plaintiff(s) UnitedStates of
America”et al,
And Co-Plaintiff(s) “State of Texas”et al to include the “State of California
and The State of “NewYork”…among others, infalse impersonationas a License
(Doctor) withinthe Jurisdictionof Co-Plaintiff “UnitedStates of America”et al
and Co-Plaintiff “State of Texas”in direct violationof TEX OC. CODE ANN. §
164.052:Texas Statutes - Section164.052: as describedinparagraph
TEX OC. CODEANN. § 164.052 :Texas Statutes - Section164.052:
PROHIBITED PRACTICES BY PHYSICIAN OR LICENSEAPPLICANT(a) A physicianor
an applicant for a license topractice medicine commits aprohibitedpracticeif
that person:(1) submits tothe board a false or misleading statement, document,
or certificateinan applicationfor a license;(2) presents tothe boarda license,
certificate, or diplomathat was illegally or fraudulently obtained;(3) commits
fraud or deceptionintaking or passing an examination;(4) uses alcohol or drugs
58. in an intemperate manner that, inthe board's opinion, couldendanger a
patient's life;(5) commits unprofessional or dishonorable conduct that is likely
to deceive or defraudthe public, as providedby Section164.053,
Or injure the public;(6) uses anadvertising statement that is false,
misleading, or deceptive;(7) advertises professional superiority or the
performance of professional service inasuperior manner if that advertising is
not readily subject toverification;(8) purchases, sells, barters, or uses, or offers
to purchase, sell, barter, or use, amedical degree, license, certificate, or
diploma, or a transcript of a license, certificate, or diplomain or incident toan
applicationto the board for a license topractice medicine;(9) alters, with
fraudulent intent, amedical license, certificate, or diploma, or a transcript of a
medical license, certificate, or diploma;(10) uses amedical license, certificate, or
diploma, or a transcript of a medical license, certificate, or diplomathat has
been:(A) fraudulently purchasedor issued;(B) counterfeited;or(C) materially
altered;(11) impersonates or acts as proxy for another personin an examination
requiredby this subtitle for amedical license;(12) engages inconduct that
subverts or attempts tosubvert anexaminationprocess requiredby this subtitle
for a medical license;(13) impersonates aphysicianor permits another touse
the person's license or certificate topractice medicine inthis state;(14) directly
or indirectly employs apersonwhose license topractice medicine has been
suspended, canceled, or revoked;(15) associates inthe practice of medicine with
a person:(A) whose license topractice medicine has beensuspended, canceled,
or revoked;or(B) who has beenconvictedof the unlawful practice of medicine
in this state or elsewhere;
(16) performs or procures a criminal abortion, aids or abets in the
procuring of a criminal abortion, attempts toperformor procure a criminal
abortion, or attempts toaid or abet the performance or procurement of a
criminal abortion;(17) directly or indirectly aids or abets the practice of
medicine by a person, partnership, association, or corporationthat is not
licensedtopractice medicine by the board;(18) performs anabortionon a
woman who is pregnant witha viable unbornchild during the thirdtrimester of
the pregnancy unless:
(A) the abortion is necessary toprevent the deathof the woman;(B) the
viable unborn childhas a severe, irreversible brainimpairment;or(C) the
woman is diagnosedwitha significant likelihoodof suffering imminent severe,
59. irreversiblebraindamage or imminent severe, irreversibleparalysis;or(19)
performs an abortionon an unemancipatedminor without the writtenconsent
of the child's parent, managing conservator, or legal guardian or without a court
order, as providedby Section33.003or 33.004,
Family Code, authorizing the minor to consent tothe abortion, unless the
physicianconcludes that on the basis of the physician's good faithclinical
judgment, a conditionexists that complicatesthe medical conditionof the
pregnant minor and necessitatesthe immediate abortionof her pregnancy to
avert her deathor to avoid a serious risk of substantial impairment of a major
bodily functionand that there is insufficient time toobtainthe consent of the
child's parent, managing conservator, or legal guardian.(b) For purposes of
Subsection(a)(12), conduct that subverts or attempts tosubvertthe medical
licensing examinationprocess includes, as prescribedby boardrules, conduct
that violates:(1) the security of the examinationmaterials;(2) the standardof
test administration;or(3) the accreditationprocess.(c) The boardshall adopt the
forms necessary for physicians toobtainthe consent requiredfor an abortionto
be performedonan unemancipatedminor under Subsection(a). The form
executedtoobtainconsent or any other requireddocumentationmust be
retainedby the physicianuntil the later of the fifthanniversary of the date of
the minor's majority or the seventhanniversary of the date the physician
receivedor createdthe documentationfor the record.
(41)
” In Direction violationof CaliforniaPenal Code 529 PC
“False impersonation”(alsoknownas “false personation”) is a crime in
California. Under CaliforniaPenal Code 529 PC, you commit the crime of false
impersonationwhenyou:
1. Falsely personate someone (that is, pretendtobe them) intheir public or
private capacity;and
2. Performany other act that might cause the personyou are impersonating to
become liable toa lawsuit or prosecutionor become obligatedtopay money, or
which might cause you to get some benefit fromimpersonating him/her.