This motion for final summary judgment alleges that the defendants entered into a $10,850 contract with the plaintiff to repair hurricane damage to their home but then breached the contract. It claims the defendants received insurance money for repairs but spent it elsewhere and confiscated the plaintiff's tools. The plaintiff argues there are no genuine issues of material fact and he is entitled to damages, lost profits, and return of his tools as a matter of law.

1. No. A-180805
Louis Charles HamiltonII IN THE DISTRICT COURT
Plaintiff 58TH
JUDICIAL DISTRICT
V.
Joyce Guy & Edward McCray ET AL OF JEFFERSON COUNTY, TEXAS
Defendants.
PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT
Comes Now Before The Honorable 58th
District Court thePro Se Plaintiff,
Louis Charles Hamilton II,
Motion before the HonorableCourt,
For a “Final Summary Judgment” in this matter, in full favor of the
described Pro Se Plaintiff herein.
The Plaintiff further movethe Court to find justcausefor a finding of fact’s,
and conclusion of Law after proper examine of all of the files, records, exhibits,
now here before the HonorableCourt.
To include the Court Direction and Full Respectful Entertainment viewing
the said Motion for Final Summary Judgment, All Exhibits and Attachment(s) and
Brief in Support, Now Here Before the Court examination
And The Direct Responseof the Defendants “Joyce Guy & Edward McCray”
Motion in Opposition, and all other records filed by the defendants collectively
To include the existence of outrageous conductof physicalharm upon the
Plaintiff person By the Defendant Edward McCray

2. Considered and EstablishedConclusively,
This Litigation has a available civil remedies with full interest incurred,
Justify per Plaintiff rightful entitlement to a “Final Summary Judgment” in his full
Favor as a matter of Law,
Plaintiff Declare, Assertand Respectfully Submit “No genuine issueof
“Material Facts” exist, and quite “clean-cut”, and “clear” on Legal Principles in
Favor on The Plaintiff
Plaintiff Further Move before The HonorableCourt He be Award all
damages in full under “Breachof Contract” precisely after examine before the
HonorableCourt’, the element of a Contract”, filed herein as Plaintiff exhibit (A-1)
establishing before the Court,
Defendants collectively after consulting together as “Husband and Wife”
“To Wit” Enter into said described contractfor the “Home Improvements” fully
described therein
Plaintiff Moves the HonorableCourt after the said hearing Now Being held
on December 17, 2014 8:30 amBeforethe Honorable58th
Judicial Honorable
Judge”
Plaintiff motion for “Final Summary Judgment”being fully Valid, Executed
And Granted to required the described Defendants Collectively herein to be held
entitled to the Plaintiff described damages to include in return all of the property
in regards to the “List of ConstructionTools” wrongfully taken fromthe Plaintiff
In the Amount established by The Court, as request by The Plaintiff in the
Original Complaint in actual damages
In excess of $18,251.00 with interest incurred fromdate of injury” namely
past date of November 16, 2007
Pro Se Plaintiff, herein file before the Honorable 58th DistrictCourt Plaintiff
Exhibit (A, B, and C) in Supportof Plaintiff Motion for final Judgment,

3. Affidavitof Defendant (Joyce Guy) exhibit (A) and Responseto Plaintiff’s
Motion for Sanctions by: Attorney of record Antoine L. Freeman, J.D. Texas Bar
No. 24058299 3723 GulfwayDr. Ste. #104 PortArthur Texas 77642 (Attorney for
the Defendant) exhibit (B) and Motion for Withdrawalof Counselexhibit (C)
Plaintiff Moves the HonorableCourt’ to take “Judicial Notice” to the
following Real facts:
1. The Plaintiff Discovery requestin the casewas well legally pursued for
all ImportantMaterial facts to supportPlaintiff cause of actions, and
filed with by and though counsel of record for the Defendants Antoine L.
Freeman, J.D. at the very start clearly in 2007 atwhich the Attorney of
Record Claim in a legal reply “no less” his only Legal obligation to this
civil case A-180805 wasto drafta (Simple) General denial on behalf of
the Defendants filed on December 18th
2007 and at that point his
“Fiduciary Duty” to his clients and beforethe Court ended on that date
December 18th
2007 and was legally completely over, no matter to the
simple facts Antoine L. Freeman, J.D. (Attorney at Law) been sitting on
this case fromdate of December 18th
2007 when this Attorney of Record
in Jefferson County Texas 58th
DistrictCourt as such to avoid a default
file his original Answer, accept paymentto be said Attorney of Record
and until April 2, 2008 up to April 11th
, 2008 defendant collectively with
Attorney of Record having no full knowledge at all that a discovery
phaseprocess had commence in this civil legal matter… some 9 months
of this Legal “MIA” playing the Plaintiff for a simple minded fool in the
process of a Civil Matter No Less, in the dancing about to release all
“discovery requestsought” in this matter as sought to supportthe
Plaintiff full cause of Actions. To include add Attorney of Record insult to
the injury of the Plaintiff civil matter (Now) Counsel of Record filed his
Motion to withdrawalas Attorney of Record on November 13 2009,
almost Two (2) entire full years in his grand funk refusalof the rules of
Civil procedurein such Soughtdiscovery request”. Claiming in said
Motion to with draw at this time in 2009 “Defendants” have not
complied with the terms of the employmentagreementwith this

4. Attorney” Filed herein as Plaintiff exhibit (C). while the Defendant
Affidavitexhibit (B) stating among other things it was her decision not to
reply to any of the Plaintiff Discovery Request …And Sworn legally on
the 11th
day of September 2009, whilethis action was filed on the 26th
day of November 2007 “Your Honor”
2. “However” Counselof Record while knowing fully as acting Counselof
Record in April 2, 2008 such a discovery phasewas needed and in
process by Plaintiff to Pursueand movea civil legal presentation before
the Honorable58th
DistrictCourt”, and fromthat said date of April 2nd
2008 date Now till November 13th
2009 (OneYear, 7 months) further
throughoutCounsel of Record “Defendants” collectively have not
complied with the terms of the employmentagreementwith this
Attorney” in this Civil Matter A-180805
Discovery- A party can obtain discovery regarding any matter that is not
privileged and is relevant to the subjectmatter of the pending action. Itis
not grounds for objection that the information would be inadmissible at
Trial if it appears reasonably calculated to lead to the discovery of
admissibleevidence.
Plaintiff Assertbefore the HonorableCourt “FormalWritten
Discovery Requestwere in fact filed with Attorney of Record Antoine L.
Freeman, J.D. Texas Bar No. 24058299 3723 and whatlittle was obtain also
filed here in as Exhibit(s) before the Court Records.
Plaintiff Supportfurther Before “The Honorable Court” that the
Defendants knowingly collectively did enter into a Contract for
Construction following Hurricanedamages on the 11th
day of November
2007 and such contract filed as Plaintiff exhibit (A-1).
To complete all home repairs as described there at the property located at
448 DeQueen Blvd. Port Arthur Texas 77640in for the Amount of
$10,850.00
I.

5. Plaintiff further supportfact’s and real life sound Evidence beforethe
HonorableCourt Plaintiff Exhibit (D) *Parker Lumber In PortArthur Texas
2948 GulfWay Drivefor the delivery of $2869.08 dollars in building
materials as described therein Plaintiff Exhibit (D) and was in fact in the
Custody, Controland Possession by thedefendant collectively after delivery
@ their home described in this civil complaint at that point the Defendant
combine Conduct created a Intentional Breach of Contract .
Which the Plaintiff would be entitled to the profits he is entitled to
before the construction started being derived from the contract in the
amount of $2869.08 subtracted fromthe Contractamount of $10,850.00
Plaintiff further submit the Defendant(s) confiscated new tool,
broughtto completely in a Professionalmanner as well as the Defendant
confiscated all of the Plaintiff entire Contract supply of tool fromeverything
air compressor, power tool, and hand held tools,
As described in the Complaint, to include Police involvement trying to
get these “Dog’s of Defendants” to in the least return to the Plaintiff his
own possession which the Defendant(Only) return was Plaintiff Laptop
Computer all which was store at their Home and Construction was to
commence the very next Morning.
II.
Plaintiff assertbefore The HonorableCourt Profitin the Amount of
$7981.00dollars in labor and Profit being secured under such Contract to
include the Plaintiff is entitled to fully recover of all tools all described in
the complaint, which is a quite substantialamount, leading to the doggeries
theft of said tools by the Defendants for wrongfulcriminaland Civil gain.
The Plaintiff Further state before The HonorableCourt, The Defendant(s)
devised a schemeof things to Fraud the InsuranceCompany of the Moneys need
for the repairs of this said home in that “Defendant(s) collectively

6. All ready spend the firstInsuranceInstallment paid by Third Party Insurance
Company and Defendant(s) refusalto identify such InsuranceCompany for these
court proceedings, through counselof record (Antoine L. Freeman J.D. Attorney at
Law) fromtime of his notice of Counsel for the Defendant in 2007-2009 on Record
While Both Defendant(s) collectively fully committed to the same refusalon
there “among other things” sign Affidavit,
And there continue action up to date before this HonorableCourt as of this
Undersign Date”.
Which “JoyceGuy” and “Edward McCray” conniveto scheme the Insurance
Company further for a balance of funds to fix the Home,
Via there scheme of things in association with real “Fraud” and “Theft” of
“Property” being wrongfully inflicted upon The Contractor, Namely Pro Se Plaintiff
Herein.
III.
The Plaintiff Further State before “The HonorableCourt”,
There after all acts committed by the Defendant(s) to include “Theft of
property “The Pro Se Plaintiff, concluding his own “Extensive Investigation” into
the Defendant(s) among other things “Multi-Business back ground, and Criminal
History:
As Fact as Follows:
A. The Defendant had listed a “Home Health” Services for the State of
Texas Aging Disability Seniors, in Jefferson County Texas namely working
in Port Arthur Texas many years (Illegally) with hand on- personalcare
for the Elderly without out ever having a Valid HCSSA license, and The
Proper Medical degrees and qualified Training for such services and
been in this “Said” business since 2nd
of May 1997 and was order by the
“State of Texas” Department of Aging and Disability Services Plaintiff

7. exhibit (E) to stop such Illegal business January 7, 2010 via Plaintiff
request on January 11th
, 2010 attached letter in Plaintiff exhibit (F)
B. Plaintiff Exhibit (E) * CertifiedMail:7003 1010 0003 6838 1858 “State
of Texas”Department of Aging and Disability Services, letter to
Defendant(s) and Copy to the Pro Se Plaintiff herein whom sent“The
State of Texas” to send Defendant(s) collectively a immediately shut
down”,
C. Notwithstanding Pro SePlaintiff was on his cell phone with the State of
Texas” Investigator” revealbadgeas arrivalupon said Defendant“Joyce
Guy” whomwas at that precise legal time give Official Legal Notice of
Her Actions with a order of Authority by “The State of Texas”as
described herein paragraph (A) and (B) abovewith Plaintiff Exhibit (E)
and (F) filed herein for support,
D. Plaintiff files Exhibit(G) County Clerk’s OfficeAssumed Names
Defendant “Bogus” Company and proof of date Company been in
operation over 13 years’, Novalid State of Texas documentations for
working withElderly , Noassumedtax records ever, while making
large incomes from saidBusiness inthe years as described herein
E. To include the listing of a “Dead Man”, in the operations of Said Home
Health Care Services for the Elderly Business as described herein for
over 7 years thereafter pasthis “Death”, Ulyess Guy Sr.” Birth
December 22, 1926 *Death November20 2003 as described in Plaintiff
Exhibit (H) filed herein before “The HonorableCourt”.
F. * Plaintiff exhibit (H) Social Security DeathIndex Search “Results” for
owner of Bogus Business filed in Jefferson County, Texas under the
Name of “Ulyess Guy Sr.”
IV.
The Plaintiff Further State before “The HonorableCourt”,

8. The Defendant was served a FirstSet of “Interrogatories” in this action,
Pursuantto Rule 197 of the Texas Rules of Civil Procedure. By and through their
Attorney of Record and filing such now
As Plaintiff Exhibit (I), Herein as The Plaintiff state Brief material facts that
the Defendant(s) collectively answer to question 24 and 25 as follows:
(24) Whatwasall of the terms and conditionsof said contractin regardsto
repairsto the home located 448 Dequeen blvd. in PortArthur, Texas
Answer
Plaintiff would repair damagesdone by Hurricanefor a total priceof
$10,800 and Defendant would put $3,616 down towardsthetotal price.
(25) Wasthe Contractforward to any insurance companiesfor paymentto
cover said construction cost?
Answer
Yes
The Plaintiff fully direct the HonorableCourt attention to these facts
1. Defendant (Already) infacts received fromsaid “Unknown Insurance”
company in excess of approximately $6,500 dollars tofix saidhome
and this money was squander and spent up from their Banking
saving/checking account quite very long before The Defendants even
enter intosaidConstructionContract withPlaintiff on 11/05/2007
Defendants were served Pursuant toRule 194 Texas Rules of Civil
Procedure. By and through their Attorney of Record Plaintiff requestfor
Disclosurewhich Defendants at that time refused through their Attorney of
record
To simply Identify Said “Unknown Insurance Company” which is very
Material to this Action and was pursued long before “Plaintiff Interrogatories”

9. was even served upon the Defendant(s) and Filed Now as Plaintiff Exhibit (J)
herein Plaintiff request for DisclosurePursuantto rule 194
Defendant(s) did in fact received fromthis “Unknown InsuranceCompany”
a balance of Monetary Funds in addition fromwhatalready was forwards to said
Defendant(s) based upon the Plaintiff “Construction Contract” of $10,800.00,
Which the Defendants further supply and combine their “twistedscheme
of things”was to physically usethe Plaintiff Construction Contract of $10.800.00
to achieve such a “Cruel Criminal Scheme of things”against not only the Plaintiff
But also to include The “Unknown Insurance Company” for MoreMonies
in addition to the amountalready received fromsaid “Unknown Insurance
Company” for repairs as being described now before the Honorable Courtin
PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT,
Notwithstanding “Facts” to the “HonorableCourt”
“Yours Honor”
Never Ever, Ever, Was Any ActualMonies ever being spent on any Actual
Physical ConstructionRepairs from any described stormdamages in the pastby
any Construction Contractors and or Sub-Contractors ever being performed at
any time at the home located at 448 Dequeen Blvd. in Port Arthur Texas,
Fromany Hurricanedamages by (Rita & Humberto) as such repair funds
was indeed paid out to cover all extreme needed structural repairs in the Past for
these “Trifling Defendant(s)”, making such claims against their “Insurance
Companies, Construction Contractors in the Past, and to include now FEMA
As this same “CrookedScheme of Things” was in fact executed more than
once by the Defendants collectively in the pastfromanother Hurricane(Rita)
Damage of said 448 Dequeen Home, long before the Plaintiff Construction
Contract filed herein was even drafted for Repairs for Damages of “Hurricane
Humberto” againstanother such Building Construction Contractor for (Rita)
stormdamages…

10. And as this same “CrookedScheme of Things” was in fact executed in the
past by the Defendants collectively on The Home Located at 5050 East 7th
Street
in Port Arthur Texas
Namely Defendant (Joyce Guy) owns Mother Home (NormaJ. Guy) whom
Defendant (Joyce Guy) had power of Attorney over her mother legal affairs at
this time frameand used this to “Her” continued wrongfulcrooked advantages
To include such a “bogus rip off scheme of things”by the Defendant(s)
collectively againstall Hurricane damages of both said homes and “Unknown
InsuranceCompanies” which moneys was in fact paid out for all needed repairs in
full in the past stormhistory, and defendants completely civil/criminally squander
every nickel in a “Long History “ of “thievery” Schemeof things against“FEMA
and Insurances Companies” following such “Natural Hurricane Damages”and
Now the same Scheme of things involved against the Plaintiff herein and his
personalproperty (Construction tools),
And The Insurance Company, and FEMA, in which the Defendant “Home”
At 448 Dequeen Blvd. in PortArthur Texas was in facts completely demolished for
Defendants crooked combine failures to supply any needed repairs (Ever) when
all such funds being legally designed for such said Hurricane Repairs to said
property located at 448 DequeenBlvd. in Port Arthur Texas
As The Plaintiff States now Before “The Honorable Court”facts that a New
Home being built at the costof $76,000.00 ona Federal Grant.
As described in Plaintiff exhibit (I) FirstSet of “Interrogatories” in this
action, question(s) 7-12
On Defendants collectively long continue corruptedhistory road of scams,
ripoff’s, thievery acts, as describedherein fully being executedby Both
Defendant Collectively.
All building materials as being describedherein Plaintiff Exhibit (E) *Parker
Lumber In Port Arthur Texas 2948 GulfWay Drivefor the delivery of $2869.08
dollars in building materials for repairs tosaid 448 Dequeenhome that was in

11. fact delivery was refundedandor sold, And not for any benefit of the saidhome
stormdamages but pure wrongful monetary Defendant(s) collectively financial
gains.
V.
The Plaintiff Further State before “The HonorableCourt”,
“The Defendant(s) By and through their Attorney of record Antoine L.
Freeman, J.D. Texas Bar No. 24058299 was in factserved Plaintiff Request for
Admissions propounded by Louis Charles Hamilton II Pro SePlaintiff herein
pursuantto rule 198 of the Texas Rules of Civil Procedure.
Filed herein as Plaintiff exhibit (K) before the “HonorableCourt”.
Providing, and legally well documented additional proof with all of the court
records, exhibit(s) and files herein causeNo. A-180805
Thus 100% Proving theFollowing official legal material facts beforeany
“HonorableCourt” of Law in and for The State of Texas as follows:
1. Attorney of Record Antoine L. Freeman, J. D. Texas Bar No. 24058299was
in fact full acting Attorney of record fromdates of filing a General Denial
December 18th
2007 as heclaim in the records and doing so further acting
as Attorney of record in filing a reply to Plaintiff (Interrogatories) already
filed herein and dated October 14th
2009 as Exhibit (I)
2. To now include Attorney of record was in fact full acting legal capacity in
filing a reply the Plaintiff Request for Admissions exhibit(K) and dated
October 14, 2009 atthis point the Plaintiff point out further that Attorney
of record made a illegal bogus claim before The HonorableJudge “Bob
Wortham that his only legal duties as described in Plaintiff exhibit (B)
paragraph III. As Stated by said Attorney of Record Antoine L. Freeman, J.
D. Texas Bar No. 24058299 follows:
3. At the time of Plaintiffs discovery requestDefendant’sAttorney had not
been retain by Defendantsto representtheir interest with regard to this
lawsuit, Defendant, Joyce Guy, retain the servicesof Antoine Freeman for

12. the purpose of writing a generaldenialso as to avoid default judgment
being rendered againsther.
4. The Honorable Court 58th
District Court Judge BobWortham” ruled
completely erroneously in favor of said Defendant’s Attorney of record
Antoine L. Freeman, J. D. Against Pro Se Plaintiff request for sanctions
being level and citied againstsaid Attorney of record Antoine L. Freeman, J.
D. Texas Bar No. 24058299 in official courtdocket No. A-180805records
when all of Plaintiff evidence filed herein supportthat a legal finding that
Defendant’s Attorney did violated Rule 193.1 by failing to respond to
Plaintiff’s discovery request up to almost 2 years while having full legal
knowledgeof such a discovery requestwas being pursued by the Pro Se
Plaintiff
A. Attorney of Record Antoine L. Freeman, J. D. Was acting with
physicalfiduciary capacities as an Attorney of Law for the State of
Texas Bar. No. 24058299 on or about December 18th
2007 and
continue doing the samelegal capacities being fully intact as
acting Attorney of record and filed official court records with the
Plaintiff as described in Plaintiff exhibit (I) and (K) dated October
14, 2009
B. The Attorney of record Antoine L. Freeman, J. D. then at this
point took his civil wrongful lie, and false presentation filing
before the 58th
DistrictJefferson County HonorableCourt Judge
“Bob Wortham” stating he was not the Attorney of record and
only filed a general denial with the Court and this was his only
legal obligations, and this ended on December 18th
2007
C. To include as further evidence to supportthe Plaintiff cause for
sanctions againstsaid Attorney Antoine L. Freeman, J. D. the
Plaintiff exhibit (A) Affidavitof Defendant“Joyce M. Guy” dated
September 11, 2009 to supportanother bogus Defendantclaim
too, on behalf of her own Attorney of record Antoine L. Freeman,
J. D. rouge acts to “avoid sanctions”in favor of the Plaintiff when
both Defendant(s) collectively and Attorney of record Antoine L.
Freeman, J. D. having full legal knowledgeof such a discovery

13. request being in place, and pursued fromDecember 18th
2007
throughout October 14, 2009
D. Attorney of Records Antoine L. Freeman, J. D. maintain his only
duties was Justfiling a “General Denial”beforethe Honorable
58th
DistrictCourt Judge“Bob Wortham” as his Attorney of record
signatureand Bar No. 24058299 is materially present on both
Plaintiff exhibit (I) and (K) dated October 14, 2009 well beyond
the filing of said General Denial onDecember 18th
2007
E. Namely official Court discovery documents devisein the formof
“Request for Admissions” pursuant toRule 198 of the Texas
Rules of Civil Procedure and Plaintiff First set of Interrogatories”
pursuant to 197 of the Texas Rules of Civil Procedure both being
dated on October 14, 2009 proving thePro Se Plaintiff was in
pursuitof civil discovery well up to 2 years through Defendant(s)
Attorney of Record, Antoine L. Freeman, J. D. with his signature
and Bar No. 24058299 being materially present againstsaid
Attorney Claims he was only acting in December 18th
2007
F. As this Rouge Attorney did aid in criminally stalling againstthe
Rules of Civil Procedures tactics with full paymentto doing such
actions by said defendant(s) to achieve this lawless civil act
against the Pro Se Plaintiff rights to a Just causeof action before
any court of Law within the State of Texas in Docket No. A-
180805
G. Yet” Attorney of Record Antoine L. Freeman, J. D. right after
October 14, 2009 was granted in addition to sanctions ruling in his
favor his additional Motion to be removed as acting Attorney
fromthis case dated November 13th
2009, after 2 years being the
official acting Attorney of record but claiming, and representing
before the Honorable58th
DistrictCourt Judge “Bob Wortham”
that this was not the legal caseat hand in courtrecords after
December 18th
2007 general denial filing.
H. “However” elementary material legal facts containing Attorney
Antoine L. Freeman, J. D. “very own signature”and Bar No.

14. 24058299 is materially present in Plaintiff Exhibit(s) (I) and (K)
proving Attorney Antoine L. Freeman, J. D. was representing the
Defendant(s) “Joyce M. Guy and Edward McCray”collectively
with actual payment render and received for billing hours
throughoutthe years of 2007, 2008 and October of 2009, up to
the actual date of November 13th
2009 butpreviously made
claims before the Honorable58th
DistrictCourt Judge “Bob
Wortham” in Plaintiff exhibit (B) *Response toPlaintiff’s Motion
for Sanctions dated11th
of September of 2009 his only “Attorney
duties” was to Draftand file a general denial on December 18th
2007 in his Attorney capacities at this time framewith payment
for such as a Attorney of Law for the State of Texas Bar. No.
24058299 on or aboutDecember 18th
2007 such generaldenial
being official filed in Court records.
I. While Pro Se Plaintiff without any law degree already being
completely robbed of his profession by the actions of the
Defendant(s) in the stealing namely of all of the Plaintiff
Construction tools, inflicting real Hardship in this act alone
J. (Now) Plaintiff being giving a additional 100% unfair disadvantage
by a “Thug Rouge” Lic# Attorney of Law in and for The State of
Texas, and his Bogus counsel of law professionaldegree
representation before the “Honorable 58th DistrictCourt Judge
“Bob Wortham” in Jefferson County Texas to wit:
K. Said Attorney of record Antoine L. Freeman, J. D. did in all facts
aid in hiding the Defendant(s) Collectively Material Facts of
Construction Corruption of HurricaneDamages funds at 3 counts,
Fraud on InsuranceMonies at3 counts, and Fraud of FEMA at 1
count, while further aiding through the Courtdiscovery records
process further theft of the Plaintiff Property namely all of
Plaintiff Construction tools and further aids in all acts as described
in Plaintiff Complaint filed in the records beforethe Honorable
Court againstthe described Defendant(s)

15. L. In order that this “bogus rouge” Attorney of Law Antoine L.
Freeman, J. D. “legal commitment”was to being paid in his
official capacity before the “Honorable 58th
District Court”and
The State of Texas” to hide such “Major Grand thievery”
commitment(s) of the Defendants collectively from December
18th
2007 toOctober 14, 2009 as described by all of the Plaintiff
Exhibit(s) (I) and (K) “Request for Admissions”pursuant toRule
198 of the Texas Rules of Civil Procedure and Plaintiff First set of
Interrogatories”pursuant to197 of the Texas Rules of Civil
Procedure both being dated on October 14, 2009 and there
(Now) official filing herein this undersigned date beforethe
Honorable58th District Court of Jefferson County Texas
M. Attorney of Record Antoine L. Freeman, J. D. being fully
committed to this “actual physical constructive fraud”of The
State of Texas Jefferson County Court records and actual physical
constructivefraud in conspireagainst the Rules of Civil
procedures as warrantby Pro Se Plaintiff Motion for sanctions as
Attorney of record actual physicalconstructivefraud for this
causeNo. A-180805 to conspireto do the “Same Scheme of
Crookedthings”in his no less legal “attorney capacity” in and for
the State of Texas on the full benefit package and behalf of the
described Defendant(s) “Joyce M. Guy” and Edward McCray full
legal behalf to achieve wrongfully civil advantages againstthe
Plaintiff to commit continue collectively fraud of courtrecords,
while producing many bald face lie’s beforea Honorable Court
Judge Namely “Judge Bob Wortham”
N. And all of Court records for docketNo. A-180805 with intent of
sleight of hand documentdeception and derailment of the
Plaintiff civil claim completely at that time framedescribed now
again before the 58th
DistrictCourt in Jefferson County Texas
while defendant(s) doing such thievery in the past and now
continue doing the sameby through their acting “legal capacity
status” of Professional“Attorney of Record” Namely Antoine L.

16. Freeman, J. D. Texas Bar No. 24058299. As this Civil Action being
fully investigated and prosecuted by Pro Se Plaintiff herein and
now all evidence of supportare official exhibit(s) and filed within
the “Jefferson County Texas” court records.
V.
The Plaintiff Further State before “The HonorableCourt”,
The defendant(s) as described in Plaintiff exhibit (K) Request for Admission
dated October 14, 2009 supply their collective responsein regards to “Request for
Admission question No. 5 and question No. 6 as follows:
Admit the Defendants herein received $7000 fromtheir home owner
insurancecompany.
RESPONSE: ADMITTED
Admit the Defendant herein forward construction Contractof 10,800 to
their home owner insurancecompany/mortgages company to receive an
additional amountto cover construction differenceamount.
RESPONSE: ADMITTED
The Defendants admitted this was the case involving the Plaintiff and his
construction contractfor $10,800, whileat the same time during discovery hiding
this unknown InsuranceCompany Identity completely frombeing broughtinto
question in this civil matter, as a precise witness in favor of all of The Plaintiff
claims that the defendant squanders $7000.00 fromtheHurricaneclaim of (Rita)
long before the $10,800 Contractof Plaintiff was even introduced to said
insurancecompany
While the Defendant(s) making the actual presentation to said Insurance
Company that more repairs funds was needed, to include that physical
construction repairs had did in fact commence on the home at 448 DeQueen blvd.
in Port Arthur Texas after $7000.00 of repair funds being already forward to said
Defendant(s) for such stormrelated repairs

17. Plaintiff states beforethe Honorable58th
DistrictCourt of Jefferson County
Texas Defendants continue to hide all Insuranceand banking records in regards to
exact amount the Defendants received in repairs funds, exact dates, and what
was spent with the $7000.00firstinstallmentof said InsuranceCompanies repair
funds for very need construction repairs in the year of 2007.
Plaintiff Exhibit (K) is material proof beforethe “HonorableCourt” of the
Plaintiff involvement in this civil matter by the defendants own admission to
exhibit (K), requestfor Admission question 5 and 6
Providing additional fact before “The HonorableCourt examination” of said
Request for Admission that the Defendant(s) collectively knowingly executed and
hatched a plan to conspire, scheme, and deliberation of a intent to commit fraud
AgainstThe Unknown InsuranceCompany” whilemaking the Plaintiff the primary
tool /mark to achieved additional monetary fund’s there after defendants already
having their squandering ways with the first$7000.00funds of Construction
Repair funds.
VI.
The Plaintiff Further State before “The HonorableCourt”,
A hearing was held before The 58th
DistrictCourt on Plaintiff Motion to
Compel Production of Documents and the Court “Ordered that Defendants Joyce
Guy and Edward McCray shall producecopies of deeds, property deeds or any
other such physicaldocument in Defendants’ possession, custodyor controlthat
shows actualownership of the property of the dwelling located at 448 DeQueen
Blvd., Port Arthur, Texas
To include the Court “Ordered further that the Defendants JoyceGuy and
Edward McCray shall producecopies of any and all construction estimates for
repairs in Defendants’ possession, custodyor controlin relationship to damages
caused by Hurricanes Rita, Humberto, and Iketo the property located at 448
Dequeen Blvd. in PortArthur, Texas

18. This Order of the 58th
DistrictCourtwas executed on May 10, 2010 and
fromthat time frameto this very undersigned date the Defendant(s) refuseto
comply with said “CourtOrders” and producesaid discovery Production of
document requestwhile Defendant(s) having the authority to comply with said
Court Orders,
Defendant(s) JoyceGuy and Edward McCray will never ever comply with
any Judicial DistrictCourt Orders within the State of Texas, and this 58th
District
Court of Jefferson County Texas has been proven to be quite beneath the
Defendants Authority, Reach, and quite simply powerless thus far againstsaid
Defendants Joyce Guy and Edward McCray, and their Attorney of the Past
Antoine L. Freeman, J. D. Texas Bar No. 24058299. Andmade to look quite
foolishin being an “Honorable Court”
Even while Defendant(s) werewith a Attorney of record it was His paid
duties to mislead the 58th
DistrictCourt and provide nothing being real Judicial
Evidence in Favor of the Plaintiff that is actual in rendering a real physical
documented responsefrom“JoyceGuy and Edward McCray” and showing their
numerous Fraud activities as described by the Pro Se Plaintiff in the Records
herein of this civil complaint
Plaintiff files 58th
Judicial Court Orders as Plaintiff exhibit (L) herein and
state respectfully before the Honorable58th
DistrictCourt”.
That all required Courtorders of this Honorable 58th
DistrictCourtis very
material in this particular case, and well within the means of the Defendants
abilities to Honor such a Judicial Court Order as they flat out refusing to do so
Defendant(s) collectively in the pastdid submitHurricanedamages
construction contractor’s estimates to their InsuranceCompanies for Hurricanes
Rita, Humberto, and Ikefor the property located at 448 DeQueen blvd. in Port
Arthur, Texas. Just as they did Plaintiff Construction Contract and as admitted in
Plaintiff “Request for Admission” exhibit (K)
As this being a standard practicefor any home owner to submitto their
home owner insurancecompanies construction contractors estimates for

19. Hurricanes related damages to receive funding based upon contractors estimates
and the Defendants refuseto retrieve any Public Records in this regards,
especially with their “InsuranceCompanies” Banking records “notwithstanding
giving up the actual Identity of said “InsuranceCompanies”
Defendant(s) JoyceGuy and Edward McCray collectively are even definite in
not providing any proof of actual ownership of the property in question at 448
DeQueen Blvd. in PortArthur Texas as the Honorable58th
DistrictCourt so Order
said Defendant(s) in doing so in this simple regards.
Contempt of court generally refers toconduct that defies disrespects or
insults the authority or dignity of a court. Often, contempt takes the formof
actions that are seenas detrimental tothe court's ability toadminister justice.
In this case the Defendant(s) Joyce Guy and Edward McCray rely on their
defines of the Honorable Court Orders toreply onthe 58th
District Court of
JeffersonCounty Texas assumedinability toadminister justiceinfavor of the
Plaintiff,
Notwithstanding Defendants Joyce Guy and Edward McCray do not even
began toadhere to this Honorable Court authority/actions, evenwhile being
withtheir Attorney of Recordof the past Antoine L. Freeman, J. D. Texas Bar No.
24058299 now creating one big messy miscarriage of Justice as of this
undersigneddate.
Civil contempt sanctions typically end when the party in contempt complies
with the Courtorder, or when the underlying caseis resolved. And this case has
not been resolved, the actions of the Defendant(s) to defend their acts provides
that a summary judgment is in favor of the Plaintiff and is warrantwith all of the
Plaintiff exhibit(s) in support thereof,
Defendant(s) took the extra civil/criminal steps in hiring a Attorney of Law
to disguisetheir civil case, mislead the HonorableCourt and at all cost bury the
physicalevidence, while misused the Rules of Texas Civil procedureto aid in the
inability of this 58th
DistrictCourt to administer justicein favor of the Plaintiff.

20. Conclusion
The Plaintiff respectfully assertbeforethe Honorable Court that a Summary
Judgment is proper in this case, in favor of the Pr Se Plaintiff Louis Charles
Hamilton II and Defendants “Joyce Guy and Edward McCray”own civil actions
before this HonorableCourt in refusalto comply with Court Orders as described
in Plaintiff exhibit (L) filed herein supportPlaintiff specifically challenge of the
evidentiary supportfor the Plaintiff claims of “Breach of Contract, and Fraud
Which such described documentation will provide beforethe Honorable
Court that Defendant(s) collectively committed to Fraud of the Insurance repair
funds”, and Plaintiff was simply a “useful mark” at the hands of the described
defendants herein pursuit to fraud their InsuranceCompanies outof $10,800.00
dollars while involving the Plaintiff,
As this same typical fraud Scheme of things being committed by the
Defendant(s) in the Past Hurricanerelated damages in which InsuranceFunds
being misused over, and over again for personalgain of the Defendant(s) “Joyce
Guy and Edward McCray”
And not for the designed purposeof fixing their stormdamaged Home.
The actual Breach started before construction started on the Defendants
home and the Plaintiff is entitled to the profits he would have derived fromthe
contract of $10, 800.00
Plaintiff spent $2869.08 dollars in materials to fix said Home with additional
the Plaintiff entire construction tools being confiscated and wrongfully taken
away in this civil mess of the Defendant(s) “Joyce Guy and Edward McCray”and
at the Hands of the described Defendant(s).
Plaintiff PersonalLostin tool(s) $3093.00 dollars, to include Plaintiff brand
New “Hitachi Air Compressor” $680.00 #2700009 purchased @ Lowell’s in “New
Orleans, L.A.” Plaintiff was working during the aftermath of Hurricane(Katrina)
and can provesuch a massivecollection of tools

21. The Defendants (Told) the PortArthur Texas (Police) Dept. that the Plaintiff
has no receipts for his tools and all of his tools are staying on their property of the
Defendant(s), “Joyce Guy and Edward McCray”
“However” the Plaintiff was only allowed to haveback his own
“ConstructionLabtop Computer” that was on the Property of the Defendant(s).
Plaintiff Further state before the HonorableCourtthe Affidavit of the
Defendant (JoyceGuy) dated September 11, 2009 supporta entry of Summary
Judgment in Favor of the Plaintiff (Alone) by the Defendant (JoyceGuy) very own
Sworn statement being Plaintiff exhibit (A)
As Follows: The Defendant (JoyceGuy) Fully awareof a civil action pending
against (Her) and from the date of December 18, 2007 throughoutthe
undersigned date of said exhibit (A) Affidavitof Defendant (JoyceGuy) September
11, 2009 being approximately “OneYear and Nine Months” Defendant having full
knowledgeof Civil suit is in progress as shequite refusalto comply with
discovery” regardless of her hired Gun “Attorney” defendant work to not comply
with any discovery at this time frameas well as a all out refusalof a “Honorable
Court order” being Plaintiff exhibit (L) dated 10th
of May 2010.
Thus bring the Defendant(s) well document actions in refusalto comply
with the local rules of This HonorableDistrict Courtto a total time of Defendant
refusalfromthe issuanceof said Court Order to now a new time frameof “Two
Years and Eight Months” Defendant(s) total disregards for this “Live” Civil action,
and their combine conduct fully dictates and logical, legal, Conclusion that a
Summary Judgmentis warrant, Justand Proper”.
Any further litigation of this civil action is a pure disgraceof the Honorable
58th
District Court times in dealing with such “Hostile” described Defendant(s)
collectively as their combine continue disregard actions for “Court Authority
before the “HonorableCourt” also supportthe Plaintiff Claims made againstthe
Doggeries Acts of Defendant(s) “Joyce Guy and Edward McCray”
Notwithstanding the only way any discover will be obtain fromthese
Defendant(s) is through a Strong Arm

22. “CourtOrder” that the Defendant(s) collectively being placed in Jefferson
County Jail until all such required discover is fully provided to the Plaintiff and the
HonorableCourt Records.
The standard for reviewing a traditional summary judgmentis well
established. See Nixon v. Mr. Prop.
Mgmt. Co., 690 S.W.2d 546, 548 (Tex. 1985); McAfee, Inc. v. Agilysys, Inc., 316
S.W.3d 820, 825 (Tex.
App.-Dallas 2010, no pet.). The movant has the burden of showing that no
genuine issue of material fact
exists and that it is entitled to judgment as a matter of law. Tex. R. Civ. P. 166a(c).
In deciding whether a
disputed material fact issue exists precluding summary judgment, evidence
favorableto the nonmovantwill
be taken as true. Nixon, 690 S.W.2d at548-49; In reEstateof Berry, 280 S.W.3d
478, 480 (Tex. App.-
Dallas 2009, no pet.). Every reasonableinference must be indulged in favor of the
nonmovantand any
doubts resolved in its favor. City of Keller v. Wilson, 168 S.W.3d 802, 824(Tex.
2005). Wereview a
summary judgmentde novo to determine whether a party's rightto prevailis
established as a matter of
law. Dickey v. Club Corp. of Am., 12 S.W.3d 172, 175 (Tex. App.-Dallas 2000, pet.
denied).
Summary judgmentis proper only when a movantestablishes that there is no
genuine issue of material
fact and that the movantis entitled to judgmentas a matter of law. TEX. R. CIV.
P. 166a(c).
A matter-of-law summary judgmentis proper only when the movantestablishes
that there is no genuine
issueof material fact and that the movantis entitled to judgmentas a matter of
law. TEX. R. CIV. P. 166a

23. (c). The motion must state the specific grounds relied upon for summary
judgment. Id.
The standard of review for a traditional summary judgmentis well established: (1)
the movantfor summary
judgmenthas the burden of showing that no genuine issue of material fact exists
and that it is therefore
entitled to summary judgmentas a matter of law; (2) in deciding whether there is
a disputed material fact
issueprecluding summary judgment, evidencefavorableto the nonmovantwill be
taken as true; and (3)
every reasonableinference mustbe indulged in favor of the nonmovantand any
doubts resolved in the
nonmovant’s favor. See, e.g., Nixon v. Mr. Prop. Mgmt. Co., 690 S.W.2d 546,
548–49 (Tex. 1985).
In a traditional motion for summary judgment, the movanthas the burden to
show there is no genuine
issueof material fact and it is entitled to judgmentas a matter of law. Nixon v.
Mr. Prop. Mgmt. Co., 690 S.
W.2d 546, 548 (Tex. 1985). In determining whether there is a genuine fact issue
precluding summary
judgment, evidence favorableto the non-movantis taken as true and the
reviewing court makes all
reasonableinferences and resolves all doubts in the non-movant’s favor. Id. at
548–49. If thereis no
genuine issue of material fact, summary judgmentshould issueas a matter of law.
Haase v. Glazner, 62 S.
W.3d 795, 797 (Tex. 2001). A defendantwho conclusively negates at least one of
the essential elements
of a plaintiff’s cause of action is entitled to a summary judgmenton that claim.
IHS Cedars Treatment Ctr.
of DeSoto, Tex., Inc. v. Mason, 143 S.W.3d 794, 798 (Tex. 2004). Oncea
defendant establishes its right

24. to summary judgment, the burden then shifts to the plaintiff to come forward
with competent controverting
summary judgmentevidence raising a genuine issue of material fact. Centeq
Realty, Inc. v. Siegler, 899 S.
W.2d 195, 197 (Tex. 1995).
To prevail on a traditional summary judgmentmotion, the movant has the burden
of proving that it is
entitled to judgmentas a matter of law and that there areno genuine issues of
material fact. Tex. R. Civ.
P. 166a(c); Cathey v. Booth, 900 S.W.2d 339, 341 (Tex. 1995). Res judicata is an
affirmativedefense.
Tex. R. Civ. P. 94; W. Dow Hamm III Corp. v. Millennium IncomeFund, L.L.C., 237
S.W.3d 745, 755 (Tex.
App.—Houston [1stDist.] 2007, no pet.). A defendant is entitled to summary
judgmentbased upon an
affirmativedefense when the defendant proves all elements of the affirmative
defense. Henry v. Masson,
No. 01-07-00522-CV, 2010 WL 5395640, at*16 (Tex. App.—Houston [1stDist.]
Dec. 31, 2010, no pet.)
(citing Havlen v. McDougall, 22 S.W.3d 343, 345 (Tex. 2000)).
To prevail on a traditional summary judgmentmotion, a movantmust provethat
there is no genuine issue
regarding any material fact and that it is entitled to judgmentas a matter of law.
See TEX. R. CIV. P. 166a
(c); Little v. Tex. Dep’tof Criminal Justice, 148 S.W.3d 374, 381 (Tex. 2004). A
party moving for summary
judgmenton one of its own claims must conclusively proveall essential elements
of the claim. See Rhone-
Poulenc, Inc. v. Steel, 997 S.W.2d 217, 223(Tex. 1999). A defendantmay also
prevail by traditional
summary judgmentif it conclusively negates at least one essential element of a

25. plaintiff’s claim or
conclusively proves an affirmative defense. See IHS Cedars Treatment Ctr. of
DeSoto, Tex., Inc. v.
Mason, 143 S.W.3d 794, 798(Tex. 2004). A movantseeking traditional summary
judgmenton an
affirmativedefense has the initial burden of establishing its entitlement to
judgmentas a matter of law by
conclusively establishing each element of its affirmativedefense. See Chau v.
Riddle, 254 S.W.3d 453,
455 (Tex. 2008) (per curiam); seealso TEX. R. CIV. P. 166a(b)–(c). A matter is
conclusively established if
reasonablepeople could not differ as to the conclusion to be drawn fromthe
evidence. See City of Keller
v. Wilson, 168 S.W.3d 802, 816 (Tex. 2005).
If the movant meets its burden, the burden then shifts to the nonmovantto raise
a genuine issue of
material fact precluding summary judgment. See Centeq Realty, Inc. v. Siegler,
899 S.W.2d 195, 197
(Tex. 1995). Theevidence raises a genuine issueof fact if reasonableand fair-
minded jurors could differ
in their conclusions in light of all of the summary-judgmentevidence. See
Goodyear Tire & Rubber Co. v.
Mayes, 236 S.W.3d 754, 755(Tex. 2007) (per curiam).
NO-EVIDENCE MOTION FOR SUMMARY JUDGMENT - TRCP
166a(i)
After adequate time for discovery, a party withoutthe burden of proof at trial
may movefor summary
judgmenton the ground that there is no evidence of one or more essential
elements of a claim or
defense. See Tex. R. Civ. P. 166a(i). Wereview the granting of a motion for no-
evidence summary

26. judgmentunder the same legal sufficiency standard used to review a directed
verdict. King Ranch, Inc.
v. Chapman, 118 S.W.3d 742, 750-51 (Tex. 2003); Ogg v. Dillard's, Inc., 239 S.W.3d
409, 416 (Tex.
App.-Dallas 2007, pet. denied). Our inquiry focuses on whether the nonmovant
produced more than a
scintilla of probative evidence to raise a fact issueon the challenged elements.
King Ranch, Inc., 118 S.
W.3d at 751. Evidence is no more than a scintilla if it is "so weak as to do no more
than create a mere
surmiseor suspicion" of a fact. Id. Where, as here, the trial court's order granting
summary judgment
does not specify the grounds upon which it was granted, we will affirm the
judgmentif any of the theories
advanced are meritorious. See ProvidentLife & Acc. Ins. Co. v. Knott, 128 S.W.3d
211, 216 (Tex. 2003);
Kastner v. Jenkens & Gilchrist, P.C., 231 S.W.3d 571, 577(Tex. App.-Dallas 2007,
no pet.).
A no-evidence summary judgmentmotion under Rule 166a(i) is essentially a
motion for a
pretrial directed verdict; it requires the nonmoving party to presentevidence
raising a genuine
issueof material fact supporting each element contested in the motion. Tex. R.
Civ. P. 166a(i);
Mack Trucks, Inc. v. Tamez, 206 S.W.3d 572, 581-82 (Tex. 2006).
STANDARD OF REVIEWON APPEAL. When reviewing a no-evidence summary
judgment,
we “review the evidence presented by the motion and responsein the light most
favorableto the
party against whomthe summary judgmentwas rendered, crediting evidence
favorableto that

27. party if reasonable jurors could, and disregarding contrary evidenceunless
reasonablejurors
could not.” Mack Trucks, 206 S.W.3d at582 (citing City of Keller v. Wilson, 168
S.W.3d 802,
827 (Tex. 2005); Johnson v. Brewer & Pritchard, P.C., 73 S.W.3d 193, 208(Tex.
2002)).
MUST STATE ON WHICH ELEMENTTHERE IS NO EVIDENCE. Itis well settled that a
trial
court cannotgrant a summary judgmentmotion on grounds notpresented in the
motion. Brewer
& Pritchard, P.C., 73 S.W.3d at204; Science Spectrum, Inc. v. Martinez, 941
S.W.2d 910, 912
(Tex. 1997). Our no-evidencesummary judgmentrulesimilarly requires that the
moving party
identify the grounds for the motion:
After adequate time for discovery, a party withoutpresenting summary judgment
evidence may
move for summary judgmenton the ground that there is no evidence of one or
more essential
elements of a claim or defenseon which an adverseparty would have the burden
of proof at trial
1.
Wherefore Pro SePlaintiff Louis Charles Hamilton II herein Docket
No. A-180805, filed and Respectfully Moves before the Honorable58th
District Courtof Jefferson County Texas His “HonorableCourt” except,
Plaintiff motion for Traditional Summary with all exhibit(s) A-1, and A-L,
Exhibit (A-1) Construction Contractof the Plaintiff
Exhibit (A) Affidavit of Defendant(Joyce Guy)

28. Exhibit (B) Responseto Plaintiff’s Motion for Sanctions by: Attorney of
record Antoine L. Freeman, J.D. Texas Bar No. 24058299 3723
Exhibit (C) Motion for Withdrawalof Counsel
Exhibit (D) *Parker Lumber In PortArthur Texas 2948 GulfWay Drivefor the
delivery of $2869.08 dollars in building materials
Exhibit (E) January 11th
, 2010 attached letterfrom Texas Department of
Aging and Disability Services, to Plaintiff
Exhibit (F) * CertifiedMail:7003 1010 0003 6838 1858 “State of Texas”
Department of Aging and Disability Services,
Exhibit(G) County Clerk’s Office Assumed
Exhibit (H) Social Security DeathIndex Search
Exhibit (I) Plaintiff FirstSet of “Interrogatories”
Exhibit (J) Plaintiff requestfor DisclosurePursuantto rule 194
Exhibit (K) Plaintiff Request for Admissions propounded by Louis Charles
Hamilton II Pro SePlaintiff herein pursuantto rule 198 of the Texas Rules of
Civil Procedure.
Exhibit (L) Order of the 58th
DistrictCourt was executed on May 10, 2010
Being filed with the Clerk of Court Records of Jefferson County Texas, and
The Honorable Courtfurther being mostfavorableto the Pr Se Plaintiff claims as
presented and supported, and the HonorableCourt Being of the opinion Plaintiff
Motion is with “merit” and should be granted into the Court Records.
2.
Wherefore Pro SePlaintiff Louis Charles Hamilton II herein DocketNo. A-
180805, Further Respectfully Moves theHonorable58th
DistrictCourt of Jefferson
County Texas His “HonorableCourt” Plaintiff recovery damages for wrongful lost

29. of tools in excess of $3093.00dollars with full 6% interest rate incurred since date
of injury from November 16th
2007
3.
Wherefore Pro SePlaintiff Louis Charles Hamilton II herein Docket No. A-
180805, Further Respectfully Moves theHonorable58th
DistrictCourt of Jefferson
County Texas His “HonorableCourt” Plaintiff recovery damages for “Breach of
Contract” at the rate of ProfitPlaintiff would have incurred,
Said being “Breach of Contract” incurred before any construction was
started “However” Plaintiff purchased $2869.08 dollars in building materials as
described in Plaintiff exhibit (D) to repair said home at 448 Dequeen Blvd. in Port
Arthur Texas which the Plaintiff is entitled to $7931.00 dollars subtracted from
the $10,800.00dollars Contractbeing Profit.
4.
Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves The
HonorableCourt for said damages and Profitof $7931.00dollars with full 6%
interest rate incurred sincedate of injury November 16th
2007
5.
Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves The
HonorableCourt for damages in the amount of the Honorable CourtJustice for
the Plaintiff suffrageof “Intentional Inflictionof Emotional distress,
“Loss of earning capacity and Hardship”incurred in the “Theft” of the
Plaintiff Construction tools”, and extreme Judicial Awards further being granted
to the Plaintiff “Louis Charles Hamilton II for “Exemplary Damages”being well
enforced by this “HonorableCourt” against said Defendant(s) “Joyce Guy” and
Edward McCray”for their combine extreme, dishonest, hostile, corrupted,
actions, directed at the Plaintiff herein’, andhis personal property andassault
upon the Plaintiff.
To include but not limited” to Defendant “Joyce Guy and Edward McCray”

30. Fraud of the InsuranceCompany schemeof things involving Pro Se Plaintiff
$10,800.00 dollars construction contractin an “Exemplary Damages” respectfully
set by this Honorable Court with full 6% interest rate incurred since date of injury
November 16th
2007
6.
Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves The
HonorableCourt that Defendant(s) “Joyce Guy and Edward McCray” pay the
amount of “Actual Damages” tothe Plaintiff in the Amount of $11,024.00 with
full 6% interest rate incurred since date of injury November 16th
2007
To include Defendant(s) paying all filing fees andall “Court Cost”incurred
in this Civil Matter.
7.
Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves The
HonorableCourt to grant the Plaintiff attached joining motion filed herein with
good “Merit” to have the “Long Arm of The Law” Namely
8.
“The JeffersonCounty Sherriff’s Office”to fully enforce and place a
“Property Lien” on the described Property of 448 DeQueenBlvd. inPort Arthur
Texas, in favor of the Pro Se Plaintiff herein Louis Charles HamiltonII which
Defendant(s) “Joyce Guy and Edward McCray”
Was so Order By This Honorable58th
DistrictCourtof Jefferson County
Texas to producecopies of deeds, property deeds or any other such physical
document in Defendants’ possession, custodyor controlthat shows actual
ownership of the property of the dwelling located at 448 DeQueenBlvd., and
fully failing to adhere to an HonorableCourtOrder.
As described in Plaintiff Exhibit (L) attached herein.

31. Further providing The “Honorable58th
Judicial Court” a secured Judicial
Honestbiting well deserved Judgment being rendered in this quite seriously civil
matter of the collectively Defendant(s) namely “Joyce Guy and Edward McCray”
ill manner back woods buck wild country state of extreme,
“Hostile and Fraudulent”actions being most favorableto the “Laws of the
State of Texas”,
Most favorableto the Pro Se Plaintiff Civil Rights, Damages and
Compensation as described fully in the records herein this Civil Action.
9.
Wherefore Pro SePlaintiff Louis Charles Hamilton II Respectfully Moves The
HonorableCourt for any further, Just, proper, Damages and Awards The
HonorableCourt Deems Judicial in and For 58th
DistrictCourt of Jefferson County
Texas in Favor of The Pro Se Plaintiff herein.
By,_______________________________
Louis Charles Hamilton II
Pro Se Plaintiff
P.O. Box 17524
Sugar Land Texas 77496