No. A-180805

Louis Charles Hamilton II 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 the Pro Se Plaintiff,

Louis Charles Hamilton II,

Motion before the Honorable Court,

For a “Final Summary Judgment” in this matter, in full favor of the

described Pro Se Plaintiff herein.

The Plaintiff further move the Court to find just cause for a finding of fact’s,

and conclusion of Law after proper examine of all of the files, records, exhibits,

now here before the Honorable Court.

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 Response of the Defendants “Joyce Guy & Edward McCray”

Motion in Opposition, and all other records filed by the defendants collectively

To include the existence of outrageous conduct of physical harm upon the

Plaintiff person By the Defendant Edward McCray

Considered and Established Conclusively,

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, Assert and Respectfully Submit “No genuine issue of

“Material Facts” exist, and quite “clean-cut”, and “clear” on Legal Principles in

Favor on The Plaintiff

Plaintiff Further Move before The Honorable Court He be Award all

damages in full under “Breach of Contract” precisely after examine before the

Honorable Court’, 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 contract for the “Home Improvements” fully

described therein

Plaintiff Moves the Honorable Court after the said hearing Now Being held

on December 17, 2014 8:30 am Before the Honorable 58th 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 Construction Tools” wrongfully taken from the 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 from date of injury” namely

past date of November 16, 2007

Pro Se Plaintiff, herein file before the Honorable 58th District Court Plaintiff

Exhibit (A, B, and C) in Support of Plaintiff Motion for final Judgment,

Affidavit of Defendant (Joyce Guy) exhibit (A) and Response to Plaintiff’s

Motion for Sanctions by: Attorney of record Antoine L. Freeman, J.D. Texas Bar

No. 24058299 3723 Gulfway Dr. Ste. #104 Port Arthur Texas 77642 (Attorney for

the Defendant) exhibit (B) and Motion for Withdrawal of Counsel exhibit (C)

Plaintiff Moves the Honorable Court’ to take “Judicial Notice” to the

following Real facts:

1. The Plaintiff Discovery request in the case was well legally pursued for

all Important Material facts to support Plaintiff 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 at which the Attorney of

Record Claim in a legal reply “no less” his only Legal obligation to this

civil case A-180805 was to draft a (Simple) General denial on behalf of

the Defendants filed on December 18th 2007 and at that point his

“Fiduciary Duty” to his clients and before the Court ended on that date

December 18th 2007 and was legally completely over, no matter to the

simple facts Antoine L. Freeman, J.D. (Attorney at Law) been sitting on

this case from date of December 18th 2007 when this Attorney of Record

in Jefferson County Texas 58th District Court as such to avoid a default

file his original Answer, accept payment to 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

phase process 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 request sought” in this matter as sought to support the

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 withdrawal as Attorney of Record on November 13 2009,

almost Two (2) entire full years in his grand funk refusal of the rules of

Civil procedure in such Sought discovery request”. Claiming in said

Motion to with draw at this time in 2009 “Defendants” have not

complied with the terms of the employment agreement with this

Attorney” Filed herein as Plaintiff exhibit (C). while the Defendant

Affidavit exhibit (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, while this action was filed on the 26th

day of November 2007 “Your Honor”

2. “However” Counsel of Record while knowing fully as acting Counsel of

Record in April 2, 2008 such a discovery phase was needed and in

process by Plaintiff to Pursue and move a civil legal presentation before

the Honorable 58th District Court”, and from that said date of April 2nd

2008 date Now till November 13th 2009 (One Year, 7 months) further

throughout Counsel of Record “Defendants” collectively have not

complied with the terms of the employment agreement with 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 subject matter of the pending action. It is

not grounds for objection that the information would be inadmissible at

Trial if it appears reasonably calculated to lead to the discovery of

admissible evidence.

Plaintiff Assert before the Honorable Court “Formal Written

Discovery Request were in fact filed with Attorney of Record Antoine L.

Freeman, J.D. Texas Bar No. 24058299 3723 and what little was obtain also

filed here in as Exhibit(s) before the Court Records.

Plaintiff Support further Before “The Honorable Court” that the

Defendants knowingly collectively did enter into a Contract for

Construction following Hurricane damages 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.

Plaintiff further support fact’s and real life sound Evidence before the

Honorable Court Plaintiff Exhibit (D) *Parker Lumber In Port Arthur Texas

2948 GulfWay Drive for the delivery of $2869.08 dollars in building

materials as described therein Plaintiff Exhibit (D) and was in fact in the

Custody, Control and Possession by the defendant 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 from the Contract amount of $10,850.00

Plaintiff further submit the Defendant(s) confiscated new tool,

brought to completely in a Professional manner as well as the Defendant

confiscated all of the Plaintiff entire Contract supply of tool from everything

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 assert before The Honorable Court Profit in the Amount of

$7981.00 dollars 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 substantial amount, leading to the doggeries

theft of said tools by the Defendants for wrongful criminal and Civil gain.

The Plaintiff Further state before The Honorable Court, The Defendant(s)

devised a scheme of things to Fraud the Insurance Company of the Moneys need

for the repairs of this said home in that “Defendant(s) collectively

All ready spend the first Insurance Installment paid by Third Party Insurance

Company and Defendant(s) refusal to identify such Insurance Company for these

court proceedings, through counsel of record (Antoine L. Freeman J.D. Attorney at

Law) from time of his notice of Counsel for the Defendant in 2007-2009 on Record

While Both Defendant(s) collectively fully committed to the same refusal on

there “among other things” sign Affidavit,

And there continue action up to date before this Honorable Court as of this

Undersign Date”.

Which “Joyce Guy” and “Edward McCray” connive to 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 Honorable Court”,

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- personal care

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

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) * Certified Mail: 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 Se Plaintiff was on his cell phone with the State of

Texas” Investigator” reveal badge as arrival upon said Defendant “Joyce

Guy” whom was 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) above with Plaintiff Exhibit (E)

and (F) filed herein for support,

D. Plaintiff files Exhibit(G) County Clerk’s Office Assumed Names

Defendant “Bogus” Company and proof of date Company been in

operation over 13 years’, No valid State of Texas documentations for

working with Elderly , No assumed tax records ever, while making

large incomes from said Business in the 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 past his “Death”, Ulyess Guy Sr.” Birth

December 22, 1926 *Death November 20 2003 as described in Plaintiff

Exhibit (H) filed herein before “The Honorable Court”.

F. * Plaintiff exhibit (H) Social Security Death Index 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 Honorable Court”,

The Defendant was served a First Set of “Interrogatories” in this action,

Pursuant to 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) What was all of the terms and conditions of said contract in regards to

repairs to the home located 448 Dequeen blvd. in Port Arthur, Texas

Answer

Plaintiff would repair damages done by Hurricane for a total price of

$10,800 and Defendant would put $3,616 down towards the total price.

(25) Was the Contract forward to any insurance companies for payment to

cover said construction cost?

Answer

Yes

The Plaintiff fully direct the Honorable Court attention to these facts

1. Defendant (Already) in facts received from said “Unknown Insurance”

company in excess of approximately $6,500 dollars to fix said home

and this money was squander and spent up from their Banking

saving/checking account quite very long before The Defendants even

enter into said Construction Contract with Plaintiff on 11/05/2007

Defendants were served Pursuant to Rule 194 Texas Rules of Civil

Procedure. By and through their Attorney of Record Plaintiff request for

Disclosure which 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”

was even served upon the Defendant(s) and Filed Now as Plaintiff Exhibit (J)

herein Plaintiff request for Disclosure Pursuant to rule 194

Defendant(s) did in fact received from this “Unknown Insurance Company”

a balance of Monetary Funds in addition from what already was forwards to said

Defendant(s) based upon the Plaintiff “Construction Contract” of $10,800.00,

Which the Defendants further supply and combine their “twisted scheme

of things” was to physically use the 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 More Monies

in addition to the amount already received from said “Unknown Insurance

Company” for repairs as being described now before the Honorable Court in

PLAINTIFF MOTION FOR FINAL SUMMARY JUDGMENT,

Notwithstanding “Facts” to the “Honorable Court”

“Yours Honor”

Never Ever, Ever, Was Any Actual Monies ever being spent on any Actual

Physical Construction Repairs from any described storm damages in the past by

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,

From any Hurricane damages 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 “Crooked Scheme of Things” was in fact executed more than

once by the Defendants collectively in the past from another 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” against another such Building Construction Contractor for (Rita)

storm damages…

And as this same “Crooked Scheme 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 (Norma J. Guy) whom

Defendant (Joyce Guy) had power of Attorney over her mother legal affairs at

this time frame and used this to “Her” continued wrongful crooked advantages

To include such a “bogus rip off scheme of things” by the Defendant(s)

collectively against all Hurricane damages of both said homes and “Unknown

Insurance Companies” which moneys was in fact paid out for all needed repairs in

full in the past storm history, and defendants completely civil/criminally squander

every nickel in a “Long History “ of “thievery” Scheme of 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

personal property (Construction tools),

And The Insurance Company, and FEMA, in which the Defendant “Home”

At 448 Dequeen Blvd. in Port Arthur 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 Dequeen Blvd. in Port Arthur Texas

As The Plaintiff States now Before “The Honorable Court” facts that a New

Home being built at the cost of $76,000.00 on a Federal Grant.

As described in Plaintiff exhibit (I) First Set of “Interrogatories” in this

action, question(s) 7-12

On Defendants collectively long continue corrupted history road of scams,

rip off’s, thievery acts, as described herein fully being executed by Both

Defendant Collectively.

All building materials as being described herein Plaintiff Exhibit (E) *Parker

Lumber In Port Arthur Texas 2948 GulfWay Drive for the delivery of $2869.08

dollars in building materials for repairs to said 448 Dequeen home that was in

fact delivery was refunded and or sold, And not for any benefit of the said home

storm damages but pure wrongful monetary Defendant(s) collectively financial

gains.

V.

The Plaintiff Further State before “The Honorable Court”,

“The Defendant(s) By and through their Attorney of record Antoine L.

Freeman, J.D. Texas Bar No. 24058299 was in fact served Plaintiff Request for

Admissions propounded by Louis Charles Hamilton II Pro Se Plaintiff herein

pursuant to rule 198 of the Texas Rules of Civil Procedure.

Filed herein as Plaintiff exhibit (K) before the “Honorable Court”.

Providing, and legally well documented additional proof with all of the court

records, exhibit(s) and files herein cause No. A-180805

Thus 100% Proving the Following official legal material facts before any

“Honorable Court” of Law in and for The State of Texas as follows:

1. Attorney of Record Antoine L. Freeman, J. D. Texas Bar No. 24058299 was

in fact full acting Attorney of record from dates of filing a General Denial

December 18th 2007 as he claim 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 at this point the Plaintiff point out further that Attorney

of record made a illegal bogus claim before The Honorable Judge “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 request Defendant’s Attorney had not

been retain by Defendants to represent their interest with regard to this

lawsuit, Defendant, Joyce Guy, retain the services of Antoine Freeman for

the purpose of writing a general denial so as to avoid default judgment

being rendered against her.

4. The Honorable Court 58th District Court Judge Bob Wortham” 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 against said Attorney of record Antoine L. Freeman, J.

D. Texas Bar No. 24058299 in official court docket No. A-180805 records

when all of Plaintiff evidence filed herein support that 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

knowledge of such a discovery request was being pursued by the Pro Se

Plaintiff

A. Attorney of Record Antoine L. Freeman, J. D. Was acting with

physical fiduciary capacities as an Attorney of Law for the State of

Texas Bar. No. 24058299 on or about December 18th 2007 and

continue doing the same legal 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 District Jefferson County Honorable Court 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 support the Plaintiff cause for

sanctions against said Attorney Antoine L. Freeman, J. D. the

Plaintiff exhibit (A) Affidavit of Defendant “Joyce M. Guy” dated

September 11, 2009 to support another bogus Defendant claim

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 knowledge of such a discovery

request being in place, and pursued from December 18th 2007

throughout October 14, 2009

D. Attorney of Records Antoine L. Freeman, J. D. maintain his only

duties was Just filing a “General Denial” before the Honorable

58th District Court Judge “Bob Wortham” as his Attorney of record

signature and 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 on December 18th 2007

E. Namely official Court discovery documents devise in the form of

“Request for Admissions” pursuant to Rule 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 the Pro Se Plaintiff was in

pursuit of 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 against said

Attorney Claims he was only acting in December 18th 2007

F. As this Rouge Attorney did aid in criminally stalling against the

Rules of Civil Procedures tactics with full payment to doing such

actions by said defendant(s) to achieve this lawless civil act

against the Pro Se Plaintiff rights to a Just cause of 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

from this case dated November 13th 2009, after 2 years being the

official acting Attorney of record but claiming, and representing

before the Honorable 58th District Court Judge “Bob Wortham”

that this was not the legal case at hand in court records 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.

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

throughout the years of 2007, 2008 and October of 2009, up to

the actual date of November 13th 2009 but previously made

claims before the Honorable 58th District Court Judge “Bob

Wortham” in Plaintiff exhibit (B) *Response to Plaintiff’s Motion

for Sanctions dated 11th of September of 2009 his only “Attorney

duties” was to Draft and file a general denial on December 18th

2007 in his Attorney capacities at this time frame with payment

for such as a Attorney of Law for the State of Texas Bar. No.

24058299 on or about December 18th 2007 such general denial

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 professional degree

representation before the “Honorable 58th District Court 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 Hurricane Damages funds at 3 counts,

Fraud on Insurance Monies at 3 counts, and Fraud of FEMA at 1

count, while further aiding through the Court discovery 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 before the Honorable

Court against the described Defendant(s)

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 to October 14, 2009 as described by all of the Plaintiff

Exhibit(s) (I) and (K) “Request for Admissions” pursuant to Rule

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 and there

(Now) official filing herein this undersigned date before the

Honorable 58th 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

constructive fraud in conspire against the Rules of Civil

procedures as warrant by Pro Se Plaintiff Motion for sanctions as

Attorney of record actual physical constructive fraud for this

cause No. A-180805 to conspire to do the “Same Scheme of

Crooked things” 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 against the

Plaintiff to commit continue collectively fraud of court records,

while producing many bald face lie’s before a Honorable Court

Judge Namely “Judge Bob Wortham”

N. And all of Court records for docket No. A-180805 with intent of

sleight of hand document deception and derailment of the

Plaintiff civil claim completely at that time frame described now

again before the 58th District Court in Jefferson County Texas

while defendant(s) doing such thievery in the past and now

continue doing the same by through their acting “legal capacity

status” of Professional “Attorney of Record” Namely Antoine L.

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 support are official exhibit(s) and filed within

the “Jefferson County Texas” court records.

V.

The Plaintiff Further State before “The Honorable Court”,

The defendant(s) as described in Plaintiff exhibit (K) Request for Admission

dated October 14, 2009 supply their collective response in regards to “Request for

Admission question No. 5 and question No. 6 as follows:

Admit the Defendants herein received $7000 from their home owner

insurance company.

RESPONSE: ADMITTED

Admit the Defendant herein forward construction Contract of 10,800 to

their home owner insurance company/mortgages company to receive an

additional amount to cover construction difference amount.

RESPONSE: ADMITTED

The Defendants admitted this was the case involving the Plaintiff and his

construction contract for $10,800, while at the same time during discovery hiding

this unknown Insurance Company Identity completely from being brought into

question in this civil matter, as a precise witness in favor of all of The Plaintiff

claims that the defendant squanders $7000.00 from the Hurricane claim of (Rita)

long before the $10,800 Contract of Plaintiff was even introduced to said

insurance company

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 storm related repairs

Plaintiff states before the Honorable 58th District Court of Jefferson County

Texas Defendants continue to hide all Insurance and banking records in regards to

exact amount the Defendants received in repairs funds, exact dates, and what

was spent with the $7000.00 first installment of said Insurance Companies repair

funds for very need construction repairs in the year of 2007.

Plaintiff Exhibit (K) is material proof before the “Honorable Court” of the

Plaintiff involvement in this civil matter by the defendants own admission to

exhibit (K), request for Admission question 5 and 6

Providing additional fact before “The Honorable Court 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

Against The Unknown Insurance Company” while making the Plaintiff the primary

tool /mark to achieved additional monetary fund’s there after defendants already

having their squandering ways with the first $7000.00 funds of Construction

Repair funds.

VI.

The Plaintiff Further State before “The Honorable Court”,

A hearing was held before The 58th District Court on Plaintiff Motion to

Compel Production of Documents and the Court “Ordered that Defendants Joyce

Guy and Edward McCray shall produce copies of deeds, property deeds or any

other such physical document in Defendants’ possession, custody or control that

shows actual ownership of the property of the dwelling located at 448 DeQueen

Blvd., Port Arthur, Texas

To include the Court “Ordered further that the Defendants Joyce Guy and

Edward McCray shall produce copies of any and all construction estimates for

repairs in Defendants’ possession, custody or control in relationship to damages

caused by Hurricanes Rita, Humberto, and Ike to the property located at 448

Dequeen Blvd. in Port Arthur, Texas

This Order of the 58th District Court was executed on May 10, 2010 and

from that time frame to this very undersigned date the Defendant(s) refuse to

comply with said “Court Orders” and produce said discovery Production of

document request while Defendant(s) having the authority to comply with said

Court Orders,

Defendant(s) Joyce Guy and Edward McCray will never ever comply with

any Judicial District Court Orders within the State of Texas, and this 58 th District

Court of Jefferson County Texas has been proven to be quite beneath the

Defendants Authority, Reach, and quite simply powerless thus far against said

Defendants Joyce Guy and Edward McCray, and their Attorney of the Past

Antoine L. Freeman, J. D. Texas Bar No. 24058299. And made to look quite

foolish in being an “Honorable Court”

Even while Defendant(s) were with a Attorney of record it was His paid

duties to mislead the 58th District Court and provide nothing being real Judicial

Evidence in Favor of the Plaintiff that is actual in rendering a real physical

documented response from “Joyce Guy 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 Honorable 58th District Court”.

That all required Court orders of this Honorable 58th District Court is 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 past did submit Hurricane damages

construction contractor’s estimates to their Insurance Companies for Hurricanes

Rita, Humberto, and Ike for 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 practice for any home owner to submit to their

home owner insurance companies construction contractors estimates for

Hurricanes related damages to receive funding based upon contractors estimates

and the Defendants refuse to retrieve any Public Records in this regards,

especially with their “Insurance Companies” Banking records “notwithstanding

giving up the actual Identity of said “Insurance Companies”

Defendant(s) Joyce Guy 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 Port Arthur Texas as the Honorable 58th District Court so Order

said Defendant(s) in doing so in this simple regards.

Contempt of court generally refers to conduct that defies disrespects or

insults the authority or dignity of a court. Often, contempt takes the form of

actions that are seen as detrimental to the court's ability to administer justice.

In this case the Defendant(s) Joyce Guy and Edward McCray rely on their

defines of the Honorable Court Orders to reply on the 58 th District Court of

Jefferson County Texas assumed inability to administer justice in favor of the

Plaintiff,

Notwithstanding Defendants Joyce Guy and Edward McCray do not even

began to adhere to this Honorable Court authority/actions, even while being

with their Attorney of Record of the past Antoine L. Freeman, J. D. Texas Bar No.

24058299 now creating one big messy miscarriage of Justice as of this

undersigned date.

Civil contempt sanctions typically end when the party in contempt complies

with the Court order, or when the underlying case is 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 warrant with all of the

Plaintiff exhibit(s) in support thereof,

Defendant(s) took the extra civil/criminal steps in hiring a Attorney of Law

to disguise their civil case, mislead the Honorable Court and at all cost bury the

physical evidence, while misused the Rules of Texas Civil procedure to aid in the

inability of this 58th District Court to administer justice in favor of the Plaintiff.

Conclusion

The Plaintiff respectfully assert before the 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 Honorable Court in refusal to comply with Court Orders as described

in Plaintiff exhibit (L) filed herein support Plaintiff specifically challenge of the

evidentiary support for the Plaintiff claims of “Breach of Contract, and Fraud

Which such described documentation will provide before the 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 Insurance Companies out of $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 Hurricane related damages in which Insurance Funds

being misused over, and over again for personal gain of the Defendant(s) “Joyce

Guy and Edward McCray”

And not for the designed purpose of fixing their storm damaged Home.

The actual Breach started before construction started on the Defendants

home and the Plaintiff is entitled to the profits he would have derived from the

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 Personal Lost in 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 prove such a massive collection of tools

The Defendants (Told) the Port Arthur 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 have back his own

“Construction Lab top Computer” that was on the Property of the Defendant(s).

Plaintiff Further state before the Honorable Court the Affidavit of the

Defendant (Joyce Guy) dated September 11, 2009 support a entry of Summary

Judgment in Favor of the Plaintiff (Alone) by the Defendant (Joyce Guy) very own

Sworn statement being Plaintiff exhibit (A)

As Follows: The Defendant (Joyce Guy) Fully aware of a civil action pending

against (Her) and from the date of December 18, 2007 throughout the

undersigned date of said exhibit (A) Affidavit of Defendant (Joyce Guy) September

11, 2009 being approximately “One Year and Nine Months” Defendant having full

knowledge of Civil suit is in progress as she quite refusal to comply with

discovery” regardless of her hired Gun “Attorney” defendant work to not comply

with any discovery at this time frame as well as a all out refusal of a “Honorable

Court order” being Plaintiff exhibit (L) dated 10th of May 2010.

Thus bring the Defendant(s) well document actions in refusal to comply

with the local rules of This Honorable District Court to a total time of Defendant

refusal from the issuance of said Court Order to now a new time frame of “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 Judgment is warrant, Just and Proper”.

Any further litigation of this civil action is a pure disgrace of 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 “Honorable Court” also support the Plaintiff Claims made against the

Doggeries Acts of Defendant(s) “Joyce Guy and Edward McCray”

Notwithstanding the only way any discover will be obtain from these

Defendant(s) is through a Strong Arm

“Court Order” that the Defendant(s) collectively being placed in Jefferson

County Jail until all such required discover is fully provided to the Plaintiff and the

Honorable Court Records.

The standard for reviewing a traditional summary judgment is 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

favorable to the nonmovant will

be taken as true. Nixon, 690 S.W.2d at 548-49; In re Estate of Berry, 280 S.W.3d

478, 480 (Tex. App.-

Dallas 2009, no pet.). Every reasonable inference must be indulged in favor of the

nonmovant and any

doubts resolved in its favor. City of Keller v. Wilson, 168 S.W.3d 802, 824 (Tex.

2005). We review a

summary judgment de novo to determine whether a party's right to prevail is

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 judgment is proper only when a movant establishes that there is no

genuine issue of material

fact and that the movant is entitled to judgment as a matter of law. TEX. R. CIV.

P. 166a(c).

A matter-of-law summary judgment is proper only when the movant establishes

that there is no genuine

issue of material fact and that the movant is entitled to judgment as a matter of

law. TEX. R. CIV. P. 166a

(c). The motion must state the specific grounds relied upon for summary

judgment. Id.

The standard of review for a traditional summary judgment is well established: (1)

the movant for summary

judgment has the burden of showing that no genuine issue of material fact exists

and that it is therefore

entitled to summary judgment as a matter of law; (2) in deciding whether there is

a disputed material fact

issue precluding summary judgment, evidence favorable to the nonmovant will be

taken as true; and (3)

every reasonable inference must be indulged in favor of the nonmovant and 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 movant has the burden to

show there is no genuine

issue of material fact and it is entitled to judgment as 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 favorable to the non-movant is taken as true and the

reviewing court makes all

reasonable inferences and resolves all doubts in the non-movant’s favor. Id. at

548–49. If there is no

genuine issue of material fact, summary judgment should issue as a matter of law.

Haase v. Glazner, 62 S.

W.3d 795, 797 (Tex. 2001). A defendant who conclusively negates at least one of

the essential elements

of a plaintiff’s cause of action is entitled to a summary judgment on that claim.

IHS Cedars Treatment Ctr.

of DeSoto, Tex., Inc. v. Mason, 143 S.W.3d 794, 798 (Tex. 2004). Once a

defendant establishes its right

to summary judgment, the burden then shifts to the plaintiff to come forward

with competent controverting

summary judgment evidence 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 judgment motion, the movant has the burden

of proving that it is

entitled to judgment as a matter of law and that there are no 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

affirmative defense.

Tex. R. Civ. P. 94; W. Dow Hamm III Corp. v. Millennium Income Fund, L.L.C., 237

S.W.3d 745, 755 (Tex.

App.—Houston [1st Dist.] 2007, no pet.). A defendant is entitled to summary

judgment based upon an

affirmative defense 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 [1st Dist.]

Dec. 31, 2010, no pet.)

(citing Havlen v. McDougall, 22 S.W.3d 343, 345 (Tex. 2000)).

To prevail on a traditional summary judgment motion, a movant must prove that

there is no genuine issue

regarding any material fact and that it is entitled to judgment as a matter of law.

See TEX. R. CIV. P. 166a

(c); Little v. Tex. Dep’t of Criminal Justice, 148 S.W.3d 374, 381 (Tex. 2004). A

party moving for summary

judgment on one of its own claims must conclusively prove all essential elements

of the claim. See Rhone-

Poulenc, Inc. v. Steel, 997 S.W.2d 217, 223 (Tex. 1999). A defendant may also

prevail by traditional

summary judgment if it conclusively negates at least one essential element of a

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 movant seeking traditional summary

judgment on an

affirmative defense has the initial burden of establishing its entitlement to

judgment as a matter of law by

conclusively establishing each element of its affirmative defense. See Chau v.

Riddle, 254 S.W.3d 453,

455 (Tex. 2008) (per curiam); see also TEX. R. CIV. P. 166a(b)–(c). A matter is

conclusively established if

reasonable people could not differ as to the conclusion to be drawn from the

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 nonmovant to raise

a genuine issue of

material fact precluding summary judgment. See Centeq Realty, Inc. v. Siegler,

899 S.W.2d 195, 197

(Tex. 1995). The evidence raises a genuine issue of fact if reasonable and fair-

minded jurors could differ

in their conclusions in light of all of the summary-judgment evidence. 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 without the burden of proof at trial

may move for summary

judgment on 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). We review the granting of a motion for no-

evidence summary

judgment under 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 issue on 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

surmise or 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

judgment if any of the theories

advanced are meritorious. See Provident Life & 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 judgment motion under Rule 166a(i) is essentially a

motion for a

pretrial directed verdict; it requires the nonmoving party to present evidence

raising a genuine

issue of 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 REVIEW ON APPEAL. When reviewing a no-evidence summary

judgment,

we “review the evidence presented by the motion and response in the light most

favorable to the

party against whom the summary judgment was rendered, crediting evidence

favorable to that

party if reasonable jurors could, and disregarding contrary evidence unless

reasonable jurors

could not.” Mack Trucks, 206 S.W.3d at 582 (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 ELEMENT THERE IS NO EVIDENCE. It is well settled that a

trial

court cannot grant a summary judgment motion on grounds not presented in the

motion. Brewer

& Pritchard, P.C., 73 S.W.3d at 204; Science Spectrum, Inc. v. Martinez, 941

S.W.2d 910, 912

(Tex. 1997). Our no-evidence summary judgment rule similarly requires that the

moving party

identify the grounds for the motion:

After adequate time for discovery, a party without presenting summary judgment

evidence may

move for summary judgment on the ground that there is no evidence of one or

more essential

elements of a claim or defense on which an adverse party would have the burden

of proof at trial

1.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket

No. A-180805, filed and Respectfully Moves before the Honorable 58 th

District Court of Jefferson County Texas His “Honorable Court” except,

Plaintiff motion for Traditional Summary with all exhibit(s) A-1, and A-L,

Exhibit (A-1) Construction Contract of the Plaintiff

Exhibit (A) Affidavit of Defendant (Joyce Guy)

Exhibit (B) Response to Plaintiff’s Motion for Sanctions by: Attorney of

record Antoine L. Freeman, J.D. Texas Bar No. 24058299 3723

Exhibit (C) Motion for Withdrawal of Counsel

Exhibit (D) *Parker Lumber In Port Arthur Texas 2948 GulfWay Drive for 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) * Certified Mail: 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 Death Index Search

Exhibit (I) Plaintiff First Set of “Interrogatories”

Exhibit (J) Plaintiff request for Disclosure Pursuant to rule 194

Exhibit (K) Plaintiff Request for Admissions propounded by Louis Charles

Hamilton II Pro Se Plaintiff herein pursuant to rule 198 of the Texas Rules of

Civil Procedure.

Exhibit (L) Order of the 58th District Court was executed on May 10, 2010

Being filed with the Clerk of Court Records of Jefferson County Texas, and

The Honorable Court further being most favorable to the Pr Se Plaintiff claims as

presented and supported, and the Honorable Court Being of the opinion Plaintiff

Motion is with “merit” and should be granted into the Court Records.

2.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket No. A-

180805, Further Respectfully Moves the Honorable 58th District Court of Jefferson

County Texas His “Honorable Court” Plaintiff recovery damages for wrongful lost

of tools in excess of $3093.00 dollars with full 6% interest rate incurred since date

of injury from November 16th 2007

3.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II herein Docket No. A-

180805, Further Respectfully Moves the Honorable 58th District Court of Jefferson

County Texas His “Honorable Court” Plaintiff recovery damages for “Breach of

Contract” at the rate of Profit Plaintiff 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 $10,800.00 dollars Contract being Profit.

4.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The

Honorable Court for said damages and Profit of $7931.00 dollars with full 6%

interest rate incurred since date of injury November 16th 2007

5.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The

Honorable Court for damages in the amount of the Honorable Court Justice for

the Plaintiff suffrage of “Intentional Infliction of 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 “Honorable Court” against said Defendant(s) “Joyce Guy” and

Edward McCray” for their combine extreme, dishonest, hostile, corrupted,

actions, directed at the Plaintiff herein’, and his personal property and assault

upon the Plaintiff.

To include but not limited” to Defendant “Joyce Guy and Edward McCray”

Fraud of the Insurance Company scheme of things involving Pro Se Plaintiff

$10,800.00 dollars construction contract in 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 Se Plaintiff Louis Charles Hamilton II Respectfully Moves The

Honorable Court that Defendant(s) “Joyce Guy and Edward McCray” pay the

amount of “Actual Damages” to the 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 and all “Court Cost” incurred

in this Civil Matter.

7.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The

Honorable Court to grant the Plaintiff attached joining motion filed herein with

good “Merit” to have the “Long Arm of The Law” Namely

8.

“The Jefferson County Sherriff’s Office” to fully enforce and place a

“Property Lien” on the described Property of 448 DeQueen Blvd. in Port Arthur

Texas, in favor of the Pro Se Plaintiff herein Louis Charles Hamilton II which

Defendant(s) “Joyce Guy and Edward McCray”

Was so Order By This Honorable 58th District Court of Jefferson County

Texas to produce copies of deeds, property deeds or any other such physical

document in Defendants’ possession, custody or control that shows actual

ownership of the property of the dwelling located at 448 DeQueen Blvd., and

fully failing to adhere to an Honorable Court Order.

As described in Plaintiff Exhibit (L) attached herein.

Further providing The “Honorable 58th Judicial Court” a secured Judicial

Honest biting 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 favorable to the “Laws of the

State of Texas”,

Most favorable to the Pro Se Plaintiff Civil Rights, Damages and

Compensation as described fully in the records herein this Civil Action.

9.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves The

Honorable Court for any further, Just, proper, Damages and Awards The

Honorable Court Deems Judicial in and For 58th District Court 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