amend to motion to freeze documents, assets, of defendant antoine l. freeman j.d., "attorney at...

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In The United States District Court For The Eastern Division of Texas Beaumont Division Louis Charles Hamilton II Pro Se Plaintiff Vs. Cause No. 1:14-CV-592 Antoine L. Freeman J. D. Defendant Joyce M. Guy Edward McCray Co-Defendant(s) PRO SE PLAINTIFF'S AMENDMENT EXHIBIT(S) FOR (TRO) MOTION TO FREEZE DOCUMENTS, RECORDS, AND ASSETS OF DEFENDANT ANTOINE L. FREEMAN J.D. ATTORNEY AT LAW AND CO-DEFENDANT(S) JOYCE M. GUY AND EDWARD McCRAY (1) Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) herein directly conspire, plotted and fully assistance Co-Defendant(s) “Joyce M. Guy” and Edward McCray” in obtaining and covering up the additional (RICO) monetary fraud scheme of things involving with Hurricanes “Rita, Humberto, Wilma and Ike to the “property located at 5050 east 7 th street in Port Arthur Texas Jefferson County “Lot number (10) in block number (4) of Lakeview addition for an additional amount of $54,839.31 U.S. Dollars

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Page 1: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

In The United States District Court

For The Eastern Division of Texas

Beaumont Division

Louis Charles Hamilton II

Pro Se Plaintiff

Vs. Cause No. 1:14-CV-592

Antoine L. Freeman J. D.

Defendant

Joyce M. Guy

Edward McCray

Co-Defendant(s)

PRO SE PLAINTIFF'S AMENDMENT EXHIBIT(S) FOR (TRO) MOTION TO FREEZE DOCUMENTS, RECORDS, AND ASSETS OF DEFENDANT

ANTOINE L. FREEMAN J.D. ATTORNEY AT LAW AND CO-DEFENDANT(S) JOYCE M. GUY AND EDWARD McCRAY

(1)

Pro Se Plaintiff being further set forth

Declares, Affirm, and State further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) herein directly conspire, plotted and fully assistance Co-Defendant(s) “Joyce M. Guy” and Edward McCray” in obtaining and covering up the additional (RICO) monetary fraud scheme of things involving with

Hurricanes “Rita, Humberto, Wilma and Ike to the “property located at

5050 east 7th street in Port Arthur Texas Jefferson County “Lot number (10) in block number (4) of Lakeview addition for an additional amount of $54,839.31 U.S. Dollars

Page 2: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

(2)

Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” having on the

28th day of August 2009 in a “live courtroom hearing before

The 58th Judicial District Court of Jefferson County Texas “defeated” Pro Se Plaintiff attempt to protect “Norma Guy” legal Senior Citizen Rights” from her own fraudulent destructive daughter pattern and practices in (RICO)

Namely Co-Defendant “Joyce M. Guy” (RICO) enterprise scheme had commenced against another said Hurricane damaged “property” located at 5050 east 7th street in Port Arthur Texas.

Which the Co-Defendant(s) “Joyce M. Guy” herein enjoying a “Power of Attorney” relating to Real Property Transactions as Described in Pro Se Plaintiff attached exhibit (O) herein “Specific Power of Attorney” executed on the 27 th day of May 2010

(3)

Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” the Co-Defendant(s) “Joyce M. Guy” herein having already “squander” all of the entire Hurricane repair funds for her own mother home as a direct result of Hurricane “Rita” storm damages which

“Hurricane “Rita” was the fourth-most intense Atlantic hurricane ever

recorded and the most intense tropical cyclone ever observed in the Gulf of Mexico, which on September 24th 2005 the inner core and eye wall of “Hurricane Rita slams into Port Arthur, Texas

Which the Pro Se Plaintiff will show the Honorable Court” factual evidence during the Trial of this matter of being the direct “construction contractor” whom was contacted to fix , provide estimates of repair cost for said damaged Home located at 5050 east 7th street in Port Arthur Texas.

Page 3: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

Thereafter Pro Se Plaintiff returning to his home town of “Port Arthur Texas from working “construction repairs” after massive storm damages in New Orleans LA as a result of Hurricane “Katrina”

Especially among other things fixing the (asap) needed roofing repairs of

5050 east 7th street in Port Arthur Texas which Co-Defendant(s) “Joyce M. Guy” refusal to comply with the terms and conditions of said

“Insurances repair Funds” to actually fix such Hurricane damages other

then Co-Defendant(s) “Joyce M. Guy” (RICO) scheming plans to obtain said “Insurances repair Funds” for her own personal private gains.

(4)

Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” the Co-Defendant(s) “Joyce M. Guy” herein after squandering all of the said “private insurance” Hurricane repair funds designated for damaged “property” located at 5050 east 7th street in Port Arthur Texas.

“Lot number (10) in block number (4) of Lakeview “she” next contacting Federal “FEMA” for needed roofing plastic covering to stop the rain water, and never fixed the damaged roof at all ever.

(5) Pro Se Plaintiff being further set forth Declares, Affirm, and State further

Before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively secretly make plans, and plotted to carry out a further

(RICO) scheme of things against first and foremost the 58th Judicial District

Court of Jefferson County Texas in the scheme execution of covering up all of the Co-Defendant “Joyce M. Guy”

Monetary scheme made against the Hurricane repair private insurance

funds designated for said damaged “property” located at 5050 east 7th street in Port Arthur Texas. “Lot number (10) in block number (4) of Lakeview

Page 4: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

(6)

Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively secretly make plans, and plotted to secondly carry out a further (RICO) fraudulent “scheme of things” against

“Texas Department of Housing and Community affairs” Loan No. 5866 File

No. 1219-2355082 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005

Federally Declared Disaster Funding under Department of Defense

Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)

Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency:

United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007 to obtain on May 28th 2010 in excess of $54,839.31 U.S. Dollars “Construction Grant”

As being described in Pro Se Plaintiff exhibit (P) attached herein namely a

“Mechanic’s Lien Contract” with DSW Homes 805 S. Hwy. 69, Memorial Fwy, Nederland, TX, 77267

To repair the home located at 5050 east 7th street in Port Arthur Texas after Private Insurances Monies already being a part of a continue (RICO) “pattern and practice squander scheme of things” committed by Co-Defendant(s) “Joyce M. Guy and Edward McCray”

Involving once again the Pro Se Plaintiff Louis Charles Hamilton II herein as

the Construction contractor with Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 fully in fraudulent (RICO) legal denial of ever being actually the physically acting “Attorney of record” in civil suit in common law A-180805 as a part of this cover up scheme of things

Page 5: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

While all of this criminal half bake concoct (RICO) scheme of things being formed against the Pro Se Plaintiff, private insurances companies, and among others parties namely “The United States of America” for a monetary lost in excess of $54,839.31 U.S. Dollars.

(7) To add to Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas

Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein combine (RICO) further fraudulent “scheme of things” in obtaining the already total of $72,500.00 U.S Dollars from namely

“Texas Department of Housing and Community affairs” Loan No. 2727 File

No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005

Federally Declared Disaster Funding under Department of Defense

Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)

Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency:

United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007

As being described in Pro Se Plaintiff attached exhibit herein (Q) Namely

“Mechanic’s Lien Contract” SWMJ Construction Inc., 525 N. Sam Houston Pkwy East, Suite 600, Houston, Texas 77060

For Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar

No. 24058299 and Co-Defendant(s) “Joyce M. Guy and Edward McCray” herein In a total (RICO) combine pattern and practice “scheme of things” against

the “United States of America” in monetary excess gain of $127,339.31 U.S. Dollars

(8)

Page 6: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

Pro Se Plaintiff being further set forth Declares, Affirm, and State further

before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney

at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward

McCray” collectively herein on or there after filed in District Court of Jefferson

County Texas March 14th 2008 1:48 pm having full discover request of the Pro Se

Plaintiff as described

To: Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar

No. 24058299 pursuant to rule 194, request for disclosure Pro Se Plaintiff

attached exhibit (R) herein

With certificate of mailing services attached and * filed also in District Court

of Jefferson County Texas March 14th 2008 1:48 pm

To: Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar

No. 24058299 Plaintiff Motion for Production of Documents being Pro Se Plaintiff

attached exhibit (S) herein

(9)

Pro Se Plaintiff being further set forth Declares, Affirm, and State further

before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney

at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward

McCray” collectively herein in exhibit(s) (A) and (B)

Already on file with the U.S. Clerk of Court maintain having knowledge

possession, custody and control of Pro Se Plaintiff discovery was during the exact

time frame of April 2nd 2008 and April 11th, 2008 which was fraudulent

statements made before the 58th Judicial District Court by

Defendant/Attorney of Record/ Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) collectively herein in comparison to Pro Se Plaintiff exhibit (R) and (S) attached herein showing “among other things” the actual request for copies of the “Property Deeds”

The exact precise time frame which is a material issue in this civil action in

common law to be on record of this civil action in March of 2008,

Page 7: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

(10) Which Pro Se Plaintiff being further set forth Declares, Affirm, and State

further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein on June 9th 2009 1 year and 2 months in direct refusal to produce said property deeds

Completely there after conspire, plotted instead of producing the Property

deed before the Honorable Court and to the Pro Se Plaintiff continue engaged in real (RICO) enterprise scheme of things and “Transfer of Lien” and “Property Deeds”, for the said dwelling located at 448 DeQueen Blvd in Port Arthur Texas to the

“Texas Department of Housing and Community affairs” Loan No. 2727 File

No. 1219-2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005

Federally Declared Disaster Funding under Department of Defense

Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)

Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency:

United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year (Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007

As being described in Pro Se Plaintiff attached exhibit herein (Q) for

$75,500.00 U.S. Housing Grant in unpaid “Principal and Interest” with a date of

Maturity being June 8th, 2012 when this civil suit in common law A-180805

commenced in December 26th 2007 and Co-Defendant(s) already (RICO) fashion

obtain funds for Hurricane Rita,

Humberto and Ike for covering cost of needed repair from previously storm

damages as all of this was for private use other than actual home repairs as

already legally described be the Pro Se Plaintiff herein providing additional proof

for the

Page 8: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

“Honorable U.S. Justice” a not so ordinary state case of Fraud but a grand

2005- 2014 (RICO) enterprise endeavor scheme of things well into future

designed, and careful craftiness by

Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.

24058299 herein to among other things appear in a live court hearing on August

28th 2009 win the (TRO) hearing the Co-Defendant did in fact squander her

mother insurance repair funds and disappear again claiming he “Attorney of

Record” was never even there before the 58th Judicial District Court he not the

“Attorney of record to win a Motion for sanctions while being

100% the retain expert skilled in Fraud Attorney fully rouge, hostile, and

criminal in holding out on all “discovery phase” as already described against him

legally.

To the point Pro Se Plaintiff attached exhibit (S) namely Plaintiff Motion for

Production of Documents filed herein never ever even been answered as of this

undersigned date.

(11)

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State

further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D.

(Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy”

and Edward McCray” collectively herein working further fraudulent together,

“Hand in hand” smiling in monetary victory as now being provided a

document first time in Texas history an extra greedy not so a ordinary state case

of Fraud but a grand (RICO) fraudulent enterprise endeavor scheme of things well

into future designed, and careful craftiness by

Chief Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 herein to engage now at this point after all fraudulent cover up all of the Fraud scheme of things as being described in paragraph

Page 9: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

(1)-(6) above against the property located at 5050 east 7th street in Port Arthur Texas to achieve another grand (RICO) enterprise endeavor scheme of things well into future designed, and careful craftiness against once again

“Texas Department of Housing and Community affairs” Loan No. 5866 File

No. 1219-2355082 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005

Federally Declared Disaster Funding under Department of Defense

Appropriations Act, 2006 CDBG Disaster Recovery Program (Homeowner Assistance Program “HAP”)

Or (Sabine Pass Restoration Program “SPRP”) Awarding Federal Agency:

United States Department of Housing and Urban Development TDHCA Federal Award Number: B-06-DG-48-0002 Federal Award Year

(Year of Award from HUD to TDHCA): 2006 TDHCA Award Year: 2007 to

obtain on May 28th 2010 in excess of $54,839.31 U.S. Dollars “Construction Housing Grant” in unpaid “Principal and Interest” with a date

of Maturity being well calculated and executed into 2015 (12) Which Pro Se Plaintiff being further set forth Declares, Affirm, and State

further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively

(RICO) scheme of things in the direct refusal of the actual request in

discover request dated back in March 14th 2008 with a Court Order further following for such a Production of said “property deeds” now being Pro Se Plaintiff attached exhibit (L) herein dated May 10th 2010 notwithstanding factual events and circumstances said

Property deeds being officially “free and clear” from the “Texas

Department of Housing and Community affairs” Loan No. 2727 File No. 1219-

Page 10: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

2102152 CFDA 14.228 Community Development Block Grant Program (“CDBG”) Hurricanes Katrina, Rita and Wilma in the Gulf of Mexico 2005 as filed and recorded April 22nd 2014 at 12:38 pm

As described in Pro Se Plaintiff attached exhibit (T) herein namely “Property

Deeds” of the Co-Defendant(s) Joyce M. Guy and Edward McCray” herein dated April 22nd 2014for the dwelling located at 448 DeQueen Blvd in Port Arthur Texas

(13) With the Co-Defendant(s) Joyce M. Guy and Edward McCray” herein

fraudulent “Financing Statement” dated June 18th 10:20 am filed as Pro Se Plaintiff attached exhibit (U)

And Co-Defendant(s) Joyce M. Guy and Edward McCray” herein

Termination of Fraudulent Financing Statement Amendment dated July 22nd 2013 2:01 pm filed as Pro Se Plaintiff attached exhibit (V)

(14) Which Pro Se Plaintiff being further set forth Declares, Affirm, and State

further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299

And Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively

further (RICO) scheme of things is involved in not being honest and providing full disclosure all of the actual Business being owned and all income derive thereof

“Namely” G & G services and E and J collectable in order to obtain

fraudulent from the “Texas Department of Housing and Community affairs” said Loan No. 2727 File No. 1219-2102152 CFDA 14.228

Community Development Block Grant Program (“CDBG”) Hurricanes

Katrina, Rita and Wilma in the Gulf of Mexico 2005 in excess of $72,500.00

Being directly in violation of 18 U.S.C. § 1001 : US Code - Section 1001: Statements or entries generally

Page 11: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

(a) Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States,

knowingly and willfully - (1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact;

(2) makes any materially false, fictitious, or fraudulent statement or representation; or

(3) makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;

(15)

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein further continue

(RICO) “Scheme of things” is involved in concealing, obscuring, masking,

cloak and shielding corrupted fraudulent “mutable fraudulent business” enterprise operations the Co-Defendant(s) “Joyce M. Guy” and Edward McCray” herein concoct and obtaining massive hidden income over many years described as follows:

A. Assumed name business “G & G Services” a fraudulent Medical services for obtain “monetary payments” from “Senior Aging Handicap Citizens within Jefferson County Texas which “G & G Services” was never even a litigable Licenses with the State of Texas from May 2nd 1997- 2010 as being order shut down as described in Pro Se Plaintiff attached exhibit (F) from the Texas Department of Aging and Disability Services. *to include but not limited to “Tax Evasion” being directed at both the “State of Texas” and “The United States of America” for a actual time period of (13) plus years in this (RICO) illegal medical business operation fraudulent corrupted “scheme of things”. To include but not limited to upon information and belief “G & G Services” medical services is secretly still in business operation …….Omg (wow)

Page 12: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

B. While “G & G Services” income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

C. Assumed name business “E and J Collectibles” 448 DeQueen Blvd. in Port Arthur Texas which is in the Used Merchandise Stores business for a unknown amount of years having (2) companies in Port Arthur Texas “However” these (2) companies is not registries with “Jefferson County Texas, or the “State of Texas” fully engaging in among other things (RICO) enterprise in “Sales Tax Evasion”, *Business is current in operation as identified on the “internet” for a unknown accountability of time.

D. While “E and J Collectibles” income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

E. Assumed Name J Can Company in Port Arthur Texas business operation from April 11th 2008 – 2015 this J Can Company business operation is a “front company” for (RICO) enterprise scheme of things in “among other things” besides hidden sells of “Crack cocaine” while actually engaging in (RICO) enterprise in “money laundering” in scrap metal materials” in connection with assumed name business “Cars and Pieces”

F. Another “front company” located in Beaumont Texas. To include but not limited to J Can Company business operation and “Cars and Pieces” business operation (RICO) enterprise in State and Federal Tax Evasion.

G. While J Can Company income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

H. Assumed Name “Car and Pieces” in Beaumont Texas business operation from May 10th 1990 while actually engaging in (RICO) enterprise in “money laundering” in scrap metal materials” in connection with assumed name business J Can Company in Port Arthur Texas. As described in paragraph (C) above.

Page 13: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

I. While “Car and Pieces” income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

J. Assumed Name Paragon Business Inc. being a unknown company of sorts, current in business operation since May 17th 2001 while Paragon Business Inc. income not listed fully in “Financing Statement” of Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein to (RICO) fraudulent obtain Federal Housing Grant in excess of $72,500.00 U.S. dollars.

(16)

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State

further before the “Honorable U.S. Justice” Defendant Antoine L. Freeman J. D.

(Attorney at Law) Texas Bar No. 24058299 and Co-Defendant(s) “Joyce M. Guy”

and Edward McCray” collectively herein continue to engage in among other things

“obstruction of Justice” collaboration, racket, and

Plot in their collective (RICO) “defense” the direct refusal to produce among

other things said 58th Judicial District “Court Order” for discovery of the “property

deeds”, and all records involved in Hurricane “Rita,

Humberto, and Ike, in connection with the dwelling located at 448

DeQueen Blvd. in Port Arthur Texas as of this undersigned date in 2015.

And ruse, dodge, concealing, withholding, destroying, masking, obscuring

all past, property deeds, banking records, contractor(s) construction insurances

estimates and contract(s) for (5)-(6) hurricane storm damages claims,

homeowner private insurance records,

FEMA records, (4)-(6) mutable private illegal business company records,

Texas Department of Housing and Community Affairs housing records, State Tax

Records, Sales Tax records, (IRS) Tax Records any document relating to any

discovery into the corrupted (RICO) enterprise endeavor fully

(17)

Page 14: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

“Chief Defendant” Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.

24058299 with legal intent to bring Pro Se Plaintiff “Civil Suit” in Common Law A-

180805 to a full collapse lost civil cause of action in a well plan, visionary clever

skilled lawyer strategy scheme to “first and foremost” make the bogus (RICO)

fraudulent “representation and presentation” as acting “attorney of record” for

the legal behalf of the Co-Defendant(s) collectively to the Pro Se Plaintiff,

While at the same time frame making the same bogus (RICO) fraudulent

“representation and presentation” as being not the acting “attorney of record”

before the Honorable 58th Judicial District Court of Jefferson County Texas

To execute withholding all discovery as now being escalated as described

of the Grand (RICO) scheme of things involving the Pro Plaintiff alone in excess

$127,339.31 scam of (2) U.S. Federal Housing Grant.

(18)

Which Pro Se Plaintiff being further set forth Declares, Affirm, and State

further before the “Honorable U.S. Justice” Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively herein

USPS Tracking™

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Page 15: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

Postal Product:

Priority Mail 2-Day™

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DATE & TIME STATUS OF ITEM LOCATION

January 29, 2015 , 10:53 am

Notice Left (No Authorized

Recipient Available)

We attempted to d

PORT ARTHUR, TX 77640

We attempted to deliver your item at 10:53 am on January 29, 2015 in PORT ARTHUR, TX 77640 and a notice w as left

because an authorized recipient w as not available. You may arrange redelivery by visiting http://w ww.usps.com/redelivery

or calling 800-ASK-USPS 800-ASK-USPS FREE, or may pick up the item at the Post Office indicated on the notice. If

this item is unclaimed after 15 days then it w ill be returned to the sender.

January 29, 2015 , 8:29 am Out for Delivery PORT ARTHUR, TX 77640

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January 28, 2015 , 10:09 am Acceptance SUGAR LAND, TX 77479

Flat out in refusal to except any “certified Mail” from this particular Pro Se Plaintiff Louis Charles Hamilton II in the State Court action A-180805 on January 29, 2015 , 10:53 am as being described

Page 16: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

Tracking Number: 70092820000295595205

For a “Writ of Attachment”, Summary Judgment, Contempt of Court

hearing being held on the 19th day of February 2015 before the 58th Judicial

District Court of Jefferson County Texas at 9:00 am hr.

Once Co-Defendant(s) collectively herein in 2015 again with such scuttle

plans, to hide, melt, destroy, conceal, ruse, scheme, dodge, all records, or being a

party thereof in this grand (RICO) scheme of things involving not only the Plaintiff

but the entire “United States of America”

And “The State of Texas” in a half bake (RICO) combine “greedy racket

enterprise” scheme of things that has accumulated gradually past acquisition of

hidden (RICO) monetary earnings cars, possessions and properties estimates in

excess of $980,000.00 U.S. dollars

From the time frame of 1997-2015 and to include but not limited to the

Grand (RICO) scheme of things involving the Pro Plaintiff Louis Charles Hamilton II

herein alone in excess $127,339.31 monetary scam of (2) U.S. Federal Housing

Grant.

(19)

Pro Se Plaintiff being respectful, before the “Honorable U.S. Justice”, and

fully reincorporate all as stated in the original (TRO) for to freeze, all records and

assets of the “Defendant Antoine L. Freeman J. D. (Attorney at Law) Texas Bar No.

24058299” and Co-Defendant(s) “Joyce M. Guy” and Edward McCray” collectively

herein

With all supporting exhibit(s) on file with the U.S. Clerk in support thereof

said (TRO) injunction and Motion to freeze records and assets and all supporting

exhibit(s) now with the weight of

“Merit” attached herein fully in favor of granting Pro Se Plaintiff Louis

Charles Hamilton II herein require protection of all discovery material(s) as

Page 17: AMEND TO MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "Attorney at Law" et al U.S. CAUSE No.1:14-CV-592

already legally described herein the records of the U.S. Federal Civil Suit (RICO)

action.

Wherefore respectfully, Pro Se Plaintiff moves before the Honorable U.S.

Magistrate Judge to grant all such (TRO) asset, and document freeze in Justice,

equity and relief.

Wherefore respectfully the Pro Se Plaintiff moves the cost of Court, Pro Se

Plaintiff fees, and such other further relief as Pro Se Plaintiff “Louis Charles

Hamilton II may be entitled to in law or in equity.

Dated this ______ day of _______________, 2015

By, _______________________________

Louis Charles Hamilton II

Pro Se Plaintiff

P.O. Box 17524

Sugar Land Texas 77496