writ for garnishment

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No. A-180805 Louis Charles Hamilton II IN THE DISTRICT COURT Plaintiff 58 TH JUDICIAL DISTRICT V. Joyce Guy & Edward McCray ET AL OF JEFFERSON COUNTY, TEXAS Defendants. Plaintiff Motion For “Writ of Garnishment” Comes Now Before The Honorable 58 th District Court the Pro Se Plaintiff, Louis Charles Hamilton II, herein Motion before the Honorable Court, For “Writ of Garnishment” against the Defendant(s) Business listed as Follows: (1). E and J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur Texas Information about E & J Collectibles E & J Collectibles is in the Used Merchandise Stores business and this category has 2 companies in Port Arthur and a total number of businesses in Texas. (2). J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640 (3). G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640 (4).

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Page 1: Writ for garnishment

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 “Writ of Garnishment”

Comes Now Before The Honorable 58th District Court the Pro Se Plaintiff,

Louis Charles Hamilton II, herein

Motion before the Honorable Court, For “Writ of Garnishment” against the

Defendant(s) Business listed as Follows:

(1).

E and J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur Texas

Information about E & J Collectibles

E & J Collectibles is in the Used Merchandise Stores business and this category has

2 companies in Port Arthur and a total number of businesses in Texas.

(2).

J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 448

DeQueen Blvd. in Port Arthur Texas 77640

(3).

G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas

(Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640

(4).

Page 2: Writ for garnishment

“Cars and Pieces” Located in Beaumont Texas (Office) also located at 448

DeQueen Blvd. in Port Arthur Texas 77640

And for just cause Before the Honorable 58th District Court of Jefferson County

Texas the Pro Se Plaintiff herein declares, affirm and state as Follows:

I.

Defendant(s) “Joyce Guy and Edward McCray” having a Civil dispute in

regards to among other things:

“Actual Damages” being owed to the Plaintiff in the Amount of $11,024.00 with

full 6% interest rate incurred since date of injury November 16th 2007

As described in Plaintiff “Motion for Summary Judgment” with all of the exhibit(s),

documents, and records herein.

II.

Defendant(s) “Joyce Guy and Edward McCray” Continue to be in the

physical custody, control, and possession of the Property located at 448 DeQueen

Blvd. in Port Arthur Texas being well within Jefferson County Jurisdiction,

Authority Namely this Honorable 58th District Court of Jefferson County Texas.

As of this undersigned date in 2014 while Defendant(s) collectively refusal

before this Honorable 58th District Court Orders to provide actual ownership of

said disputed property in this Civil Matter Docket No. A-180805 as of this

undersigned date in the Month of November 2014.

III.

Defendant(s) “Joyce Guy and Edward McCray” mutable business E and J

Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur Texas, J Can

Company 1807 East 7th Street Port Arthur Texas,

Page 3: Writ for garnishment

G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas

and, “Cars and Pieces” Located in Beaumont Texas (Office) also located at 448

DeQueen Blvd. in Port Arthur Texas 77640

Are all in fact legally owned by the Defendant(s) collectively herein as

records do in fact “indicate” and on file with the “Jefferson County clerk”

At this time the Pro Se Plaintiff Louis Charles Hamilton II Respectfully caution the

“Honorable Judicial 58th District Court” to take Calm raised eye brow calculations

of "Judicial Notice" to the Following Plaintiff Brief in Support of a “Writ of

Garnishment” against the Defendant(s) “Joyce Guy and Edward McCray”

Plaintiff Attached Brief in Support

1.

Defendant(s) “Joyce Guy and Edward McCray” refused to file proof of the required discovery as required in a “direct court order” which the Defendant(s) both were in fact in “full attendance” before The Honorable Court when such an Order was so enforced by the Court and stated on Court Records.

“Elementary Simply” Defendant(s) “Joyce Guy and Edward McCray” collectively thinking not only The Pro Se Plaintiff “Louis Charles Hamilton II herein but to include but not limited to

The “Honorable 58th District Court” of Jefferson County Texas to be at a sad state of being absolutely extra green-n- slow, lacking “intelligence or common sense” and very dull to understand the cold, scheming, cunning, calculating, dishonest, corrupted, double-dealing, fraudulent “Grand Theft” history of the Defendant(s) involving among other things,

Committed to many counts of “Insurance and FEMA” $$$ Heisting which said discovery of the Pro Se Plaintiff Defendant(s) “Joyce Guy and Edward McCray” refusing the said court order would in fact produce quite a “Outstanding” scary “Criminal and Civil extremely high profile embarrassing situation and predicament of “prison penalties” both being 100% against the

Page 4: Writ for garnishment

Peace and Dignity against The “State of Texas” and The “U.S. Federal Government Justice Dept.” criminal codes.

To the Point this “civil action” herein is also known to be Pro Se Plaintiff Louis Charles Hamilton II a/k/a Cmdr. Bluefin (USN)

“Sherlock Holmes” Case of “The Dead Man Who Paid Taxes”

2.

Plaintiff further state that on or about June/18/2009 a “Mechanics Lien” was filed in Jefferson County Texas by: SWMJ Construction against Blk. 172 Lt. 1-2 own by Defendant(s) “Joyce Guy and

Edward McCray” for primary “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages,

“First American Title Insurance Co. 510 Bienville Street, Floor 2r “Johanna” New Orleans LA 70130 being the Returnee

Which the Defendant(s) “Joyce Guy and Edward McCray”

Collectively refusal of said Court Order in this said discovery documents ,involving full details, of the Construction Company and the terms and condition of the contract for repairs, Funds paid out for repairs, by all parties involved namely “First American Title Insurance Co.

3.

Plaintiff further state that on or about November/16/2010 a “Mechanics Lien” was filed in Jefferson County Texas by: DSW Homes on Property own by Defendant(s) “Joyce Guy and Edward McCray” BlK.4 Lt.

10 For primary “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages,

“First American Title Insurance Co. 510 Bienville Street, Floor 2r “Johanna” New Orleans LA 70130 being the Returnee

4.

Page 5: Writ for garnishment

Plaintiff further state before the “Honorable Court” that Defendant(s) “Joyce Guy and Edward McCray” having “Deed” to the Property located in Port Arthur Texas Lt. 1-2 Blk. 172 filed in Jefferson County Texas #2014012455 filed 04/22/2014

5.

Plaintiff further state before the “Honorable Court” that Defendant(s) “Joyce Guy and Edward McCray” having “Deed” to the Property located in Port Arthur Texas Lt. 8 Blk. 210 filed in Jefferson County Texas #2007032430 filed 08/17/2007

6.

Plaintiff further state before the “Honorable Court” that Defendant(s) “Joyce Guy and Edward McCray” having “Deed” to the Property located in Port Arthur Texas Lt. 11 Blk. 94 filed in Jefferson County Texas #2008022271 filed 06/20/2008

7.

Plaintiff further state before the Honorable Court that Defendant(s) “Joyce Guy” having “Power of Attorney” over Norma Guy Her dead mother and Now “Deed” to the Property located in Lakeview Texas Lt. 10 Blk. 4 filed in Jefferson County Texas #2010042042

8.

Plaintiff further state before the Honorable Court that Defendant(s) “Joyce Guy” having “Deed” to the Property located in Port Arthur Texas Lt. 8 Blk. 210 filed in Jefferson County Texas #2007032430 filed 08/17/2007 real estate 1807 Rev. Ransom Howard Street Port Texas Geographic ID 053400-000-237400-00000-5 “Commercial Vacant Lot”.

Page 6: Writ for garnishment

9.

Plaintiff further state before the Honorable Court that Defendant(s) “Joyce Guy” having “Power of Attorney” over “Norma Guy” Her dead mother “legal affairs” and Now upon information and belief “Deed” to the Property located 5050 east 7th street in Port Arthur Texas

Notwithstanding Defendant(s) “Joyce Guy” having “Power of Attorney” over “Norma Guy” Her dead mother legal affairs primary for

“Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages,

to the Property located 5050 east 7th street in Port Arthur Texas.

10.

Plaintiff further state before the “Honorable Court” quite Judicially seriously that Defendant(s) “Joyce Guy and Edward McCray”

secretly conspire in full conclusion to keep hidden through their retained “Attorney of Record” Antoine L. Freeman J. D. Texas Bar No. 24058299 that actually being filed in Jefferson County Clerk office on the June/18/2009

While This “Live” Civil Action is ongoing since November 17th 2007 and a legal discovery request already being made by The Pro Se Plaintiff “Louis Charles Hamilton II” herein into the Records of Hurricane “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages, and its involvement with

“First American Title Insurance Co.” 510 Bienville Street, Floor 2r “Johanna” New Orleans LA 70130 being the Returnee and the property located at 448 DeQueen Blvd. in Port Arthur Texas

Defendant(s) 100% Bold in being a flat out refused of the Honorable 58th District Court “Court Order” to produce said Records relating to “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages, and its involvement with the Defendant(s) “Joyce Guy and Edward McCray”

“Shockingly” a legal transfer of the Defendant(s) “Joyce Guy and Edward McCray” collectively property of 448 DeQueen blvd.

Page 7: Writ for garnishment

Said property Namely 448 DeQueen Blvd. in Port Arthur Texas 77640

Namely being Lot 1-2 Block 172 Jefferson County Texas records #2009022762 filed on June/18/2009 was in fact transfer to the “Texas Department of Housing & Community Affairs” and Attorney of Record Antoine L. Freeman J. D. Texas Bar No. 24058299

Now boldly as an Attorney of Law” lying to The “Honorable 58th District Court” about his position as Attorney of record for the Defendant(s) “Joyce Guy and Edward McCray” Docket No. A-180805

Antoine L. Freeman J. D. Texas Bar No. 24058299 fully hidden the Pro Se Plaintiff herein Louis Charles Hamilton II “Request for Admission”, Disclosure Documents and “Interrogatories” request and legally refused to file a timely reply to them for over 3 + years

11.

Plaintiff further state before the “Honorable Court” Defendant(s) “Joyce Guy and Edward McCray” while this civil action ongoing since November 17th 2007 and with their retained “Attorney of Record” Antoine L. Freeman J. D. Texas Bar No. 24058299 filed Financing statement on June /18/2009 with “Texas Department of Housing & Community Affairs” Jefferson County Texas records #2009022763

12.

Plaintiff further state before the “Honorable Court” Defendant(s) “Joyce Guy and Edward McCray” while this civil action ongoing since November 17th 2007 Defendant(s) received a release of “Deed” dated on July/22/2013 from the “Texas Department of Housing & Community Affairs” Jefferson County Texas records #2013023794

13.

Plaintiff further state before the “Honorable Court” Defendant(s) “Joyce Guy and Edward McCray” while this civil action ongoing since November 17th 2007 Defendant(s) received a Termination from the “Texas Department of Housing & Community Affairs” Jefferson County Texas records #2013023794

Page 8: Writ for garnishment

448 DeQueen Blvd. “Property Deed” being in the possession of the Defendant(s) “Joyce Guy and Edward McCray”

As of April/22/2014 which the “Texas Department of Housing & Community Affairs” housing Grant the Defendant(s) fraudulently obtain was in fact a “Federal Housing Grant” for “Texas Department of Housing & Community Affairs”

As admitted by the Defendant(s) through their “Attorney of Record” Antoine L. Freeman J. D. Texas Bar No. 24058299 in his reply to Plaintiff First Set of Interrogatories” dated October 14th 2009

Exactly 4 months and 5 days from June/18/2009 to October 14th 2009 a knowing legal transfer of the Defendant(s) “Joyce Guy and Edward McCray” collectively property of 448 DeQueen blvd. was in fact transfer to the “Texas Department of Housing & Community Affairs” during this ongoing civil action

Meanwhile “Attorney of Record” making numerous false claiming before the “Honorable Court” he was never was acting or having any involvement on the behalf of the Defendant(s) “legal interest”

However Antoine L. Freeman J. D. Texas Bar No. 24058299 being in the possession, custody and control of the Pro Se Plaintiff “Request for Admission”, “Disclosure Documents”

And “Interrogatories” now filed as Exhibit(s) attached to Pro Se Plaintiff Motion for Final Summary Judgment filed by “Attorney of Record” on signature Antoine L. Freeman J. D. Texas Bar No. 24058299 proves in addition;

14.

Pro Se Plaintiff seeking Federal Action in The Eastern District Court of Texas

of “Racketeer Influenced and Corrupt Organizations Act” (RICO) Hamilton v.

Freeman et al Filed: February 2, 2010 as 1:2010cv00055 Plaintiff: Louis Charles

Hamilton, II Defendant: Antoine L Freeman, Edward McCray, Joyce M Guy

Against the Defendant(s) “Joyce Guy and Edward McCray” and their Attorney of Record Antoine L. Freeman J. D. Texas Bar No. 24058299

Page 9: Writ for garnishment

When said Attorney of Record did in fact filed Court Document(s) herein the files of this “civil action”

Claiming “among other things” that Attorney of record did not violated Rule 193.1 as was only retain to file a “General Denial” to this action (ONLY) “However Plaintiff exhibit(s) “Request for Admission”, “Disclosure Documents” And “Interrogatories” dictate before the “Honorable Court”

Attorney of Record conspire with Defendant(s) “Joyce Guy and Edward McCray” to fully Withholding all discovery information from 2007-2010 when Attorney was release from Defendant(s) defense

To include Attorney of Record Antoine L. Freeman J. D. Texas Bar No. 24058299 conspire with Defendant(s) “Joyce Guy and Edward McCray”

Collective outlandish criminal failure to supply any “materials facts” of the physical property transfer of 448 DeQueen Blvd. in Port Arthur Texas 77640

Namely being Lot 1-2 Block 172 Jefferson County Texas to the ownership of “Texas Department of Housing & Community Affairs” during this ongoing civil action before the 58th District Court of Jefferson County Texas Before the “Honorable Bob Wortham” Judicial Watch.

15.

Plaintiff further state before the “Honorable Court” at no time was the Honorable Court”, and The Pro Se Plaintiff was to have any knowledge of Defendant(s) “Joyce Guy and Edward McCray” and their skilled

“Fraudulent”, “Devious”, Calculating”, Trickery” activities involving the “Texas Department of Housing & Community Affairs”

An absolute upmost urgent concealment and containment of the “Honorable Court” and the Pro Se Plaintiff in remaining completely “Blind” throughout this civil action between the dates of 2007-2010

In addition as what has been described above in paragraph 10-14 above

Attorney of Record Antoine L. Freeman J. D. Texas Bar No. 24058299 further in rouge conclusion “conspire” with Defendant(s) “Joyce Guy and Edward

Page 10: Writ for garnishment

McCray” to fully Withholding all other material discovery information and documents relating with these activities of the estate of 448 DeQueen Blvd. in Port Arthur Texas in relationship to wit:

That on or about June/18/2009 Defendant(s) and their Attorney of record continue with clever (RICO) intent knowingly withheld Legal “Discovery Material Facts” of a “Mechanic Lien” filed by SWMJ Construction in Jefferson County Texas record #2009022761 against 448 DeQueen Blvd. Property while this civil action was “Live” and ongoing

“Ungodly Committed” to a Crooked Dead Frog Underhanded Double Dealing Sneaky shady” jack up the legal court system in further acts to continue misleading the Pro Se Plaintiff and The “Honorable Court” during this ongoing civil action before the 58th District Court of Jefferson County Texas

Committed to retain Failure to admit such a “Lien” Against the same 448 DeQueen dwelling in Port Arthur Texas exist as a cause of Hurricane damages claims being made for repairs by this “SWMJ” Construction Contractors, in regards to “Hurricane “Rita”, “Ike” and “Humberto ” related Construction storm damages,

As Plaintiff making the same claims for Defendant(s) Collective skilled “Grand Rip off Activities” of Insurance Funds, as described in the Complaint of the Plaintiff for damages in regards to “Hurricane Humberto” and $10,800.00 U.S. Dollars related to Construction storm damages involving the said Pro Se Plaintiff

As Defendant(s) “Joyce Guy and Edward McCray”, to include but not limited to Attorney of Record Antoine L. Freeman J. D. Texas Bar No. 24058299

Fully intertwine in refusal of “Court Orders” to do so in this require as a matter of Law Production of Document(s).

16.

Plaintiff further state, affirm and declare before the “Honorable Court” on or about June 18th 2009 the Defendant(s) “Joyce Guy and Edward

McCray”, filed with the Jefferson County Clerk #2009022763 “Financing statement to obtain activities involving the “Texas Department of Housing & Community Affairs” and Federal Funds to secure the “New Home” on the

Page 11: Writ for garnishment

property at a cost of $76,000.00 U.S. Dollars (Grant) as a result of the Defendant(s) “hoodwinking” and

“Devious” trickery to obtain all of the repair funds proceeds from any and all “insurance company” and using the building contractors as their direct corrupted devise to “Heist” the “insurance companies”, and any “State” and “Federal agency” (FEMA) and the likes.

17.

When the Defendant(s) “Joyce Guy and Edward McCray”, filed with the

Jefferson County Clerk #2009022763 “Financing statement” they refused to

provide fact of the Assumed Name Business G and G Service Company P.O. Box

515, 416 DeQueen Blvd. in Port Arthur Texas

(Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640

In which this illegal medical business for the disable elderly senior citizens of Jefferson County Texas was on going from the dates of May 5th1997 throughout January 7th 2010 for a period of 13 years of “Earn Income” with cash being paid to all “employees” when it was order shut down by the State of Texas Department of Aging and Disability Services until a real licensed being obtain.

The “Financing statement” of the Defendant(s) “Joyce Guy and Edward

McCray”, was submitted on June 18 2009 in Jefferson County Clerk records during

the operations of the “illegal medical business” G and G Service Company P.O.

Box 515, 416 DeQueen Blvd. in Port Arthur Texas moreover all “Income” derive

thereof was unaccountable “Earn Income” being fraudulently fully omitted from

the “Financing Statement” to obtain a “Texas Department of Housing &

Community Affairs” and Federal Funds to secure the “New Home” on the

property of 448 DeQueen Blvd. at a cost of $76,000.00 U.S. Dollars (Grant).

Notwithstanding” Pro Se Plaintiff Affirm, Declare, and State G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas “illegal medical business” address is for two “Vacant Lots” own by the Defendant(s) (“Joyce Guy and Edward McCray”) and their Attorney of record Antoine L.

Page 12: Writ for garnishment

Freeman J. D. Texas Bar No. 24058299 quite content secretly in civil/criminal behavior against the Civil Rights, Peace and Dignity of The Pro Se Plaintiff

Pasted to this shame continue with clever (RICO) intent knowingly withheld Legal “Discovery Material Facts” as described herein and as once again An absolute upmost urgent “concealment and containment” of the “Honorable Court” and the Pro Se Plaintiff in remaining completely “Blind” throughout this civil action between the dates of 2007-2010 while this Fraud of The “Financing Statement” of the Defendant(s)

“Joyce Guy and Edward McCray”, was submitted on June 18 2009 in Jefferson County Clerk records ” to obtain a “Texas Department of Housing & Community Affairs” and Federal Funds to secure the “New Home” now sitting on the Property of 448 DeQueen Blvd. in Port Arthur Texas

Absent all “Income” Earn for ” G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur Texas

To include but not limited to “Joyce Guy” Not paying “State or Federal Taxes” being paid on this Business G and G Service Company

“Ever” No Insurance, Workmen compensation and taxes deductions on employees “Ever”.

18.

Plaintiff further state, affirm and declare before the “Honorable Court” Defendant “Edward McCray” having “Deed” to the property filed in Jefferson County Clerk records #2001017640 on May 17th 2001

Lot 10 Blk. 18 Jef Chaison

19.

Plaintiff further state, affirm and declare before the “Honorable Court” Defendant “Edward McCray” in the past had a “earn income” derived from the sales of “Dangerous Drugs” Jefferson County Cause No. 97903 and Cause No. 146302 and upon further information and belief Defendant “Edward McCray” Federal Charges

Page 13: Writ for garnishment

derived in the performance of such as “Manufacturing” sales of a “Crack Cokecaine Industry” for earn income.

20.

Plaintiff further state, affirm and declare before the “Honorable

Court” J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at

448 DeQueen Blvd. in Port Arthur Texas 77640 being owned by the Defendant(s)

“Joyce Guy and Edward McCray”, assumed name filed on April 11th 2008

Jefferson County Clerk records #72594

1807 East 7th street in Port Arthur Texas is actually a “Vacant Lot” which

has been raided by the PAPD Dept. (Police) for engaging in “illegal Scrap

Industry”

“Moreover” once all “Illegal Scrap Metal” other then used Cans being

recycle and obtain in the City of Port Arthur Texas city limits by Defendant

“Edward McCray”, by the business J Can Company being now introduced as

“Scrap Metal” in connection with “Cars and Pieces” business Located in

Beaumont Texas (Office) also located at 448 DeQueen Blvd. in Port Arthur Texas

77640

Making the final “Legal sales” of all “illegal scrap” obtain in the City of Port

Arthur Texas city limits by Defendant “Edward McCray”,

“Moreover” Pro Se Plaintiff Louis Charles Hamilton II herein (Fully) quite

“elementary sure and certain” after prior raid by the (PAPD) Police into “illegal

scrap” of J Can Company that this “many years of “baffling exchange” transfer

rate of

“Illegal scrap” from Port Arthur Texas City Limits has been confusing the

(PAPD) Police in the exchange rate form now “legal scrap” derived in

“Beaumont Texas” from J Can Company “Namely” to wit:

Page 14: Writ for garnishment

“Cars and Pieces” business in Beaumont Texas being now major illegal

scrap metal “money laundering” “Earn Income” system for Defendant (Edward

McCray) derived from this “criminal endeavor.

21.

Conclusion

Pro Se Plaintiff moves before the Honorable Court”, that a “Writ of

Garnishment” is just, proper, and “Judicial Correct” in favor of the Pro Se Plaintiff

for all Judgments Plaintiff is fully entitled to as assigned by this “Honorable Court”

Defendant(s) (“Joyce Guy and Edward McCray”) are quite Crafty in

concealing their numerous “Earn Income” regardless if it’s “legal or illegal” in

the among other things Business as described

(1). E and J Collectibles (409) 330-048 448 DeQueen Blvd. in Port Arthur Texas

(2). J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 448

DeQueen Blvd. in Port Arthur Texas 77640

(3). G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur

Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640

(4). “Cars and Pieces” Located in Beaumont Texas (Office) also located at 448

DeQueen Blvd. in Port Arthur Texas 77640

Defendant(s) (“Joyce Guy and Edward McCray”) fully content to also Fraud

this “Honorable Court” which is supported by all material facts supply in Plaintiff

attached brief, exhibits filed in the records of this action and in Support of a “Writ

of Garnishment” all evidence of Jefferson County Texas Records being described

above standing as sound, solid Proof thereof.

Defendant(s) (“Joyce Guy and Edward McCray”) fully content to abscond

completely from “Monetary Judgment” of this action and to continue having

possession, custody, and control of the Plaintiff Property and lively hood Namely

“Construction tools” for over (7) years and counting

Page 15: Writ for garnishment

Defendant(s) collectively already in the past having many “Lien” filed

against them both, in connection among other things the Property which is a part

of this civil action while (“Joyce Guy and Edward McCray”) secretly living wealthy

in the numerous business as described above herein at the dwelling of 448

DeQueen Blvd. in Port Arthur Texas.

1.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the

Honorable Court to incorporate all “materials facts” herein in full force in Favor of

Plaintiff Motion for “Final Summary Judgment”.

2.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the

Honorable Court incorporate all “materials facts” herein in full force in Favor of

Plaintiff Motion for “Property Lien”.

3.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the

Honorable Court incorporate all “materials facts” herein in full force in Favor of

Plaintiff Motion for “Sanctions” against the Defendant(s) (“Joyce Guy and Edward

McCray”).

4.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the

Honorable Court incorporate all “materials facts” herein in full force in Favor of

Plaintiff Motion for “Writ of Garnishment” against the Defendant(s) (“Joyce Guy

and Edward McCray”).

5.

Wherefore Pro Se Plaintiff Louis Charles Hamilton II Respectfully Moves the

Honorable Court for an Order for “The Jefferson County Sherriff’s Office” to fully

enforce and place a “Garnishment” against (1). E and J Collectibles (409) 330-048

448 DeQueen Blvd. in Port Arthur Texas

Page 16: Writ for garnishment

(2). J Can Company 1807 East 7th Street Port Arthur Texas (Office) located at 448

DeQueen Blvd. in Port Arthur Texas 77640

(3). G and G Service Company P.O. Box 515, 416 DeQueen Blvd. in Port Arthur

Texas (Office) located at 448 DeQueen Blvd. in Port Arthur Texas 77640

(4). “Cars and Pieces” Located in Beaumont Texas (Office) also located at 448

DeQueen Blvd. in Port Arthur Texas 77640

In Favor of the Pro Se Plaintiff Louis Charles Hamilton II herein for all

entitled Judgments being of This Honorable 58th District Court of Jefferson

County Texas in favor of the Pro Se Plaintiff

5.

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 in

regards to a “Writ of Garnishment” against the Defendant(s) (“Joyce Guy and

Edward McCray”)

And for all Judgment(s) of This Court To include Defendant(s) paying all

filing fees and all “cost” incurred for this “Writ of Garnishment” in this Civil

Matter.

By, _______________________________

Louis Charles Hamilton II

Pro Se Plaintiff

P.O. Box 17524

Sugar Land Texas 77496