Wherefore All (Plaintiffs) assert “Respectfully before the Honorable Judge Jack Ewing” that all (Defendants) Mr. Andre Horn, (Defendant) Mrs. Andre Horn, and (Defendant) DND Texas Investments by and through their (Attorneys) and or (Pro Se) being legally required to appear before the above entitled “Honorable Court” And (defend) against all (Plaintiffs) collective Motion to Freeze All Assets of the (Defendants) each has been identified in paragraph (2) herein all being (Defendants) in both Civil Actions CV-0095677 and CV-0095978. 3. Wherefore (Plaintiff) Hamilton enjoy “temporary emergency housing and food voucher” awards and expedited cost provided for and from each and all (Defendants) City of Galveston Texas et al, (Defendant) Galveston Police Department et al, (Defendant) Amber Evans, and (Defendants) St. Vincent’s House et al, (Defendant) Mr. Horn, (Defendant) Mrs. Ander Horn and (Defendant) DND Texas Investments “Court Cost” in excess of $4200.00 as described in the Notice for Default Judgment against (Defendant) Mrs. Andre Horn in paragraph (8) being pay to the order of (Plaintiffs) Law Office of Ron D. Harris for such “temporarily housing needs” 4. Wherefore (Plaintiffs) is awared all court cost, attorneys fees and others “Just Awards” this Honorable Court Deems fits on behalf of all (Plaintiffs)

(Motion to Freezing Assets) Against (Defendant) Mrs Ander Horn 11001 Wallisville Rd. Houston Texas77013 and (Defendants) Mr. Andre Horn 11001Wallisville Rd. Houston Texas 77013 and (Defendants) DND Texas Investments 11001 Wallisville Rd. Houston Texas 77013 1. (Plaintiffs) collectively assert respectfully before the above entitled court Honorable Jack Ewing presiding against all (Defendants) in the above Court Case CV-0095677 the following: (a). On the 1st day of September 2026 2:32 pm (Defendant) Mrs. Andre Horn refused to file an answer to the “Court” and on July 20th 2026 2:32 PM when the original of the citation, together with return receipt duly received by County Clerk Office Julie Hairgrove. (b). Plaintiffs filed Motion for Default Judgment on the 1st day of September 2026 2:32 pm against (Defendant) Mrs. Andre Horn. (c). (Defendant) Mrs. Andre Horn Default on approximately $171,700.00 which including (Court Cost). (d). (Defendant) Mrs. Andre Horn as of undersigned dates has not reply to the (New) Original Complaint, CV-0095978 filed on August 31st 9:45 AM this being addition to the Civil Action CV-00956677 (Defendant) Mrs. Andre Horn having legally been filed as a Default Judgments by all (Plaintiffs) on approximately $171,700.00 including (Court Cost) (e). (Defendant) Mr. Andre Horn has a Judgment pending before a Jury Trial approximately $171,700.00 all (Plaintiffs) Seeking collectively in awards and (Court Cost) sames as Default Judgment in paragraph (d) above. (f). (Defendants) DND Texas Investments has a Judgment pending before a Jury Trial approximately $171,700.00 all (Plaintiffs) Seeking collectively in awards and (Court Cost) same as Default Judgment in paragraph (d) above. (g). (Defendants) Mr. Horn, Mrs. Horn, DND Texas Investments has an additional Judgment pending before a Jury Trial as described in CV-0095978. (h) all (Plaintiffs) in CV-0095978 Seeking collectively in awards and (Court Cost) approximately $1,885,850.00