This complaint alleges that the defendants breached a written contract and committed fraud related to a proposed $56 million media campaign to promote the 2012 Mexican presidential candidacy of Enrique Peña Nieto. The complaint claims that while the defendants secured funding from the Mexican government for the campaign, they converted the funds for their own personal use and failed to pay for the advertising as agreed, instead making false representations and threats. The plaintiffs, who own a television network, seek damages for breach of contract, fraud, RICO violations, and other claims.
PA Superior Court Decision: Northern Forests II, Inc. v. Keta Realty CompanyMarcellus Drilling News
In the Northern Forests case, the surface rights owner (Northern Forests) claimed they should also own the subsurface rights due to a legal principal called adverse possession. In reviewing the case, a PA trial court found the original case from 1989 awarding Northern Forests the mineral rights, was in error and the rights revert back to the original rights owners. PA Superior Court agreed and upheld the decision.
Decision by U.S. District Judge David N. Hurd on Force Majeure Case in New Yo...Marcellus Drilling News
A decision issued by Judge David Hurd in a case of landowners from Broome and Tioga Counties in New York State against Chesapeake Energy and Statoilhydro. Chesapeake is attempting to extend leases on property for gas drilling claiming that the moratorium in New York has stopped them from drilling. Landowners claim the leases were signed long before horizontal hydraulic fracturing of shale was done and that Chesapeake could have drilled, conventionally, any time they chose to.
Employee class action v Google, Apple, Intel and othersDennis Howlett
Google, Apple, Intel and others are in the dock in a case where plaintiffs argue the operation of an illegal cartel designed to restrict pay to skilled workers.
The French Gourmet Inc., indicted recently for knowingly making false attestations on I-9 Forms, hiring employees unauthorized to work in the U.S., and employing those aliens after learning of their ineligibility to work. U.S. v. The French Gourmet Inc.
Restraining order against sex offender provided by Darren Chaker. Policing sex offenders is important, but if the scope of defining who is a sex offender expands, the police/parole budget does not. As explained on www.darrenchaker.org, sex offenses cannot be typically expunged, in Nevada, even if arrested for a sex offense is later dismissed, it cannot be sealed, however California allows for record sealing if lack of probable cause exists under PC851.8.
SDFL - Order Dismissing Various Claims - Jurisdiction - Trade SecretsPollard PLLC
The Plaintiff filed a 20 count lawsuit alleging, among other counts, theft of trade secrets, unjust enrichment, breach of fiduciary duty, trademark infringement, violations of the Computer Fraud Abuse Act and more.
This is the classic shock and awe, everything and the kitchen sink approach to litigation.
In this instance, that approach backfired spectacularly. The Court dismissed 17 of the counts on jurisdictional grounds -- holding they cannot be refiled in federal court but must be pursued, if at all, in state court.
The court also dismissed one count with prejudice. Denied the motion to dismiss with respect to one count. And granted leave to amend on one count--- but warned plaintiff and its counsel to mind Rule 11 if they decide to amend.
Think twice before you file a 20 count complaint in federal court where you are literally throwing everything at the wall and hoping something sticks.
Sample California motion to strike complaintLegalDocsPro
This sample motion to strike portions of a complaint for California was created by a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
Complaint for breach of contract, constructive fraud, constructive trust and unfair business practices against Joshua Macciello, self-pronounced bidder for the Dodgers and alleged film producer. Anyone with knowledge of Mr. Macciello's whereabouts, or who "invested" or "lent" money to Mr. Macciello, please contact CharismaticScam@gmail.com
Qui Tam Action Legal Papers Brought by Bernard Lisitza Against Pharmacy Compa...Behn Wyetzner, Chartered
Legal Motion Documentation on Medical Fraud Whistleblower Case brought by Qui Tam Law Firm Behn & Wyetzner Chartered against Omnicare Pharmaceuticals in the State of Massachusetts
Official Motion to add 200 new plaintiffs to the Armando Montelongo Lawsuit. This outlines how attempts to Arbitrate the case failed due to Montelongo refusing to follow the American Arbitration Association Rules, thus they declined to arbitrate the case and asked he remove their name from clauses in the contract. In addition, new plaintiff's have approached the case with similar details of fraud. See additional file with documentation supporting the case, or get a synopsis at http://www.jeannorton.com/armando-montelongo-rico-doubles/
PA Superior Court Decision: Northern Forests II, Inc. v. Keta Realty CompanyMarcellus Drilling News
In the Northern Forests case, the surface rights owner (Northern Forests) claimed they should also own the subsurface rights due to a legal principal called adverse possession. In reviewing the case, a PA trial court found the original case from 1989 awarding Northern Forests the mineral rights, was in error and the rights revert back to the original rights owners. PA Superior Court agreed and upheld the decision.
Decision by U.S. District Judge David N. Hurd on Force Majeure Case in New Yo...Marcellus Drilling News
A decision issued by Judge David Hurd in a case of landowners from Broome and Tioga Counties in New York State against Chesapeake Energy and Statoilhydro. Chesapeake is attempting to extend leases on property for gas drilling claiming that the moratorium in New York has stopped them from drilling. Landowners claim the leases were signed long before horizontal hydraulic fracturing of shale was done and that Chesapeake could have drilled, conventionally, any time they chose to.
Employee class action v Google, Apple, Intel and othersDennis Howlett
Google, Apple, Intel and others are in the dock in a case where plaintiffs argue the operation of an illegal cartel designed to restrict pay to skilled workers.
The French Gourmet Inc., indicted recently for knowingly making false attestations on I-9 Forms, hiring employees unauthorized to work in the U.S., and employing those aliens after learning of their ineligibility to work. U.S. v. The French Gourmet Inc.
Restraining order against sex offender provided by Darren Chaker. Policing sex offenders is important, but if the scope of defining who is a sex offender expands, the police/parole budget does not. As explained on www.darrenchaker.org, sex offenses cannot be typically expunged, in Nevada, even if arrested for a sex offense is later dismissed, it cannot be sealed, however California allows for record sealing if lack of probable cause exists under PC851.8.
SDFL - Order Dismissing Various Claims - Jurisdiction - Trade SecretsPollard PLLC
The Plaintiff filed a 20 count lawsuit alleging, among other counts, theft of trade secrets, unjust enrichment, breach of fiduciary duty, trademark infringement, violations of the Computer Fraud Abuse Act and more.
This is the classic shock and awe, everything and the kitchen sink approach to litigation.
In this instance, that approach backfired spectacularly. The Court dismissed 17 of the counts on jurisdictional grounds -- holding they cannot be refiled in federal court but must be pursued, if at all, in state court.
The court also dismissed one count with prejudice. Denied the motion to dismiss with respect to one count. And granted leave to amend on one count--- but warned plaintiff and its counsel to mind Rule 11 if they decide to amend.
Think twice before you file a 20 count complaint in federal court where you are literally throwing everything at the wall and hoping something sticks.
Sample California motion to strike complaintLegalDocsPro
This sample motion to strike portions of a complaint for California was created by a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years.
Complaint for breach of contract, constructive fraud, constructive trust and unfair business practices against Joshua Macciello, self-pronounced bidder for the Dodgers and alleged film producer. Anyone with knowledge of Mr. Macciello's whereabouts, or who "invested" or "lent" money to Mr. Macciello, please contact CharismaticScam@gmail.com
Qui Tam Action Legal Papers Brought by Bernard Lisitza Against Pharmacy Compa...Behn Wyetzner, Chartered
Legal Motion Documentation on Medical Fraud Whistleblower Case brought by Qui Tam Law Firm Behn & Wyetzner Chartered against Omnicare Pharmaceuticals in the State of Massachusetts
Official Motion to add 200 new plaintiffs to the Armando Montelongo Lawsuit. This outlines how attempts to Arbitrate the case failed due to Montelongo refusing to follow the American Arbitration Association Rules, thus they declined to arbitrate the case and asked he remove their name from clauses in the contract. In addition, new plaintiff's have approached the case with similar details of fraud. See additional file with documentation supporting the case, or get a synopsis at http://www.jeannorton.com/armando-montelongo-rico-doubles/
City Attorney Dennis Herrera sent a pre-litigation demand letter and draft complaint to McDonald's Corporation this afternoon, informing the Oak Brook, Ill.-based fast-food giant of its civil liability for violations of the California Drug Abatement Act and Unfair Competition Law at the property it owns in San Francisco's Haight-Ashbury neighborhood.
The letter and complaint sent to President and CEO Steve Easterbrook detail the bases for which McDonald's Corporation could be held legally accountable for the lawlessness harbored at its 730 Stanyan Street property, where its franchisee has defiantly refused to abate problems related to drug trafficking and other public nuisances. The McDonald's location "has generated nearly 1,100 calls for service" to the San Francisco Police Department since January 2012, according to Herrera's letter -- more than any other business in the area. Criminal activity includes arrests for sale and possession of LSD, psychedelic mushrooms, hashish, marijuana, and marijuana edibles as well as dozens of incidents involving fights, assaults, auto burglaries and even two dog attacks.
Herrera expressed "hope to enlist your assistance to resolve the public nuisance conditions" to McDonald's President and CEO, but was unequivocal in his intention to file suit if necessary, both to abate conditions plaguing the Haight-Ashbury neighborhood and to pursue injunctive relief, civil penalties, and attorneys' fees.
Armando Montelongo is being sued by 330 students. This is a recent filing that contains a synopsis, "...the system is comprised of worthless, dangerous, and unlawful advice that has caused the student Plaintiffs financial harm when they attempt to follow it. Defendants employ their seminars to loot the students’ retirement and other accounts, sell the students properties at inflated prices without disclosing their stake in them, and encourage the students to pursue real estate investments using Montelongo’s allies, who also victimize the students."
http://www.jeannorton.com/armando-montelongo-rico-doubles/
http://www.jeannorton.com/3137-2/
http://www.jeannorton.com/plot-thickens-armando-montelongo/
Opposition To Motion To Dismiss S Gerard Ange V Templer FGérard Angé
THE END GAME...
WHEN CORPORATIONS AND CEO'S CAN PAY TO SUBVERT THE FABRIC OF OUR CONSTITUTIONAL RIGHTS THAT PROTECT ALL CITIZENS. THEN... WE ALL LOSE.
THESE ARE THE OFFICIAL COURT TRANSCRIPTS & COURT DOCUMENTS:
After SIX YEARS and $100,000.00 in legal fees... OUR CASE DAMAGES WERE THROWN OUT BY A "SURPRISE SUBSTITUTED JUDGE" & ON A TRUMPED UP PHONY MISSING "Assignment of Claims" DOCUMENTS THAT WERE NEVER MISSING AT ALL.
READ THE SHOCKING OFFICIAL COURT TRANSCRIPTS AND THEN DECIDE FOR YOURSELF WHY OUR CONSTITUTIONAL RIGHT TO TRIAL WAS DENIED BY A SUBSTITUTED JUDGE.
http://www.win-tv.net/GAP_WINTV_Site/GAP_WIN-Tv_Website_Theft.html
Dawn Estep Stroud: Sued for Fraud - Defendant's motion to dismiss 1 of 2 default judgments against her Las Vegas, Nevada Corporation, Murdoch Group Inc. — an Executive Recruitment Firm in Newport Beach, CA — is Denied. Read Plaintiff's "Opposition" to motion.
Gobierno de Xóchitl Gálvez acusa a ITAM de ser opinólogos a los que se refier...toliro
Contrato del ITAM con la Delegación Miguel Hidalgo para publicar inserciones en la revista Foreign Affairs. Según una respuesta de transparencia de la delegación Miguel Hidalgo, el ITAM son los "opinólogos" que según Arne Aus Den Ruthen están enojados porque ya no cobran en la delegación.
Contrato entre administración de Ricardo Monreal y La Jornadatoliro
Contrato firmado entre la administración de Ricardo Monreal en la delegación Cuauhtémoc y el diario La Jornada para la publicación de un sólo anuncio por 105 mil pesos para difusión de "acciones" de la delegación Cuauhtémoc cuando Monreal apenas tenía dos meses y medio en el cargo. Esto a pesar de que la delegación Cuauhtémoc alega tener poco menos de 38 mil pesos de presupuesto para difusión en medios de comunicación.
Contrato GDF-BBmundo Direct SA de CV (marthadebayle.com)toliro
Contrato firmado por el Gobierno del Distrto Federal en marzo de 2015 con la empresa BBmundo Direct SA de CV para publicidad en los sitios de internet bbmundo.com y marythadebayle.com
Dictamen de reforma energetica del PRIAN que privatiza el petróleotoliro
Este es el protecto de dictamen de reforma energética que fraguaron en lo oscurito el PRI y el PAN en el Senado para privatizar el petróleo mediane modificaciones al artículo 27 Constitucional y mediante el artículo transitorio 4 (página 273).
Acusan a Peña Nieto y a Montiel de permitir fraude inmobiliariotoliro
Documento del Frente Mexiquense en defensa de una vivienda digna en el cual acusan a Enrique Peña Nieto y a Arturo Montiel de haber permitido fraude inmobiliario en el Estado de México.
Declaracion patrimonial de Enrique Peña Nieto 2013toliro
Declaración patrimonial de Enrique Peña Nieto dada a conocer el 16 de enero de 2013, y en la cual omite decir el costo de sus propiedades, así como la cantidad de dinero que tiene en sus cuentas bancarias e inversiones.
Informe de la CDHDF sobre detenciones arbitrarias por la policía del DFtoliro
Reporte preliminar de la Comisión de Derechos Humanos del DF denunciando 22 casos de detenciones arbitrarias y por lo menos 4 casos de tortura a los detenidos.
Dinorah Pizano. Punto de acuerdo. Construcciones irregulares DFtoliro
Punto de acuerdo presentado por la asambleista del PRD; Dinorah Pizano para llamar a comparacer a funcionario de Benito Juárez por construcciones irregulares.
blogdeizquierda.com - Reforma Laboral (proyecto de dictamen)toliro
Documento del proyecto de dictamen de la Reforma Laboral que pretenden aprobar el PAN y el PRI, y con el cual se vulneran los derechos de los trabajadores, se facilita el despido, se reducen los salarios a 7 pesos por hora, se recortan prestaciones laborales y se beneficia a los patrones.
Presentación de caso de presunto lavado de Luis Videgaray en Stoliro
Presentación de Ricardo Monreal sobre las presuntas triangulaciones de miles de millones de pesos del erario de Edomex por medio de una cuenta de Luis Videgaray en ScotiaBank,
Estados de cuenta dde Luis Videgaray Caso en ScotiaBank presentados por Ricardo Monreal en los que se documentan presuntas triangulaciones de recursos públicos a la campaña de Enrique Peña Nieto por un monto de más de 7 mil millones de pesos.
Business Valuation Principles for EntrepreneursBen Wann
This insightful presentation is designed to equip entrepreneurs with the essential knowledge and tools needed to accurately value their businesses. Understanding business valuation is crucial for making informed decisions, whether you're seeking investment, planning to sell, or simply want to gauge your company's worth.
Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
Discover the innovative and creative projects that highlight my journey throu...dylandmeas
Discover the innovative and creative projects that highlight my journey through Full Sail University. Below, you’ll find a collection of my work showcasing my skills and expertise in digital marketing, event planning, and media production.
"𝑩𝑬𝑮𝑼𝑵 𝑾𝑰𝑻𝑯 𝑻𝑱 𝑰𝑺 𝑯𝑨𝑳𝑭 𝑫𝑶𝑵𝑬"
𝐓𝐉 𝐂𝐨𝐦𝐬 (𝐓𝐉 𝐂𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬) is a professional event agency that includes experts in the event-organizing market in Vietnam, Korea, and ASEAN countries. We provide unlimited types of events from Music concerts, Fan meetings, and Culture festivals to Corporate events, Internal company events, Golf tournaments, MICE events, and Exhibitions.
𝐓𝐉 𝐂𝐨𝐦𝐬 provides unlimited package services including such as Event organizing, Event planning, Event production, Manpower, PR marketing, Design 2D/3D, VIP protocols, Interpreter agency, etc.
Sports events - Golf competitions/billiards competitions/company sports events: dynamic and challenging
⭐ 𝐅𝐞𝐚𝐭𝐮𝐫𝐞𝐝 𝐩𝐫𝐨𝐣𝐞𝐜𝐭𝐬:
➢ 2024 BAEKHYUN [Lonsdaleite] IN HO CHI MINH
➢ SUPER JUNIOR-L.S.S. THE SHOW : Th3ee Guys in HO CHI MINH
➢FreenBecky 1st Fan Meeting in Vietnam
➢CHILDREN ART EXHIBITION 2024: BEYOND BARRIERS
➢ WOW K-Music Festival 2023
➢ Winner [CROSS] Tour in HCM
➢ Super Show 9 in HCM with Super Junior
➢ HCMC - Gyeongsangbuk-do Culture and Tourism Festival
➢ Korean Vietnam Partnership - Fair with LG
➢ Korean President visits Samsung Electronics R&D Center
➢ Vietnam Food Expo with Lotte Wellfood
"𝐄𝐯𝐞𝐫𝐲 𝐞𝐯𝐞𝐧𝐭 𝐢𝐬 𝐚 𝐬𝐭𝐨𝐫𝐲, 𝐚 𝐬𝐩𝐞𝐜𝐢𝐚𝐥 𝐣𝐨𝐮𝐫𝐧𝐞𝐲. 𝐖𝐞 𝐚𝐥𝐰𝐚𝐲𝐬 𝐛𝐞𝐥𝐢𝐞𝐯𝐞 𝐭𝐡𝐚𝐭 𝐬𝐡𝐨𝐫𝐭𝐥𝐲 𝐲𝐨𝐮 𝐰𝐢𝐥𝐥 𝐛𝐞 𝐚 𝐩𝐚𝐫𝐭 𝐨𝐟 𝐨𝐮𝐫 𝐬𝐭𝐨𝐫𝐢𝐞𝐬."
Cracking the Workplace Discipline Code Main.pptxWorkforce Group
Cultivating and maintaining discipline within teams is a critical differentiator for successful organisations.
Forward-thinking leaders and business managers understand the impact that discipline has on organisational success. A disciplined workforce operates with clarity, focus, and a shared understanding of expectations, ultimately driving better results, optimising productivity, and facilitating seamless collaboration.
Although discipline is not a one-size-fits-all approach, it can help create a work environment that encourages personal growth and accountability rather than solely relying on punitive measures.
In this deck, you will learn the significance of workplace discipline for organisational success. You’ll also learn
• Four (4) workplace discipline methods you should consider
• The best and most practical approach to implementing workplace discipline.
• Three (3) key tips to maintain a disciplined workplace.
Personal Brand Statement:
As an Army veteran dedicated to lifelong learning, I bring a disciplined, strategic mindset to my pursuits. I am constantly expanding my knowledge to innovate and lead effectively. My journey is driven by a commitment to excellence, and to make a meaningful impact in the world.
[Note: This is a partial preview. To download this presentation, visit:
https://www.oeconsulting.com.sg/training-presentations]
Sustainability has become an increasingly critical topic as the world recognizes the need to protect our planet and its resources for future generations. Sustainability means meeting our current needs without compromising the ability of future generations to meet theirs. It involves long-term planning and consideration of the consequences of our actions. The goal is to create strategies that ensure the long-term viability of People, Planet, and Profit.
Leading companies such as Nike, Toyota, and Siemens are prioritizing sustainable innovation in their business models, setting an example for others to follow. In this Sustainability training presentation, you will learn key concepts, principles, and practices of sustainability applicable across industries. This training aims to create awareness and educate employees, senior executives, consultants, and other key stakeholders, including investors, policymakers, and supply chain partners, on the importance and implementation of sustainability.
LEARNING OBJECTIVES
1. Develop a comprehensive understanding of the fundamental principles and concepts that form the foundation of sustainability within corporate environments.
2. Explore the sustainability implementation model, focusing on effective measures and reporting strategies to track and communicate sustainability efforts.
3. Identify and define best practices and critical success factors essential for achieving sustainability goals within organizations.
CONTENTS
1. Introduction and Key Concepts of Sustainability
2. Principles and Practices of Sustainability
3. Measures and Reporting in Sustainability
4. Sustainability Implementation & Best Practices
To download the complete presentation, visit: https://www.oeconsulting.com.sg/training-presentations
Remote sensing and monitoring are changing the mining industry for the better. These are providing innovative solutions to long-standing challenges. Those related to exploration, extraction, and overall environmental management by mining technology companies Odisha. These technologies make use of satellite imaging, aerial photography and sensors to collect data that might be inaccessible or from hazardous locations. With the use of this technology, mining operations are becoming increasingly efficient. Let us gain more insight into the key aspects associated with remote sensing and monitoring when it comes to mining.
Explore our most comprehensive guide on lookback analysis at SafePaaS, covering access governance and how it can transform modern ERP audits. Browse now!
As a business owner in Delaware, staying on top of your tax obligations is paramount, especially with the annual deadline for Delaware Franchise Tax looming on March 1. One such obligation is the annual Delaware Franchise Tax, which serves as a crucial requirement for maintaining your company’s legal standing within the state. While the prospect of handling tax matters may seem daunting, rest assured that the process can be straightforward with the right guidance. In this comprehensive guide, we’ll walk you through the steps of filing your Delaware Franchise Tax and provide insights to help you navigate the process effectively.
Taurus Zodiac Sign_ Personality Traits and Sign Dates.pptxmy Pandit
Explore the world of the Taurus zodiac sign. Learn about their stability, determination, and appreciation for beauty. Discover how Taureans' grounded nature and hardworking mindset define their unique personality.
Taurus Zodiac Sign_ Personality Traits and Sign Dates.pptx
Demanda de Jose Aquino VS EPN
1. 1 MAXWELL C AGHA
BANKER’S HILL LAW FIRM APC
2 160 Thorn Street, Suite 200
San Diego, California 92103
3
Telephone (619) 230-0330
4 Facsimile (619) 230-1726
5
6 Attorney for Plaintiffs Jose Aquino and Frontera
Television Network LLP
7
8
9 UNITED STATES DISTRICT COURT
10 SOUTHERN DISTRICT OF CALIFORNIA
11 EDWARD J. SCHWARTZ U.S. COURTHOUSE
12
13 JOSE AQUINO and FRONTERA ) Case No.
TELEVISION NETWORK LLP )
14 ) COMPLAINT FOR:
Plaintiff, )
15 ) 1. BREACH OF WRITTEN
vs. ) CONTRACT;
16 ) 2. PROMISSORY ESTOPPEL, IN
) THE ALTERNATIVE;
17 Jiramos S. A. De CV; Alejandro ) 3. INTENTIONAL
Carrillo Garza Sada; GM Global S. A. ) MISREPRESENTATION;
18 de CV; Mario Ignacio Moran Jimenez; ) 4. SPECIFIC PERFORMANCE;
and Does 1 through 100, inclusive ) 5. FRAUD RICO Violations;
19 ) 6. CONCEALMENT;
) 7. BREACH OF THE COVENANT
20 Defendants. ) OF GOOD FAITH AND FAIR
) DEALING
21
(Jury Trial Demanded)
22
23 Plaintiffs, Jose Aquino and Frontera Television Network LLP, (the “Plaintiffs”),
24 by and through their undersigned attorney, for their Complaint in this action, hereby
25 alleges against Defendants’ Jiramos S. A. De CV; Alejandro Carrillo Garza Sada; GM
26 Global S. A. de CV; Mario Ignacio Moran Jimenez; and Does 1 through 100 on personal
27 knowledge as follows:
28 ///
2. 1 INTRODUCTION
2 1. This action is filed by the victims of a conspiracy to provide television
3 network to advertise in the United States for PRI campaign for the political presidential
4 candidacy of Enrique Pena Nieto. Pursuant to meeting between the parties, a contract
5 was entered between the parties for political advertising campaign for PRI candidate.
6 Defendants executed a contract to obtained funding from the Mexican government to
7 advertise in the United States for PRI campaign for the political presidential candidacy of
8 Enrique Pena Nieto. Defendants’ and each of them converted the funds for their own
9 private use. Defendants’ and each of them refused to pay for the advertising campaign
10 for PRI candidate Enrique Pena Nieto. Defendants’ and each of them concealed the fact
11 that they converted the advertising funds for their own private and personal use. The
12 defendants - Jiramos S. A. De CV; Alejandro Carrillo Garza Sada; GM Global S. A. de
13 CV; Mario Ignacio Moran Jimenez - are the perpetrators of a fraudulent conspiracy and
14 the members of a racketeering enterprise with the object of converting campaign funds
15 for their personal use, and denying plaintiffs from receiving their just benefits from the
16 written contract in the way of that objective.
17 2. Plaintiff, Jose Aquino is the owner of a television broadcasting network
18 known as Frontera Television Network LLP which is a Nevada Limited Liability
19 Partnership.
20 3. Defendant, Alejandro Carrillo Garza Sada met with Plaintiff Jose Aquino
21 in November of 2011, Mr. Jose Aquino, is the owner and President of Frontera
22 Television Network, and Jose Aquino was invited by Alejandro Carrillo Garza Sada to
23 meet Pepe Carrillo at a breakfast at the Café de la O del Conjunto Arcos, and Jose
24 Aquino was presented a project to disseminate the image and positioning of the Lic.
25 Enrique Peña Nieto, the candidate of the PRI to the Presidency of the Republic, through
26 spectacular, magazines, radio, television, Internet and social networks to be operated in
27 the United States of America, using the structure and relations of Plaintiff Jose Aquino
28 with the media in the United States, project for which Plaintiff Jose Aquino subsequently
Complaint for Damages for RICO Violations racketeering enterprise
-2-
3. 1 design a media Plan, for an amount of us $56 million US Dollars, being agreed under the
2 terms and conditions of the parties to the transaction. Defendant, Mario Ignacio Moran
3 Jimenez met with Plaintiff Jose Aquino in November of 2011, the owner and President
4 of Frontera Television Network, and Jose Aquino was invited to meet Pepe Carrillo at a
5 breakfast at the Café de la O del Conjunto Arcos, and Jose Aquino was presented a
6 project to disseminate the image and positioning of the Lic. Enrique Peña Nieto, the
7 candidate of the PRI to the Presidency of the Republic, through spectacular, magazines,
8 radio, television, Internet and social networks to be operated in the United States of
9 America, using the structure and relations of Plaintiff Jose Aquino with the media in the
10 United States, project for which Plaintiff Jose Aquino subsequently design a media Plan,
11 for an amount of us $56 million US Dollars, being agreed under the terms and conditions
12 of the parties to the transaction. Defendant, Alejandro Carrillo Garza Sada and
13 defendant, Mario Ignacio Moran Jimenez and Gisselle sister of Defendant, Mario
14 Ignacio Moran Jimenez all were the negotiators, as a matter of fact Defendant, Mario
15 Ignacio Moran Jimenez personally never was mentioned it was at all the times his sister
16 Giselle Moran and her company defendant, GM Global S. A. and defendant, Alejandro
17 Carrillo Garza Sada did all of the negotiating with the PRI , money was funded to Banca
18 Mifel in Virreyes Alicama 5 Mexico City to the account of Jiramos S.A C.V, both
19 defendants withdrew the money and split the money with the PRI Officials and never
20 Funded the project as was promise. Defendants used Plaintiff’s American companies to
21 justify a bonafide transaction, Plaintiff Jose Quino contacted the PRI officials - David
22 Lopez, Edwing Lino, Roberto Callejas, Alfredo Carrillo, and Jose Carrillo and Plaintiff
23 was threaten by it being stated to him that the money that was originated was funded by
24 companies belonging to the ZETAS cartel from drugs and for Plaintiff Jose Aquino to be
25 very careful not to make any noise or his life is in danger.
26 ///
27 ///
28 ///
Complaint for Damages for RICO Violations racketeering enterprise
-3-
4. 1 4. At the same time, defendant, Alejandro Carrillo Garza Sada and
2 defendant, Mario Ignacio Moran Jimenez had secretly determined that they will use
3 Plaintiff’s American companies to convert campaign funds for their personal use, and
4 denying plaintiffs from receiving their just benefits from the written contract. As part of
5 that plan, the defendants and others acting with them made numerous fraudulent
6 misrepresentations to Plaintiff Jose Aquino and concealed numerous material facts from
7 Plaintiff, Jose Aquino which helped to induce plaintiffs to entering into the written
8 contract. As a condition to make a payment of $15 million as advance payment for the
9 realization of the project, defendant, Alejandro Carrillo Garza Sada decided that on
10 January 6, 2012, that he will enter into a contract between "Intellimedia" and SISA, a
11 company dedicated to providing services to the agricultural sector, property of Mr.
12 Alejandro Ramirez Gonzalez, General Director of the Confederation of Porcicultores of
13 Mexico, who entered into a contract with defendant Alejandro Carrillo Garza Sada and
14 who assumed the responsibility to pay plaintiff Jose Aquino and his company, as well as
15 monitor the implementation of the project in the United States, turning the purchase
16 orders where specified in a manner clear and accurate, means, amounts, squares and
17 markets to cover, as well as ways to do recruitment and testing of investments (billing),
18 that was designed to enrich defendant, Alejandro Carrillo Garza Sada and defendant,
19 Mario Ignacio Moran Jimenez and others who were acting in concert with them.
20 JURISDICTION AND VENUE
21 5. The Court has subject matter jurisdiction over this action pursuant to 18
22 U.S.C. § 1964(c) and 28 U.S.C. § 1331.
23 6. This action arises under the laws of the United States, in particular, the
24 Racketeer Influenced and Corrupt Organizations Act ("RICO"), 18 U.S.C. § 1961 et seq.
25 7. The Court has supplemental jurisdiction over the state law claims for relief
26 pursuant to 28 U.S.C. § 1367(a), since these claims arise from a common nucleus of
27 operative facts and are so intertwined with the federal claims for relief as to make an
28 exercise of the Court's jurisdiction appropriate.
Complaint for Damages for RICO Violations racketeering enterprise
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5. 1 8. Venue is proper under 18 U.S.C. § 1965(a) and 28 U.S.C. § 1391(b).
2 9. Defendants are subject to the personal jurisdiction of this Court inasmuch
3 as they are located in Mexico and have purposefully availed themselves of the privileges
4 of doing business in California with regard to the actions alleged herein, and such
5 jurisdiction is reasonable.
6 10. Venue is proper in this district because 1) Plaintiff does business within the
7 Southern District of California; 2) Defendant Jiramos S. A. De CV is an organization
8 conducting business in Mexico; 3) Defendant Alejandro Carrillo Garza Sada resides in
9 Mexico; 4) Defendant GM Global S. A. de CV is an organization conducting business in
10 Mexico; 5) Defendant Mario Ignacio Moran Jimenez resides in Mexico; 6) a substantial
11 part of the acts complained of occurred in the Southern District of California and 7) the
12 contract at issue was performed in the Southern District of California (28 U.S.C. §
13 1391(b)(2)).
14 11. Contrary to numerous false representations made to plaintiff Jose Aquino
15 by defendant Alejandro Carrillo Garza Sada and defendant Mario Ignacio Moran
16 Jimenez, from the beginning of Alejandro Carrillo Garza Sada and defendant Mario
17 Ignacio Moran Jimenez involvement with Enrique Pena Nieto’s media candidacy
18 Campaign, he and his co-conspirators engaged in a scheme that had as its object the
19 conversion of campaign funds from the candidate of the PRI to the Presidency of the
20 Republic, so that defendant Alejandro Carrillo Garza Sada and his co-conspirators could
21 justify converting the campaign funds from the candidate of the PRI to the Presidency of
22 the Republic, for their own private and personal use. The conduct by the Defendants
23 that effectively destroyed the economic viability of the campaign for the candidate for
24 the PRI for the Presidency of the Republic included converting the campaign funds from
25 the candidate of the PRI to the Presidency of the Republic, for their own private and
26 personal use and stating to Plaintiff Jose Aquino that the money that was originated was
27 funded by companies belonging to the ZETAS cartel from drugs and for Plaintiff Jose
28 Aquino to be very careful not to make any noise or his life is in danger, abandoning
Complaint for Damages for RICO Violations racketeering enterprise
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6. 1 agreed-upon financial plans for the campaign for the candidate for the PRI for the
2 Presidency of the Republic, and undermining a planned recapitalization of the campaign
3 that would have added new respectful investors.
4 12. Between October 2011 and 2012, defendants continued to make numerous
5 false representations and material omissions to Plaintiff Jose Aquino as they carried out
6 their plans to convert campaign funds received by the ZETAS cartel from drug activities
7 and remove plaintiffs from standing in the way of that objective. As a result, plaintiffs'
8 have received nothing from their work, while defendants’ having allowed plaintiffs’ to
9 use their American Companies to make the campaign successful in the United States of
10 America. This dilution gave defendants’ the power to dispose of the candidate for the
11 PRI for the Presidency of the Republic and thus carry out the objective of defendants'
12 conspiracy.
13 13. Upon information and belief, in or about October 2011, Francisco Torrez
14 invited plaintiff Jose Aquino to meet PRI official Alejandro Carrillo Garza Sada, Mario
15 Ignacio Moran Jimenez, Giselle Morgan, Alfredo Carrillo, Jose Carrillo, David Lopez
16 and Roberto Calleja, all represented to plaintiff Jose Aquino to be PRI representatives
17 running Candidate EPN campaign for president of Mexico, after plaintiff Jose Aquino
18 offered a package of $15,000,000 US dollars, defendants’ decided to increase the amount
19 to $56,000,000 US dollars, after the parties agreed, within the next 5 days the parties
20 proceeded to sign all agreements. Plaintiff Jose Aquino for Frontera Television
21 Network LLP with Jiramos and Mario Ignacio Moran Jimenez for GM Global S. A. De
22 CV. Jiramos was represented by Alejandro Carrillo Garza Sada and GM Global S. A.
23 De CV was represented by Giselle Moran and her brother Mario Moran in which both
24 were contracting and signing the main contract as representatives agents between
25 Frontera Television Network LLP and PRI officials ( David Lopez, Edwin Lino, Alfredo
26 Carrillo, Jose Carrillo, Hugo, and Roberto Calleja within approximately 15 days all the
27 parties met and agreed to all of the terms and conditions and they all met at a notary
28 office and execute the written agreement, within two weeks after money was funded by
Complaint for Damages for RICO Violations racketeering enterprise
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7. 1 David Lopez and Edwin Lino to Alejandro Carrillo Garza Sada company Jiramos,
2 defendants’ informed plaintiff Jose Aquino that in order to make all of this legal that they
3 wanted to exchange the existing agreement for a new agreement, we all agreed
4 supplement the new written agreement and sign the second agreement were Jiramos was
5 not going to fund money to Frontera Television Network LLP but rather defendants’
6 asked plaintiff Jose Aquino to bring a new company known as Intellimedia LP and then
7 defendants had plaintiff Jose Aquino to sign new agreements under Intellimedia LP and
8 from their side they brought a new company call SISA The National Association of
9 Porcicultores and Agriculture. The written agreements were signed, defendants’ signed
10 the agreement as well, and promised to provide funding in the amount of $5,000,000 US
11 Dollars by April 1, 2012, notwithstanding this never happened and since then
12 defendants’ all changed their email addresses and also changed their cell phone numbers
13 and they all hiding and refuses to answer any telephone calls from plaintiff or his
14 attorney.
15 14. Upon information and belief, plaintiff believe that SISA is also a
16 government entity and plaintiff believes that SISA is well involved with the acts
17 complained of herein. Plaintiff believes that SISA was a party to the fraud because the
18 SISA had no intention to pay plaintiff for the use of his American Companies but only
19 agreed to do so in order to justify the money to be withdrawn from sponsors and from the
20 State of Mexico to pay for illegal interviews that were not allowed by IFE. Upon
21 information and belief, plaintiff believe that the IFE is also a government entity that
22 regulates campaign money.
23 15. Plaintiff sent his attorney to talk to Edwin Lino, Alfredo Carrillo, David
24 Lopez, Jose Carrillo and Roberto Calleja, and even have exchanged emails and plaintiff
25 was threaten saying this money was contributed by the Zeta Cartel and that plaintiff Jose
26 Aquino should be very careful.
27 ///
28 ///
Complaint for Damages for RICO Violations racketeering enterprise
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8. 1 16. All of the defendants thus attained their mutual goal of carrying out a
2 scheme to deprive plaintiffs’ of their labor. The defendants also attained their goal of
3 converting the campaign funds from the candidate of the PRI to the Presidency of the
4 Republic, for their own private and personal use and stating to Plaintiff Jose Aquino that
5 the money that was originated was funded by companies belonging to the ZETAS cartel
6 from drugs and for Plaintiff Jose Aquino to be very careful and not to make any noise or
7 his life is in danger, abandoning the agreed-upon financial plans for the campaign for the
8 candidate for the PRI for the Presidency of the Republic, and undermining a planned
9 recapitalization of the campaign that would have added new respectful investors.
10 17. This Complaint alleges claims against defendants under both the
11 Racketeering Influenced and Corrupt Organizations Act, 18 U.S.C. § 1961 et seq.
12 ("RICO"), and applicable state law.
13 18. Plaintiffs seek redress for their injuries, including compensatory damages,
14 which are tripled under RICO, and punitive damages in an amount no less than US $100
15 million. In addition, this action seeks a constructive trust over the campaign for the
16 candidate for the PRI for the Presidency of the Republic, and injunctive relief prohibiting
17 the contraction, for any new campaign advertising for the PRI for the Presidency of the
18 Republic.
19 THE PARTIES
20 Plaintiffs
21 19. Plaintiff Jose Aquino is an individual with his principal place of business
22 in San Diego County, and San Bernardino County California. Jose Aquino is an
23 accomplished businessman is Tele-media.
24 20. Plaintiff Frontera Television Network LLP is a Limited Liability
25 Partnership organized under the Laws of the State of Nevada with its managing partner
26 address of 711 S. Carson Street Suite 4, Carson City NV 89701. The agent for service
27 of process is Resident Agents of Nevada, Inc., located at 711 S. Carson Street Suite 4,
28 Carson City NV 89701.
Complaint for Damages for RICO Violations racketeering enterprise
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