1 

IN THE UNITED STATES DISTRICT COURT FOR THE 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO: 20-22829-CR-LFL 

IN THE MATTER OF THE 

EXTRADITION OF 

CESAR HORACIO DUARTE JAQUEZ

 / 

NOTICE OF SUPPLEMENTAL EVIDENCE

 Respondent, César Horacio Duarte Jáquez (“Mr. Duarte”), respectfully submits this Notice 

of Supplemental Evidence for the Court’s consideration in conjunction with his response (ECF 

No. 59, the “Response”) to the Government’s memorandum in support of extradition (ECF No. 

23, the “Extradition Memorandum”). 

 On January 20, 2021, the Chihuahua news website Entrelíneas reported on a press 

conference called by the Secretary of the City Council for Chihuahua,1 César Jáuregui-Moreno to 

discuss political persecution happening within the Chihuahua government.2 During the press 

conference, Mr. Jáuregui-Moreno revealed that Chihuahua’s Department of Justice had been 

pressuring protected (i.e., confidential) witnesses to provide false testimony linking María Eugenia 

 

1

 The Secretary of the City Council for Chihuahua (Secretario del Ayuntamiento de Chihuahua) 

is an administrative position within the Government of the City of Chihuahua, State of Chihuahua, 

that has amongst others duties (1) assisting the Mayor of Chihuahua (Presidente Municipal de 

Chihuahua) in all matters relating to the internal administration of the City; (2) assisting the Mayor 

also in relations with the branches of the State and with other cities, state and federal authorities; 

and (3) providing legal advice to other city entities (e.g., in connection with amparo or 

constitutional remedies filed by citizens). See Reglamento Interior del Municipio de Chihuahua, 

art. 29, Anexo del Periódico Oficial del Estado de Chihuahua [APOC] 05-10-2013, últimas 

reformas APOC 21-05-2013. 

2

 Denuncia Jáuregui acoso a testigos protegidos para involucrar a Maru Campos con Duarte, 

ENTRELÍNEAS (Jan. 20, 2021), available at https://entrelineas.com.mx/local/denuncia-jaureguiacoso-a-testigos-protegidos-para-involucrar-a-maru-campos-con-duarte/. 

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Campos-Galván, the current mayor of Chihuahua, with alleged acts of corruption committed by 

Mr. Duarte. The goal of this false testimony was to prevent her from winning the nomination to 

become the Partido Acción Nacional’s (“PAN”) candidate for governor of Chihuahua, because 

Javier Corral, the current governor, supports Ms. Campos-Galván’s opposition, Senator Gustavo 

Madero-Muñoz. 

 In support of his allegations, Mr. Jáuregui-Moreno stated that Jaime Herrera, the Treasury 

Secretary3 under Mr. Duarte and the Government’s primary witness against Mr. Duarte, had 

repeatedly called Mr. Jáuregui-Moreno seeking to speak with him. Eventually, Mr. JáureguiMoreno accepted Mr. Herrera’s calls on November 29, 2020 and December 28, 2020. In the course 

of Mr. Jáuregui-Moreno’s conversations with Mr. Herrera, Mr. Herrera revealed that: 

• High-ranking members of Chihuahua’s Department of Justice coerced Mr. Herrera 

to testify against many individuals, including by threatening political persecution 

against him; and 

• The testimony Mr. Herrera provided against these individuals, as well as other 

supporting evidence against them, is untrue. 

Mr. Jáuregui-Moreno presented recordings of these calls via close-captioned video during the press 

conference. He also presented excerpts from an expert report confirming that the voice on the 

video belonged to Mr. Herrera. A transcription and translation of the press conference, including 

the recorded calls, is attached as Exhibit 1. 

 

3

 The Treasury Secretary of the State of Chihuahua (Secretario de Hacienda del Estado de 

Chihuahua) is cabinet position within the Government of the State of Chihuahua, that has amongst 

other duties, the duty to define, design and implement the financial system for collection, 

expenditure, budgetary control, evaluation and governmental accounting, issuing the norms and 

guidelines for its operation. See Reglamento Interior de la Secretaría de Hacienda del Estado de 

Chihuahua, art. 8, APOC 04-04-2012, abrogado APOC 10-12-2014; see also Reglamento Interior 

de la Secretaría de Hacienda del Estado de Chihuahua, art. 8, APOC 10-12-2014, últimas reformas 

APOC 06-07-2019. 

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 Yesterday, January 24, 2020, the PAN held its primary election to define its candidate for 

governor of Chihuahua and the preliminary results (i.e., internal polls) show Ms. Campos-Galván 

as the winner. Mr. Madero-Muñoz recognized via Twitter that such preliminary results “no me 

favorecen” (are not in (his) favor) but that he will await for the official count.4

 Mr. Duarte respectfully requests that the Court consider the above evidence in conjunction 

with the Response as it undermines the Government’s showing of probable cause. Mr. Herrera is 

the Government’s primary witness against Mr. Duarte, having purportedly been instructed by Mr. 

Duarte to authorize and sign the various agreements between the State of Chihuahua and Union 

Ganadera and Financiera in his capacity as Secretary of the Treasury. See, e.g., ECF No. 1-5 at 

47, 58-59, 63-64, 68-69 (describing testimony of Mr. Herrera). Thus, Mr. Herrera’s testimony is 

central to the Government’s ability to provide probable cause that Mr. Duarte committed the 

crimes of peculado and asociacion para delinquir. See, e.g., ECF No. 23 at 24. In his telephone 

calls with Mr. Jáuregui-Moreno, however, Mr. Herrera confesses that the testimony he provided 

against numerous individuals, likely including Mr. Duarte, was false and coerced by Chihuahua’s 

Department of Justice. Thus, Mr. Herrera’s more recent admissions destroy the competency of his 

prior testimony, and the Court should not consider it in the context of assessing probable cause. 

See ECF No. 59 at 16-17 (citing Matter of Extradition of Contreras, 800 F. Supp. 1462, 1469 (S.D. 

Tex. 1992)); ECF No. 66 at 8 (citing Santos v. Thomas, 830 F.3d 987, 1005 (9th Cir. 2016)). 

 

 

 

4

 Maru Campos triunfa sobre Gustavo Madero en interna del PAN; será candidata a gubernatura 

de Chihuahua, LATINUS (Jan. 24, 2021), available at https://latinus.us/2021/01/24/maru-campostriunfa-gustavo-madero-interna-pan-candidata-gubernatura-pan-chihuahua/. 

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Dated: January 25, 2021. Respectfully submitted, 

BELL ROSQUETE REYES ESTEBAN, PLLC 

999 Ponce De Leon Blvd. 

Suite 1120 - Penthouse 

Coral Gables, Florida 33134 

Telephone: (305) 570-1610 

Facsimile: (305) 570-1599 

By: /S/ Henry P. Bell 

HENRY P. BELL 

Florida Bar No. 0090689 

hbell@brresq.com 

-andBy: /S/ Armando Rosquete 

ARMANDO ROSQUETE 

Florida Bar No. 648434 

arosquete@brresq.com 

QUINN EMANUEL URQUHART & 

SULLIVAN, LLP 

1300 I Street NW, Suite 900 

Washington, DC 20005 

Telephone: (202) 583-8000 

Facsimile: (202) 583-8100 

By: /S/ Juan Morillo 

JUAN MORILLO 

Florida Bar No. 135933 

juanmorillo@quinnemanuel.com 

-andGIANNA PUCCINELLI 

Admitted pro hac vice 

giannapuccinelli@quinnemanuel.com 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on January 25, 2021 a true and correct copy of the foregoing 

has been furnished electronically via ECF to all counsel of record. 

By: /S/ Juan Morillo 

 JUAN MORILLO 

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