Exhibit 1

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Chihuahua

STATE GOVERNMENT

STATE ATTORNEY GENERAL’S OFFICE

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Investigation Case File No. 19-2018-28510

Date: May 25, 2020

Time: 5:00 p.m.

ADDITION TO STATEMENT TO THE PROSECUTOR’S OFFICE 

WITH CONFIDENTIAL IDENTITY CODE

56RT65PW7

In the city of Chihuahua, Chihuahua, at 5:00 p.m. (five o’clock in the afternoon) on MAY TWENTYFIFTH, IN THE YEAR TWO THOUSAND TWENTY, before the undersigned, Eduardo Cháirez Cos, 

Prosecutor for the Chihuahua State Attorney General’s Office, who acts pursuant to articles 21 of the 

Political Constitution of the United Mexican States, 118 and 119 of the Political Constitution of the State 

of Chihuahua, 131, 212, 213, 215, and 251 section X of the National Code of Criminal Procedure; as well 

as numbers 1, 2 paragraph B, and 12 of the Organic Law of the State Attorney General’s Office; and 19

and 20 of its internal Regulations, there appears freely and voluntarily the person with confidential identity 

code 56RT65PW7, whose personal information is contained in a secret sealed envelope of this institution 

and is likewise available to the Court for the relevant purposes. He is informed of his right to appoint a

Defense Attorney to assist him and may consult with that attorney regarding everything related to this 

proceeding; therefore MR. MARTÍN EDUARDO CASTAÑEDA is appointed in this act as his Defense

Attorney, and he is present at the act, and states that his name is as written, and he may be notified at the 

same address as the declarant, his occupation is Attorney, with professional license number 5280133, and 

he states that at this time he accepts the conferred position and affirms that he will faithfully discharge his 

duties. Next, once he has the technical legal assistance of his defense attorney, he is informed of his

constitutional and legal rights, established in article 20 paragraph B of the Political Constitution of the 

United Mexican States and numbers 113 and 114 of the National Code of Criminal Procedure, which state, 

respectively: “Article 20. [...] B. Regarding the rights of all suspects: I. They will be presumed innocent 

until found guilty via judgment handed down by the judge in the case; II. They may make a statement or 

remain silent. They will be informed of the reasons for their arrest at the time of arrest, and of their right to 

remain silent, which may not be used against them. Holding them incommunicado or intimidating or

torturing them is prohibited and will be sanctioned by criminal law. Confession made without the presence

of the defense attorney will lack all probative value; III. They will be informed of the acts with which they 

are charged and their rights both at the time of arrest and at their appearance before the Prosecutor’s Office 

or judge. In the case of organized crime, the judicial authority will be able to authorize keeping the accuser’s 

name and information confidential. The law will establish benefits for the accused, defendant, or convict 

who effectively assists in the investigation and prosecution of organized crime; IV. Offered witnesses and 

other relevant evidence will be received, granting the time deemed necessary by law for that purpose and 

assisting to secure the appearance of the people whose testimony is requested, as set forth by law; V. They 

will be tried at a public hearing by a judge or court. Publicity may only be restricted in exceptional cases 

determined by law

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Chihuahua

STATE GOVERNMENT

STATE ATTORNEY GENERAL’S OFFICE

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for reasons of national security, public safety, protection of victims, witnesses, and minors, when the 

disclosure of legally protected information is put at risk, or when the court deems that there are well-founded 

reasons to justify it. In organized crime, the records made in the investigation phase may have probative 

value when they cannot be reproduced at trial or there is a risk to witnesses or victims. The foregoing is 

without prejudice to the right of the accused to object to or challenge them and provide evidence against 

them; VI. They will be provided all of the information requested for their defense that is recorded in the 

case. The suspect and their defense attorney will have access to the records of the investigation when the 

suspect has been arrested and when the intent is to take their statement or interview them. Likewise, before 

their first appearance before a judge they will be able to consult those records, with sufficient time to prepare 

a defense. From this time the proceedings of the investigation will not be able to be kept confidential, except 

in those exceptional cases expressly identified by law when it is essential to safeguard the success of the 

investigation and provided they are disclosed in a timely manner so as not to affect the right to a defense; 

VII. They will be tried within four months if the maximum penalty for the crimes in question does not 

exceed two years in prison, and within one year if the penalty exceeds that time, unless a longer period is 

requested for the defense; VIII. They will have the right to an adequate defense by an attorney, who they 

will freely choose even from the time of arrest. If they do not want to or cannot appoint an attorney, after 

having been asked to do so, the judge will appoint a public defender. They will also have the right for their 

defense attorney to appear in all acts of the case and the attorney will be obligated to do so as often as 

requested, and IX. In no case will imprisonment or detention be extended as a result of failure to pay defense 

attorney’s fees or for any other provision of money, due to civil liability, or any other similar reason. Pretrial 

detention may not exceed the maximum time of the penalty set by law for the crime that led to the case and 

in no event will it be longer than two years, unless its extension is a result of the suspect’s exercise of the 

right to a defense. If this term comes to an end without judgment having been rendered, the suspect will be 

immediately released while the case continues, without detriment to the imposition of other precautionary 

measures. All prison sentences imposed by judgment will count the time in custody. [...]”; “Article 113. 

Rights of the suspect. The suspect will have the following rights: I. To be considered and treated as innocent 

until their guilt is proven; II. To communicate with a family member and with their Defense Attorney when 

they are arrested, and the Prosecutor’s Office must make every effort to help them achieve this; III. To 

make a statement or remain silent, with the understanding that their silence will not be able to be used 

against them; IV. To be assisted by their Defense Attorney at the time they make their statement, as well as 

during any other proceeding, and to consult privately with the attorney beforehand; V. To be informed at 

the time of arrest, as well as at their appearance before the Public Prosecutor’s Office or Due Process Judge,

of the acts of which they are accused and their rights, as well as, where applicable, the reason for their 

detention and the public official who ordered it, showing them, as appropriate, the warrant issued for them; 

VI. Not to be subjected at any time during the proceeding to techniques or methods that threaten their 

dignity, induce or alter their free will; VII. To request before the judicial authority the modification of the 

precautionary measure that has been imposed, in event they are in pretrial detention, under the 

circumstances indicated in this Code; VIII. For the suspect and their attorney to have access, except as 

provided by law, to the records of the investigation, as well as to obtain a free copy, photographic or 

electronic record of the same, pursuant to articles 218 and 219 of this Code; IX. To receive the relevant 

evidence offered, being granted the necessary time for that purpose and assistance to secure the appearance 

of the people

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Chihuahua

STATE GOVERNMENT

STATE ATTORNEY GENERAL’S OFFICE

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whose testimony is requested and cannot be directly presented, as established in this Code; X. To be tried 

at a hearing by a trial court, within four months if the maximum penalty for the crimes in question does not 

exceed two years in prison, and within one year if the penalty exceeds that time, unless a longer period is 

requested for their defense; XI. To have an adequate defense by a lawyer or an attorney-at-law, with 

professional license, who may be freely selected from the time of arrest and, barring this, by the 

corresponding Public Defender, as well as to meet or talk with that attorney in strict confidentiality; XII. 

To be assisted at no charge by a translator or interpreter should they not understand or speak the Spanish 

language; when the suspect belongs to an indigenous group or community, the Defense Attorney must know 

their language and culture, and, if this is not possible, must be assisted by an interpreter of the culture and 

language in question; XIII. To be presented before the Prosecutor’s Office or before the Due Process Judge, 

as appropriate, immediately after arrest or apprehension; XIV. Not to be exhibited to the media; XV. Not 

to be presented to the community as guilty; XVI. To request from the time of their arrest, social assistance 

for minors or disabled persons whose personal care is their responsibility; XVII. To obtain their release 

should the arrest have been made without a pretrial detention order or other precautionary measure limiting 

their freedom; XVIII. To have the corresponding embassy or consulate informed upon arrest, and to be 

provided immigration assistance when they are a foreign national, and XIX. The rest as set forth in this 

Code and other applicable provisions. The terms to which section X of this article refer will be counted 

from the initial hearing to the time in which judgment is handed down by the competent Court. When the 

suspect has minors or disabled persons under their care, or adult dependents, and there is no one else to 

provide that care, the Public Prosecutor’s Office must direct them to the corresponding social welfare 

institutions so that they may receive protection.” “Article 114. Statement of the suspect. The suspect will 

have the right to make a statement at any stage of the proceeding. In this event, they will be able to do it 

before the Public Prosecutor’s Office or before the Court, with full respect for their rights and in the

presence of their Defense Attorney. Should the suspect tell the Police they wish to make a statement 

regarding the acts under investigation, the Police must communicate this to the Public Prosecutor’s Office 

in order for the statements to be received with the formalities set forth in this Code.” As a result, once the 

content of the previous articles is read and the appearing party duly informed of his rights, he states that it 

is his wish to participate in this proceeding through his statement, so he is instructed to tell the truth before 

this authority and says that he will do so, and he is informed of his right to remain silent at any time, if any 

of the acts regarding which he is going to make a statement is prejudicial to him, to which the appearing 

party acknowledges that he is informed of this and he adds that his name and other general information is 

correct as they have been entered on the personal identification record sheet with confidential identity code. 

Next and with regard to the acts related to Investigation Case File 19-2018-28510, after a discussion with 

his attorney, he states that he is appearing before the Public Prosecutor’s Office to provide an addition to 

his statement as follows: As I already said in my previous statement dated December 8, 2018, I am afraid 

that the information provided puts my surroundings at risk, given its sensitive nature, specifically because 

I have been the victim of threats against my person, issued by the former governor himself, CESAR 

HORACIO DUARTE JAQUEZ, and also by people who have attempted to harm me, operating under the 

extensive networks of influence that this man has developed

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Chihuahua

STATE GOVERNMENT

STATE ATTORNEY GENERAL’S OFFICE

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throughout his career as a politician and that carried him to the governor’s office in the State of Chihuahua, 

in the 2010−2016 term. So, with regard to the threats of which I have been a victim, I want to state that as 

a result of the events that took place on March 20, 2017, after the death of CARLOS HERMOSILLO, 

following his unexpected roadway “accident,” and as a result of a leak so that CÉSAR DUARTE knew or 

was informed by GERARDO VILLEGAS that I was cooperating with the State authorities who were 

investigating acts of corruption that took place in the state government precisely when he was serving as 

governor in the 2010−2016 period, GERARDO VILLEGAS openly threatened me through a Blackberry 

text message on Thursday, March 23, with alleged criminal acts that he would make known about me. The 

next day, Friday, March 24, 2017, I received a call from CESAR DUARTE himself, summoning me to come 

as soon as possible, setting as a date the next Sunday, March 26, in the city of El Paso, Texas, in the United 

States of America, in a restaurant located in the Sunland Park area, very close to the shopping center of 

the same name, specifically the IHOP restaurant, we agreed to meet at one in the afternoon, so that Sunday 

the 26th I went to the meeting with my wife, we traveled by land from the city of Chihuahua, we crossed to 

El Paso, and we went to the indicated restaurant, and as soon as we arrived we went in and my wife and I 

were ordering coffee and in a few minutes CÉSAR DUARTE arrived, and he came alone, which led my wife 

to go to one of these stores that sell name-brand clothes at big discounts, Ross or Marshalls (one of these) 

and I stayed alone with former governor DUARTE, and at that time he asked me if it wouldn’t be better to 

go out walking in the parking lot of the plaza where the IHOP was located, and that’s what we did. Clearly, 

from the start, his gestures and attitude towards me were of anger and he had an aggressive tone, I had 

started the conversation regarding the accident and death of CARLOS HERMOSILLO, just the week before, 

to which he immediately said that CARLOS HERMOSILLO had been with him in El Paso a day before the 

accident, and that he had incidentally told him that he had seen me at the Mexico City airport two weeks 

before, and that I had avoided him, making my disapproval clear, which I told him had not been the case. 

Then DUARTE told me that he knew through several sources that he did not identify, that they had seen me 

meet with my attorney and that I was desperately trying for a State Government authority to receive me, 

and that he knew that I wanted to be a protected witness. He indicated to me in a joking and sarcastic tone 

that the concept did not exist, but he let me know that because I was acting in that regard, and because of 

what GERARDO VILLEGAS had told him, he wanted to know directly from me whether I was going to be 

with him or against him. And if it was the latter, that I would experience the consequences. I let him know, 

faced with a clear threat of that type, that all I wanted was to take care of my family and confronted with

the questions that the authorities would ask me about various acts, I was going to be truthful. And right 

away he asked me what acts they could ask me about where I could be accused of some responsibility, and 

I started by referring to the FEPADE [Special Prosecutor’s Office for Electoral Crimes] case, in which I 

had been identified as arranging and carrying out the discounts in wages of State government workers in 

order to direct those funds to the Institutional Revolutionary Party (PRI), making him see that this had 

started in the year 2010 and not in 2012 when I entered. On that matter he responded to me that he wasn’t 

at all concerned since he had asked GUILLERMO DOWELL, then the State PRI chairman, to resolve the 

issue with the PRI National Executive Committee, and it was not all that serious. Next I let him know that 

GERARDO VILLEGAS had checked with him and he had authorized them to carry out a diversion of around 

400 million pesos with the company ONLINE S.A. de C.V., to which he said that he didn’t know anything, 

and as he had always said, he would always deny this and all of the other acts 

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Chihuahua

STATE GOVERNMENT

STATE ATTORNEY GENERAL’S OFFICE

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attributed to him. So next I referred to another matter he knew about, and that was a transaction carried 

out by RICARDO YAÑEZ and ALEJANDRO GUTIERREZ, in which they diverted funds belonging to the 

public treasury of the State of Chihuahua, as much as 250 million pesos, that were allocated to the national 

PRI. Concerning this he told me that was RICARDO YAÑEZ’s problem, and that he was going to deny 

knowledge of everything that connected it to him. Finally, I told him that GERARDO VILLEGAS had 

previously told me about a case that I was not familiar with where they invoiced the Government of the 

State of Chihuahua for sham operations through a company called KEPLER S.A. de C.V., in the amount of 

120 million pesos. As in the previous cases, the former governor indicated to me that he didn’t know 

anything, and that he was always going to deny these acts, and he directly and bluntly reiterated, with 

anger towards me, that he was not responsible for any of this, and that where applicable, if I participated 

as a protected witness, that I was wrong and all they wanted was to use me in order to then prosecute me. 

During about an hour of rough and threatening conversation, he let me know that they were never going 

to be able to arrest him and on the contrary, there would come a time when he would first put the current 

Governor Javier Corral in prison, because he had the full support of the federal authorities, and he likewise 

let me know that he would get those federal authorities to go after me and put me in prison. Finally, and 

after these warnings and threats, he again told me that I would be better off with him and with that he shook 

my hand, with enough force to intimidate me, and concluded by asking me if I had stolen money to which I 

answered no, and he bluntly told me “me neither.” And that was the goodbye. He went back to his vehicle 

and I went to find my wife. And that is how this chapter with the former governor ended.

I want to add that before that encounter I had in several calls and in some meetings with him and his family 

specific communication in which I was trying to get the process he was carrying out with the Office of the 

Attorney General of the Republic to finally arrive at a conclusion and decision in the UNION PROGRESO 

case, however this did not progress, and the final agreement with my attorney was that this meeting on 

Sunday, March 26, would be the last one with CESAR DUARTE, and that in it I would be clear about my 

future actions, completely separating myself from this man; nevertheless, that same Sunday, upon returning 

to the city of Chihuahua, it was already late, around 10 in the evening, I received a call on my cell phone 

from Mr. RICARDO SANCHEZ REYES RETANA, who was CÉSAR DUARTE’s defense attorney, telling 

me that it was urgent that I speak with GERARDO VILLEGAS, because they knew that the authority was 

investigating what he called a “big case,” and later he specified that it was a case involving the company 

ONLINE S.A. de C.V.—regarding the diversion of funds in a very high amount, which I already mentioned, 

totaling nearly $400 million pesos—and in view of that investigation I should go to Mexico City right away 

the next day, and I let him know that GERARDO VILLEGAS was no longer taking my calls, that it had been 

several days, to which he said that he would talk to GERARDO, to coordinate that meeting in Mexico City 

so we could come to an agreement to find an alternative that would allow us to avoid the charges since this 

case was for a very significant amount, even if it was necessary to create documents that did not exist in 

order to verify the payment of the diverted funds. And so GERARDO VILLEGAS got in touch with me right

after I hung up with the attorney SANCHEZ REYES RETANA, and he told me that he and EVER AGUILAR 

would travel to Mexico City the next day, Monday, that they would leave early and wait for me there, 

without specifying a place to meet, just that they would be on Paseo de la Reforma, to which I said that I 

would have to check flight options as appropriate to see if it would be possible to 

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Chihuahua

STATE GOVERNMENT

STATE ATTORNEY GENERAL’S OFFICE

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meet them, a situation that I had definitely decided would not happen. The next morning, it was March 27, 

2017, I sent a message to GERARDO VILLEGAS to ask him if they had agreed on a place for us to meet in 

Mexico City, but he did not reply to me, so I assumed he had turned off his cell phone. Around nine in the 

morning I contacted Mr. SANCHEZ REYES RETANA to see about the place where the meeting would be 

held, clarifying that as I already indicated, I had no intention of going, and then he told me that there was 

no longer a need to go to Mexico City because they had just arrested GERARDO VILLEGAS. And that 

same day there were more arrests, they also arrested JAVIER GARFIO PACHECO, who had been 

Secretary of Communications and Public Works, in the morning; and in the evening, RICARDO YAÑEZ, 

who held various positions and ended the 2010−2016 state administration as Secretary of Education, and 

GERARDO VILLEGAS himself had also been a public official as he held the position of Director General 

of Administration of the State Government Office of the Secretary of the Treasury. Just that same Monday 

afternoon, around 5 in the afternoon, I was at home, with my attorney, when I received a call on the home 

phone, and on answering it turned out that CÉSAR DUARTE was calling me, he told me that what was 

happening was “bullshit,” that what they had done to his nephew GERARDO VILLEGAS was bullshit, and 

then he asked me if I was covered, to which I replied yes, and he immediately hung up. I understand that 

he called the house to learn whether they had arrested me too. After this call, I never again had contact 

with CÉSAR DUARTE. The next day, March 28, it was published in some media outlets that an arrest 

warrant had been issued against CÉSAR DUARTE, and since then he has been a fugitive, perhaps hidden 

somewhere in the United States, which was the country where I saw him for the last time. Nevertheless, due 

to his political contacts and the corruption networks he developed, as well as his extensive financial 

capacity in large part because of the funds he obtained illegally, he may still have the influence to at any 

time carry out the threats that he made against me from that time that I saw him for the last time in El Paso, 

Texas, or they may harm my family, since he is a vindictive person.

It is relevant to note that throughout this entire time, and above all stemming from the arrest of Mr. 

ALEJANDRO GUTIERREZ GUTIERREZ, Director General of Finance of the PRI National Executive 

Committee, in December of 2017, since a note was published in the national newspaper Reforma about that 

arrest—and I do not understand why my name was mentioned in it as a person who testified against Mr. 

GUTIÉRREZ and former governor DUARTE given that my identity was confidential—as a result of that 

Diario Reforma publication the threats against me were again renewed, even a friend of mine, a former 

representative named LAURA DOMINGUEZ, talked to me to tell me to be very careful because they were 

going to come after me, and that CÉSAR DUARTE still had federal support, from the then Office of the 

Attorney General of the Republic (PGR) and from the Ministry of Internal Affairs, to go after me. To the 

extent that on February 6, 2018, they arranged a meeting for me with ALFONSO NAVARRETE PRIDA, 

who at that time was in the Ministry of Internal Affairs, and the meeting took place in Bucareli, in Mexico 

City, and there NAVARRETE PRIDA told me to change my testimony to disassociate CÉSAR DUARTE and 

ALEJANDRO GUTIÉRREZ, and that in exchange they would give me a plea bargain. I refused this given 

that what he was asking from me was not the truth of the matter. And since I didn’t change my statement, 

that is what I said before the State authorities, which led to the arrest of ALEJANDRO GUTIÉRREZ 

GUTIÉRREZ, on February 9, they started an investigation against me in the then Office of the Attorney 

General of the Republic. And at that time the PGR told me that they had been instructed to go after me 

whatever the cost, and that they were going to 

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Chihuahua

STATE GOVERNMENT

STATE ATTORNEY GENERAL’S OFFICE

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go after my family. All of these threats continued until the new federal administration came in, in December 

of 2018, from a party other than PRI, and they ended with the departure of Attorney General ALBERTO 

ELIAS BELTRAN, and the arrival of the new Attorney General ALEJANDRO GERTZ MANERO. And I am 

saying this to show the vast sphere of influence of former governor CESAR HORACIO DUARTE JÁQUEZ 

and his networks of complicity, which have sought to injure and harm me, including through the 

manipulation of public officials who instead of seeking justice, focused on trying to harm me and my family. 

This is all I have to say in this matter. Having nothing further to state, in this act he is informed of the 

content of article 256 of the National Code of Criminal Procedure, regarding cases in which Plea Bargains 

apply, which indicates in its section V as follows: “Article 256. [...] When the suspect provides essential 

information useful for the prosecution of a crime more serious than the one of which they are accused [...]” 

In addition, he is informed of his obligation to appear at the trial, as well as the obligation to communicate 

any change of address or residence. Next, after a conversation held with his attorney, he states: I 

acknowledge what you just told me and I promise to appear at trial if called and to give my testimony based 

on everything I have declared regarding these acts, and I likewise promise to communicate to this authority 

any change of address I might have. This is all I have to say. This is all he has to say. Next, the Suspect’s 

Defense Attorney is given the floor, and he says: I do not wish to make any type of statement. With the 

foregoing, this proceeding is concluded, and after the declarant reads this document in its entirety, he ratifies 

its content and states his agreement with it by affixing his fingerprint in the margin at the bottom of each 

page of this record, for the relevant purposes, and the Public Defender likewise signs, before the Prosecutor 

for the State Attorney General’s Office.

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“56RT65PW7”

Declarant

[signature]

MARTÍN EDUARDO CASTAÑEDA

Defense Attorney

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EDUARDO CHÁIREZ COS

Prosecutor

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JTG, inc.

8245 Boone Boulevard 

Suite 700

Vienna, Virginia 

22182

1.703.548.7570 voice

1.877.746.8906 toll free

1.703.548.8223 fax

jtg-inc.com

CERTIFICATE OF TRANSLATION

I, Heather Oland , certify that I am competent to translate this document, and 

that the translation is true and accurate, to the best of my abilities. Archival seals, stamps, 

and certifications have been translated here.

Spanish file name:

PRIORITY Anexo¿ Declaración Ministerial de 56RT65PW7

English file name:

PRIORITY Anexo¿ Declaración Ministerial de 56RT65PW7_T

I certify under penalty of perjury, pursuant to 28 U.S.C. 1746, that the attached translation 

of the referenced file is true and correct.

Executed this 14th day of July, 2020.

_ __________________

Signature 

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