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Case 5:13-cv-00152 Document.4 Filed 04/01/2013CPage 1 of 7 

UNITED STATES DISTRICT COURT 

WESTERN DISTRICT of TEXAS 

SAN ANTONIO DIVISION 

REYNALDO FLORES, 

# 961543, 

Plaintiff 

v. 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

SAN ANTONIO POLICE DEPARTMENT, § 

BEXARCOUNTY § 

·~ . DISTRICT ATTORNEY OFFICE, § 

BEXAR COUNTY ADULT § 

DETENTION CENTER, § 

Defendants 

§ 

§ 

SHOW CAUSE ORDER 

Civil Action 

No. SA-13-CA-152-XR 

Before the Court is Plaintiffs 42 U.S.C. § 1983 civil rights complaint. Plaintiff is 

incarcerated in the Bexar Cotmty Adult Detention Center. 

Plaintiff alleges the following. On December 29, 2011, Plaintiff was arrested without 

probable cause. He was charged with aggravated kidnaping and sexual assault. Police officers 

searched his dwelling and took one of his a vehicle, legal documents, construction equipment, and 

software information. Plaintiff contends the officers acted in complicity with the alleged victim to 

steal mor~ tha"l $1,250,000 in bek·ngin;;s frcm Plaintiff's dweilin~~ and st.:.;rage \.liltL Plaintiff 

contends the following police officers were involved in the arrest and in the search and seizure: 

Detective R. Vara, Detective Valadez R., Sergeant W. McCourt, Sgt. Porter, Officer David Berman, 

Officer B. Moen, and Officer M. Blanquis. Plaintiff asserts the charges were false. He claims the 

Bexar County District Attorney Office and Chris Martino acted in collusion with appointed counsel 

to try to coerce Plaintiff into pleading guilty for a IS-year sentence. He claims they knew he was . 

·~ . \ 
.. ...• . 

Defendant: REYNALDO FLORES 

JN #: 1501454-1 

DEFENDANT'S COPY 

Address· . SAN ANTONIO, TX 

Complainant: Myra Rubio 

CoDefendants: 

Offense Code/Charge: 100110- AGGRAVATED KIDNAPPING 

GJ: 548361 

Court #: :) q Q+h 

PH Court: 290 

SID #:961543 Cause#: 

Wit_ness: State's Attorney 2012 

TRUE BILL OF INDICTMENT 

FILED i 

I 

1---O'CLOCK,___--!-! M 

MAR 0 1 ZUll / 

DONNA KAY MQKINN~ 

DISTRICT CLER~. j 

BEXAR COUNTY, T~S 

·~· 

; 

I 

CR-196Q 

I 

IN THE NAME AND BY AUTHORITY OF THE STATE OFTEXAS, the Grand Jury of BeKar County, 'State of 

Texas, duly organized, empanelled and sworn as such at the January term, A.D., 2012, of the ;;~.C1f0 -ttl. 

Judicial District Court of said County, in said Court, at said term, do present in and to said Court that in the 

County and State aforesaid, and anterior to the presentment of this indictment: 

· Count I 

Paragraph A 

on or about the 23rd day of December, 2011, Reynaldo Flores did intentionally and knowingly abdu1 another 

person, riamely: Mayra Rubio, with intent to inflict bodily injury on Mayra Rubio or with intent to viol e or abuse 

Mayra Rubio sexually; . 1. 

' Paragraph B ·· I 

I . I 

on or about the 23rd day of December, 2011, Reyrialdo Flores did intentionally and knowingly abduc/t another 

person, namely: ·Mayra Rubio, with intent to terrori~e Mayra Rubio; 

Count II 

. i 

onorabo~~e23~day~~m~~~~~--=· 

intentionally and knowingly cause the penetration of th~ female sexual organ of Mayra Rubio, hereinpfter 

referred to as complainant, by the finger of the defendant, .sail:) act having been committed without t~e c~ns n~ 

of the complainant, in that the defendant compelled the complainant to submit and participate by thel~e ~ 

~ W/ 

physical force or violence; . · ~i 

· Count Ill : / 

! 

on or about the 23rd day of December, 2011, Reynaldo Fibres, hereinafter referred to as defendant, 1did 

intentionally, knowingly and recklessly cause bodily injury to Mayra Rubio, a member of the defendaTt's family or 

househoJd, .hereinafter referred to as complainant, by striking the complainant with the hand of the defendant 

and by scratching the complainant with the hand of the defendant; . ' ' ~''i filii·~'~ /7(,A~r!f /Lik Ra_ i? a:_cJ T/;)1fZ1?:iJ/f_~f' . Ulr y)'{''E ~ye ~· , . (/ .I j)D ·-#it£~---tl:r/b/?e ;J~ v&#~//- --r-c:::;;""/fr~l : . /?.M ;1 r .L/J/!{7~1'¥" r A77'Z"/'/Jet e/ . 
.. 12 

1 cabinets -- the jobs, finishing the jobs, whatever they 

2 pay him from there, with that they were supposed to 

3 pay we were supposed to pay the rent and the amount 

4 to the workers. 

5 And he was the one that wanted me to be iQ 

charge of the company, but I didn't have the means o~ 

7 the knowledge to do that. 

8 Q. Isn't it true you actually profited over 

9 $15,DOO while running his business? 

10 MR. DEMARTINO: I'm going to object to 

11 relevance, Judge. 

12 THE COURT: Sustained. 

13 Q. (BY MR. EASTLAND) And while he was in custody, 

14 do you remember who claimed all three vehicles and all 

15 the equipment? 

16 MR. DEMARTINO: Objection, relevance. 

17 THE COURT: Overruled. 

18 THE WITNESS: Well, the pickup was just a 

19 pickup that was still being owed to -- to the man and 

20 they still owed two months of payments on the truck. 

21 And the tools, those were just a couple of 

22 tools that he would use in the cabinets. And I took 

23 them and I took them home. 

24 MR. EASTLAND: No furthe~ questions, Your 

25 Honor. 

DEBRA JIMENEZ, CSR 

290TH JUDICIAL DISTRICT COURT 

210.335.1236 
v 

(I 

I 

1 .•. 

}· {, 

I J;· 

·...; 

No. 2012CR1969 

INCIDENT NO./TRN: 9110859780 

Count II 

THE STATE OF TEXAS 

vs. 

REYNALDOFLORES 

STATE ID No.: 8724279 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

IN THE 290TH DISTRICT 

COURT 

BEXAR. COUNTY, TEXAS 

JUDGMENT OF ACQUITTAL BY COURT 

Judge Presiding: 

Attorney for State: 

Charged Offense: 

sexual Assault 

.Charlting Instrument: 

HON. MELISA C SKINNER 

CHRISTOPHER WILLIAM 

DEMARTINO 

Count II OF THE INDICTMENT. 

Plea to Offense: 

NOT GUILTY 

Date judgment 

Entered: 

Attoriioy foi; 

Defend~tnt: 

Date of Acquittal 

11,26·2012 

Statute for Offense: 

22.0ll(A) PC 

Foreperson:. 

Jodee Gilmore 

11·26·2012 

DOUGLAS J KAPPMEYER 

All pertinvnt infonnalion, names and &88el8monts indicatsd above are inc:Orporatsd illto the language o£ the judgment below by rararence. 

This cause was called for trial in Bexar County, Texas. The State appeared by her District Attorney. 

Counsel I Waiver of Counsel (select one) 

0 Def~ndant appeared in person with Counsel. 

0 Defendant knowingly, intelligently, and voluntarily waived the right to representation by counsel in writing in open court. 

It appeared to the Court that Defendant was mentally competent and had pleaded as shown above to the charging 

instrument. Both parties announced ready for trial. Defendant waived tbe right or trial by jut·y and entered the plea indicated 

above. The Cou1't received the plea and entered it of record. Having heard the evidence submitted, the Court FINDS Defendant 

NOT GUILTY qf the charged offense. 

'l'he Cour:t ORDERS, ADJUDGES, AND DECREES that Defendant ia NOT GUILTY of the charged offense. The Court 

FURTHER ORDERS Defendant immediately discharged. . 

Clerk: 32809 

llllllllllllliiUIIDII 

DC2012CR1969 

104 OR!O!NAL 

JUDGE PRESIDING 

MELISA C SKINNER 

290TH DISTRICT COURT 

BEXAR COUNTY, TEXAS 

20 12CR 1969· ACQCRT Page I of I 
FIND A LAWYER 

{ Back to Search Results } 

OVERVIEW CONTACT AND MAP 

Mr. George Albritton Eastland 

· Bar Card Number: 24050547 

Work Address: 921 S Saint Marys St Ste 2 

San Antonio, TX 78205-3452 

Work Phone Number: 210-227-9800 

Primary Practice Location: San Antonio ,. Texas 

In cooperation "~tb 

LICENSE INFORMATION 

Bar Card Number: 24050547 

Texas License Date: 11/04/2005 

PRACTICE> INFORMATION 

Firm: 

Firm Size: 

Occupation: 

Practice Areas: 

Services Provided: 

Foreign Language 

Assistance: 

LAW SCHOOLS 

Law School 

St. Mary's University 

Law Office of Britt Eastland 

Solo 

Private Law Practice 

Criminal 

Hearing impaired translation: Not Specified 

ADA -accessible client service: Not Specified 

Language translation: Not Specified 

Spanish 

Graduation Date 

05/2005. 

Degree Earned 

Doctor of 

JuriSQ!Il_d_e~~~~(_J urjs 

Doctor (J.D.) 

Current Member Status 

Eligible To Practiceiri Te 

{ CONTACfTHIS LAWYEi 

{VISIT LAWYER WEBSITl 

WEBSITE 

www.britteastland.com 

COURTSOFADMITTTANCE 

Federal 

Texas Western District Court 

Other Courts 

None Reported By Attorney 

OTIIER STATES LICENSED 

None Reported By Attorney 

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38 

1 Against Mayra Rubio, used or attempted use of force you 

2 will find the defendant not guilty of felony. assau1;. 

3 I'm making those corrections. Other than those 

4 corrections, does the State have any object to the 

5 charge? 

6 

7 

8 

@ 

10 

11 

12 

13 

14 

//15 

16 

17 

18 

19 

20 

21 

@ 

23 

24 

@ 

MR. DEMARTINO: No objections, Your Honor. 

THE COURT: All right. Now, the defense? 

MR. EASTLAND: Yes, Your Honor. And before we 

make those formal objections I'd like to make a motion 

for directed verdict. 

------~ All right. 

/ ~ 

And based on? 

MR. EAS TLA~: Based on that hardly a scintilla 

~~ .... "'" 

presented to convict Mr. Flores of 

these three charges. 

THE COURT: Of each of the charges? 

MR. EASTLAND: Of each of them. 

THE COURT: And that will be~denied~ 

Now, did you have a request for the 

charge, and I will note for the record that the Court on 

its own has included, based on the defendant's 

testimony, unlawful restraint and necessity as a 

justification. Other than those additions to the 

charge, do you have any other request? 

MR. EASTLAND: We have no objection to the 

unlawful restraint. We are formally objecting to the 

DEBRA JIMENEZ, CSR 

290TH ,TUDIC:IAL DISTRICT COURT 

210.335.1236 
1ft-50061 

Mr. Reynaldo Flores 

#1912036,#961543 

CID Garza West Transfer-Facility - -- -------- ----

_________ ___ _425_0_Bighway 202 

-- ---- -- ------- --Beeville, TX 781 02-0000 

·- ..... -····--·-···---·-····---------·----------··-·········· ... ····-···· . .. 

--------------------------------------------------------------------------------------------------------------------------------------------------· 

TDCJ - INSTITUTIONAL DlVISIDN 

OFFICIAL LAVIN PASS 

f-~Df·1 IN I ET RPT I VE 

EFFECTIVE DATE; 05/29/2014 

FROM-TO TIME: 07:00-08:00 

START DRTE: 05/29/2014 END DATE: 05/29/2014 

ADMIT: 01912036 FLORES,REVNALDO 

REASON: 7:00 MAILROOM HOUSE: E4·-049T 

EDUC~ 

TITLE: COUNTROOM 
/ .... United States Court of Appeals 

LYLE W. CAYCE 

CLERK 

Mr. Reynaldo Flores 

FIFTH CffiCUIT 

OFFICE OF THE CLERK 

May 06, 2014 

· TEL. 504-310-7700 

· 600 S. MAESTRI PLACE 

NEW ORLEANS, LA 70130 

~~-=o===o=.coc==-#--1-9:1-2-Q3·6.,-- -#-9 615 4 3 

CID Garza West Transfer Facility 

4250 Highway 202 · 

Beeville, TX 78102-0000 

No. 14-50061 

Dear Mr. Flores, 

Reynaldo Flores v. San Antonio Police 

Department, et al 

USDC No. 5:13-CV-2 

The district court denied you in forma pauperis (IFP) status under 

28 U.S.C. § 1915(a) (3) and FED R. APP. P. 24 (a). You have 30 days 

from the date of this letter to pay the full $505.00 fees to the distric~ court clerk, or to challenge the district .. court's denial 

of IFP status. If you challenge the decision, you must apply to 

this court for IFP and include a brief supporting your position. 

Your brief may only discuss the reasons why you think the district 

court's denial of IFP was wrong. If you do not pay the full fees 

or file a motion and brief with this court, we will dismiss your 

appeal without further noti.ce, 5TH.CIR. R. 42~3. 

Sincerely, 

LYLE W. CAYCE, Cler~ 

.(Y)OJ-_(J ~o.J. 

By: 

Mary C. Stewart, Deputy Clerk .. 504-310-7694 
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