Declaration of Jonathan Villareal Page 1 of 14

IN THE UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

JONATHAN VILLAREAL, 

individually and derivatively on behalf 

of ZROBLACK, LLC. 

Plaintiffs, 

v. 

JOHN SAENZ, MIGUEL

VILLARREAL, JR., and GUNN, 

LEE, & CAVE, P.C.

Defendants

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CIVIL ACTION NO. ___________

__________________________________________________________________________

DECLARATION OF JONATHAN VILLAREAL

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1. My name is Jonathan Villareal. I am above the age of 18 and competent to make 

this unsworn declaration. Except as otherwise indicated, the following facts are within my personal 

knowledge and true and correct. I am an individual and resident of Boerne, Kendall County, Texas.

2. I developed proprietary technology which allows one to access cell phones, 

including iPhones. This technology can be used to access a cell phone wirelessly and wipe the 

data. This is useful, in that if a user¶s phone is stolen, the owner can wipe its data remotely even if 

the security password has been changed. My company, Plaintiff ZroBlack, LLC (3ZroBlack ́), is 

one of the few companies in the world that can do this.

3. In January of 2019, I was negotiating with a technology company in Finland for the 

licensing of the technology. John Saenz (3Saen] ́), Zho is married to my cousin, claimed that he 

could fill voids my previous partner could not. Saenz represented to me that he had the business 

experience and government contacts to market the technology to the government. He represented 

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that he could use his 3contacts ́ in the militar\ and technolog\ business sectors to bolster sales and 

proposed forming a company as a vehicle to market the technology. That company was to be 

ZroBlack. I believed him and, as a family member, trusted him. I relied on the representations he 

made, and as a result we agreed to form a limited liability company to market the software to the 

company in Finland. Saenz was to be CEO and I took on the technology role as Security Engineer.

4. On Januar\ 11, 2019, Saen] purchased ZroBlack¶s domain name, 

www.zroblack.com, from GoDaddy. He did this in anticipation of our forming ZroBlack, and he 

was to hold the domain name on behalf of ZroBlack. GoDadd\ hosted ZroBlack¶s Zebsite and 

email server. The login and passZord information for accessing ZroBlack¶s GoDadd\ account and 

for accessing the laptop was confidential and not shared with anyone.

5. On January 14, 2019, we formed ZroBlack, LLC, organized under the laws of the 

State of Delaware. Exhibit 2 is a true and correct cop\ of the compan\¶s Certificate of Formation.

Saenz and I were ZroBlack¶s founding members and each owned fifty percent. ZroBlack was 

founded as an IT company to provide applications and services regarding cell phone data capture 

and erasure. We planned to offer two different types of software, one for commercial use and one 

for governmental use. I was to perform all the in-house coding and servicing of the technology.

Saenz was responsible for client engagement and promoting the company.

6. Saenz and I executed a Limited Liability Company Operating Agreement for 

ZroBlack, LLC (hereinafter, 3Operating Agreement ́). E[hibit 3 is a true and correct copy of the 

Operating Agreement. Section 4.7 of the Operating Agreement states:

Title to the Company's assets will be held in the Company's name or in 

the name of any nominee designated by the Members. The Members 

have power to enter into a nominee agreement with any person, and that 

agreement may contain provisions indemnifying the nominee, except 

for his or her willful misconduct.

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7. I also assigned my intellectual property rights in the software technology, which 

included the code for accessing cell phones wirelessly, to ZroBlack. Exhibit 4 is a true and correct 

copy of my Assignment of Intellectual Property Rights. However, I do not have a signed copy. 

Saenz has the signed assignment and has never given me a copy. ZroBlack¶s trade secrets consist 

of my code for accessing and wiping information from cell phones.

8. In connection with his duties as CEO, on May 2, 2019, Saenz purchased a 15-inch 

Apple MacBook Pro for $2,631.00. The purchase order reflects that the laptop was ordered 3John 

Saenz, Zroblack, at 1150 N. Loop 1604-W, Ste 108-259, San Antonio, Te[as 78248, ́ Zhich Zas 

ZroBlack¶s address. It was purchased with a debit card ending with the number 8032, which was 

a debit card issued in ZroBlack¶s name. Exhibit 5 is composed of true and correct copies of the 

purchase order, receipt, and ZroBlack¶s bank statement shoZing the debit amount to its bank 

account. The laptop computer¶s part number Zas MR94LL/a and the serial number is 

C02YF1Y9JG5J. The laptop is located at Saen]¶s residence, 28710 Estin Height St., San Antonio, 

Texas 78260.

9. In addition to the code described above, ZroBlack¶s trade secrets also consist of the 

login and passZord information for ZroBlack¶s GoDadd\ account and for accessing the laptop.

10. On March 15, 2019, ZroBlack executed a non-disclosure agreement (3NDA ́) with 

the technology company located in Finland and with whom I had been negotiating. The purpose 

of the NDA was to allow ZroBlack to disclose trade secrets to the Finnish company during contract 

negotiations while maintaining the secrecy of those trade secrets. The trade secrets included the 

software code. Exhibit 6 is a true and correct copy of the NDA. A copy of that code is located on 

the ZroBlack laptop that Saenz purchased.

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11. On or about April 15 2019, ZroBlack entered into a Professional Services 

Agreement (3PSA ́) with the Finnish company (referred to in the Complaint and Application for 

Seizure and Injunctive Relief as ZroBlack¶s 3Foreign Customer ́), wherein ZroBlack would pass 

down its knowledge of mobile devices, consult with the customer on its software development and 

coding, hardware development, and organize and document the process of supporting the ability 

to identify, diagnose, clear, and validate certain devices. The contract price was One Million Five 

Hundred Thousand Dollars ($1,500,000.00) to be paid up front and a fourteen and one-half percent 

(14.5%) earn out on new customer revenue and existing customer growth. Exhibit 7 is a true and 

correct copy of the PSA. After procuring a contract from the Finnish company, ZroBlack grew to 

as many as ten employees.

12. Saenz had the $1.5 million transferred into a Wells Fargo business account that he

had established for ZroBlack. Saenz then transferred $740,000 of those funds to his personal 

account. Exhibit 8 is a true and correct copy of the Bank Statements for the account showing the 

deposit of $1,500,000 and Saenz¶s ZithdraZal of $740,000.

13. ZroBlack retained the services of Gunn, Lee & Cave (hereinafter, 3Gunn Lee laZ 

firm ́) and specificall\ attorne\ Mike Villareal (hereinafter, 3Mike ́) to advise on the contract 

negotiations with the Finnish company. Mike Villareal and I are not related. Shortly before signing

the PSA, on or about April 12, 2019, I emailed Mike and discussed negotiations with the Finnish 

company. In the mail, I stated:

John and I went through it [PSA] last tonight, he had concerns, but at 

the end of our talks we worked out the logic behind the revenue sharing. 

I hope this closes today too, hard lessons have been learned for sure. If 

Ze sign toda\, it¶s basicall\ as though Ze are getting a $750,000 salar\ 

each for 2019. Do you have a recommendation for an attorney that can 

setup a trust for me?

Exhibit 9 is a true and correct copy of the email. The email demonstrates that $1.5 million dollars 

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was to constitute salary for us through the end of 2019. The money was not a gift, nor was it 

deemed earned upon the signing of a contract with ZroBlack¶s Foreign Customer.

14. The PSA included confidentiality provisions. Section 7.1 provided that all 

deliverables and inventions and all other information (including computer programs, technical 

drawings, algorithms, know-how, formulas, processes, ideas, inventions (whether patentable or 

not), schematics, and other technical, business, financial, and customer and product development 

plans, forecasts, strategies and information) that ZroBlack, Saenz, or I developed, learned, or 

obtained in connection with the services they rendered under the PSA constituted the proprietary 

information of the Foreign Customer. ZroBlack, Saenz, and I were required to hold that

information in confidence and not use or disclose it. Section 7.2 of the PSA stated that upon 

termination of the PSA or as otherwise requested by the Finnish company, ZroBlack, Saenz, and 

I would promptly return all items and copies containing or embodying proprietary information 

including all deliverables and work-in-progress.

15. After ZroBlack signed NDA and PSA, Saenz tried to shop the technology to others, 

including an individual named Roger Graham, who was formerly with UBS Financial and, at the 

time, employed by Wells Fargo; he is currently a Senior Vice President-Investment Officer and 

PIM Portfolio Manager. I warned Saenz that he was in violation of the NDA and the confidentiality 

provisions of the PSA. Saenz threatened to continue to try to market the code.

16. After signing the PSA, Saenz took half of the upfront payment ($740,000) and then 

performed very little work for ZroBlack.

17. In May 2019, the ZroBlack¶s customer required both Saenz and I to travel to 

Finland. Saenz refused to leave at the same time as I did, but he eventually showed one week late. 

Two days after arriving in Finland, Saenz sent an email to the customer¶s VP of Technology stating 

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that I would take care of 100% of the technical and that he (Saenz) would no longer be attending 

morning meetings but would check up from time to time:

I wanted to send you a note to clarify my role on these calls. I will be 

on from time to time as an observer and to offer guidance from 

ZroBlack¶s point of vieZ. Jonathan can handle all the technical side of 

the conversations.

Exhibit 10 is a true and correct copy of the email Saenz sent.

18. I was required to return to Finland during the week of June 8 to 15, 2019; Saenz 

refused to accompany me. Saenz went to Finland only once. Saenz was also charged with 

completing tax returns and paying the quarterly business taxes, but he did not.

19. Saenz used most of the $740,000 he took from ZroBlack. Saenz invested around 

$305,000 into the stock market. Saenz also used around $423,850 in property renovations. As a 

result of Saen]¶s refusal to perform his work, I grew very frustrated. On June 26, 2019, I notified 

Saenz by text message that I wished to dissolve our partnership. Exhibit 11 is a true and correct 

copy of the text message I sent to Saenz. In the notification, I took him to task for not doing any 

work, stating:

You can¶t sit back and e[pect a pa\check. You can¶t sa\ \ou front loaded the contract then 

dip out. Besides, I did a huge part to close out the contract, I did the entire due diligence 

and put the entire BRIX document together. I expected you to do work after we got paid, 

this isn¶t a free ride man. [Foreign Customer] only wants to go forward with me for a reason 

and I don¶t know what happened to you. I don¶t knoZ Zh\ \ou stopped working after 

getting paid $750k.

Id.

20. When Mike and the Gunn Lee law firm represented ZroBlack, the representation 

began as a normal corporate representation, where the law firm and the Mike were advising Saenz 

and I on matters regarding the company. Though unsigned, Exhibit 12 is a true and correct copy 

of the Engagement Agreement. Soon after ZroBlack executed the PSA, however, Saenz and I came 

to cross purposes over Saen]¶s lack of performance and misappropriation of compan\ funds.

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21. After I threatened to dissolve the partnership, Saenz got Mike involved further. 

Mike and the Gunn Lee law firm undertook to represent both me and Saenz in negotiations to settle 

our dispute. One of my main concerns was the $740,000 John Saenz withdrew from the $1.5 

million paid to ZroBlack. Those monies were paid in advance, and ZroBlack¶s customer expected 

ZroBlack, Saenz, and I to perform under the contract, but Saenz refused to perform his obligations 

to ZroBlack and its customer. Furthermore, Saenz would not agree to take steps to ensure his 

performance, despite being told by Mike during a meeting in Mike¶s office in Jul\ 2019 that he 

(Saenz) had breached his fiduciary duty to the company.

22. To salvage the relationship, on or about July 27, 2019, Mike suggested that I set 

tasks for Saenz. Saenz refused to have the tasks incorporated into any agreement, sending a text 

message stating he would not 3agree to tie a contract to daily tasks because that could be easily 

manipulated. ́ Exhibit 13 is a true and correct copy of that text message. I responded, 3Seriousl\. 

Please dude. That¶s not fair. I literall\ have m\ Zork planned out for an entire \ear I¶m asking \ou 

for one month. Hello? HoZ can I help \ou Zith it? ́ Saen] also refused Mike¶s suggestion that his 

CEO duties be incorporated into the company operating agreement.

23. After Saenz took the $740,000, ZroBlack was forced to cut salaries of its 

employees. Saenz refused to assist ZroBlack in paying bills and I was not able to make the tax 

payment. I was forced to incur serious debt to get the capital to complete the deal with ZroBlack¶s 

customer in Finland. I began selling my personal property including electronics and my Zife¶s 

wedding ring to ensure that ZroBlack could maintain working capital.

24. Because Saenz is married to my cousin, our falling out began to cause strife in the 

family. The family relationship was very important to me. My dispute with Saenz was causing 

stress and hard feelings between my father and his brother, cousins, and others in the family. Mike 

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began emphasizing to me that I needed to settle Zith Saen] b\ 3thinking about the famil\. ́ Saen] 

began demanding that the $740,000 he took from ZroBlack be characteri]ed as a 3gift ́ for ta[ 

purposes. I refused to do this as I believed it would violate the law. On July 17, 2019, Saenz offered 

to assign all of his interest in ZroBlack to me if ZroBlack would characterize the $740,000 as a 

gift. Exhibit 27 is a true and correct copy of the text message.

25. After Saenz and I disagreed on how to qualify the $740,000 from ZroBlack, we

decided it was time to part ways. The money that Saenz had taken from the company was to be 

returned, on a basis to be structured by Mike and the Gunn Lee law firm. Mike did not adequately 

advise me or ZroBlack as to the consequences of what we were doing and structured an agreement 

that hurt both me and ZroBlack.

26. On or about July 17, 2019, I sent a text message to Saenz, saying:

Thanks for the call, it¶s disappointing that \ou had no idea Ze had a product released 

alread\. It¶s disappointing that you were not on the phone call this morning for our morning 

meeting. It¶s disappointing that \ou never responded to ma\ emails letting me knoZ Zhat 

you did for our client that paid our company $1.5 million, it¶s disappointing that \ou say 

\ou¶re going to taking [sic] legal action against [Foreign Customer], it¶s disappointing that 

you cannot provide me with what you have done for our client for the last 2 months.

Exhibit 14 is a true and correct copy of the text message.

27. Mike and the Gunn Lee law firm eventually prepared a document titled 3Release. ́ 

Exhibit 15 is a true and correct copy of the Release. The Release made no express provision for 

the return of the $740,000 to ZroBlack, despite my continued requests that the money be returned.

The Release also contained no express requirement that Saenz return property to ZroBlack, which 

included not onl\ the $740,000 and a laptop computer belonging to ZroBlack, but also ZroBlack¶s 

proprietary and trade secret information. I did not have an express provision requiring the return 

of ZroBlack¶s domain name, webpage, and email server. The Release also provided that Saenz 

would receive 2% and ZroBlack 12.5% of the 14.5% Earn-Out Obligation under the PSA.

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28. Saenz and I executed the Release on August 9, 2019 while negotiations regarding 

the $740,000 were on going. Section 7 of the Release states that 3Each Part\ hereto full\ releases 

the other Parties from all claims and demands, knoZn or unknoZn. ́ Section 7 goes on the discuss 

claims that are known and unknown. It does not address inchoate claims or claims that have not 

yet accrued.

29. Saenz and I also executed a Unanimous Written Consent in Lieu of Meeting by

ZroBlack¶s membership (hereinafter, 3Consent ́). Exhibit 16 is a true and correct copy of the 

Consent. The second 3WHEREAS ́ in the Consent states, 3the undersigned wish to memorialize 

John Saen]¶s assignment of his entire interest in ZroBlack LLC to Jonathan Villareal. ́ The first 

3RESOLVED ́ states that 3John Saen] hereby assigns his entire interest in ZroBlack LLC to 

Jonathan Villareal pursuant to Article VII of the μLimited Liabilit\ Company Operating 

Agreement for ZroBlack LLC¶ dated Januar\ 14, 2019 and applicable laZs, « ́ Saenz assigned

all of his ownership interest to me, and relinquished all claims of an\ oZnership of ZroBlack¶s 

property, including the laptop and proprietary code contained therein.

30. Just prior to execution of the Release and Consent, on or about August 1, 2019, 

Saenz, myself, ZroBlack, and its Finnish customer executed a First Amendment to Professional 

Services Agreement (hereinafter, 3First Amendment ́). Exhibit 17 is a true and correct copy of the 

First Amendment. The First Amendment releases Saenz from his obligations under the PSA, save 

and except the obligations of confidentiality in Section 7 of the PSA, which would survive.

31. Nonetheless, after the deal for Saenz¶s to exit ZroBlack was struck, Saenz 

continued to want the money he had taken from the company to be construed as a 3gift. ́ This was 

an ongoing dispute between Saenz and me. I anticipated providing service to the United States 

federal government and I told Saenz that I would never agree to qualify the $740,000 Saenz took

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as a gift. In fact, I gave Saenz an ultimatum: return the money, or face the harsh consequences. 

This was the same discussion I had with attorney Mike and the Gunn Lee law firm.

32. On August 15, 2019, I asked Saen] to release ZroBlack¶s Zebpage. Saen] said he 

Zould 3look into it. ́ Exhibit 18 is a true and correct copy of my text exchange to him requesting 

transfer of website. Exhibit 19 is a true and correct copy of an email I sent Saenz requesting transfer 

of website. Despite my requests for return, Saenz continues to hold the domain name. Later, Saenz 

demanded I pay him $7,000 for the domain name, webpage, and email server.

33. Since then, Saen] has taken the Zebsite doZn effectivel\ terminating ZroBlack¶s 

ability to gain new clients. Saenz also deleted the email server, thereby destroying emails and 

documents related to the Finnish technology company project and other projects. Saenz currently 

holds access to ZroBlack¶s GoDaddy domain name, so I have no access to the site and no 

opportunity to attempt to recover the webpage and emails.

34. I also asked Saenz to return the laptop computer belonging to ZroBlack. This is the 

laptop computer that Zas purchased Zith ZroBlack¶s debit card, on or about May 2, 2019, and 

described above. Saenz refused this request also and he still maintains control over it even though 

I have requested its return multiple times. This computer contains proprietary code related to 

ZroBlack¶s phone security project.

35. On September 12, 2019, I emailed Mike advising him that Saenz had deleted all the

emails from ZroBlack¶s email server. Exhibit 20 is a true and correct copy of the email I sent. 

Then, on September 13, 2019, I emailed Mike begging for help:

I¶m beside m\self right noZ, and reall\ struggling Zith ever\thing, I can¶t eat, I can¶t sleep, 

my anxiety and stress is so high, and for the ne[t 3 \ears if I continue like this I¶ll end up 

losing my contracts and not be able to work.

I have worked too hard to allow myself to slip like this. I need help Mike, this is not right. 

I¶ve done nothing Zrong. John got $750,000 cash, and there has to be a way for me to stop 

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this madness, get him to give up the 2%, get my company website, my company 

documents, and my company computer. Like I said, I have a company that pays real taxes, 

has 10 real employees, we have a real ph\sical location, and I can¶t even put up m\ 

company website.

Exhibit 21 is a true and correct copy of the email sent. Mike continued to try to negotiate a 

resolution between Saenz, myself, and ZroBlack.

36. On or about September 19, 2019, I again emailed Saenz, copying Mike, demanding 

the return of ZroBlack¶s propert\, including the laptop containing proprietary code, ZroBlack¶s 

Zeb domain and Zebpage, and ZroBlack¶s emails. I also demanded return of the $740,000 Saenz 

misappropriated from ZroBlack. Exhibit 22 is a true and correct copy of that email. I sent a similar 

email to Saenz and Mike on September 20, 2019, explaining why I believed Saenz should return 

the $740,000 and other property of ZroBlack. Exhibit 23 is a true and correct copy of that email.

37. On or about September 26, 2019, Mike tried to arrange a meeting between Saenz 

and myself to discuss settling our dispute and offered his offices as a place to have the discussions. 

Mike gave his available days and stated that 3Ze are tr\ing to resolve \our difference, not 

attempting to take advantage of each other. I appreciate you both willing to show good faith on 

both your parts in coming together and seeing if a resolution can be reached. ́ Exhibit 24 is a true 

and correct copy of the email I received from Mike trying to arrange the meeting.

38. Despite promises to appear for a meeting, Saenz kept putting it off until I decided 

it was time to take our dispute in a different direction. I emailed Mike and stated as much. Exhibit 

25 is a true and correct copy of the email chain between Mike and me.

39. Saenz has not returned the money he took from ZroBlack. He has not returned the 

web domain and webpage, emails, laptop, and other proprietary information belonging to 

ZroBlack. Saen] continues to hold on to ZroBlack¶s propert\ and refuses to return it. The ZroBlack 

laptop that Saenz took contains proprietary information and trade secrets belonging to ZroBlack.

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Saenz also threatened me that he Zould 3muck up ́ my life if I did not turn over the company and 

assign it to him.

40. I trusted Mike and the Gun Lee law firm. I am not an attorney and am not familiar 

with legal issues. I trusted and relied on Mike and his firm to guide me and navigate the dispute

with Saenz. I placed my trust in Mike and the Gun Lee law firm, just as ZroBlack trusted them as 

ZroBlack¶s corporate counsel.

41. Mike failed to disclose the extent of his relationship with Saenz. Mike continued to 

pressure me to resolve the dispute for 3the sake of the famil\. ́

42. On or about February 22, 2020, I attempted to contact Saenz to collect back the 

money that he had took at the close of the deal Zith ZroBlack¶s Foreign Customer. After we signed 

the Release, Saenz failed to turn in all company assets to including, money, computers, email 

servers, website, non-disclosure agreements, company contacts, original documents, and 

everything else that belonged to ZroBlack.

43. ZroBlack is the owner of trade secrets. The trade secrets relate to products and

services used in interstate and foreign commerce, mainly in the contract with ZroBlack¶s Foreign 

Customer in Finland. ZroBlack¶s trade secrets are composed of its proprietary software code built 

and maintained by me and which can be used to access cell phones wirelessly. The login and 

passZord to access ZroBlack¶s GoDadd\ account are also trade secrets of ZroBlack.

44. The software code has economic value by not being generally known to others. 

Because the code is not known to others, ZroBlack can use the code to provide cell phone data 

erasure services to clients. ZroBlack is one of the few companies in the world that can perform the 

erasure services wirelessly. The economic value of ZroBlack¶s trade secrets is evidenced b\ its 

contract with if Foreign Customer in Finland, which paid $1,500,000 upfront for access to the 

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technology, as well as a 14.5% payout on new and existing customers during the lift of the contract.

45. ZroBlack took steps to maintain the secrecy of the software code. The software

code was known only to those in managerial positions; as the chief executive officer and a trusted 

employee, Saenz had access to the code. This information was not shared with others outside of 

management and was secured and password protected.

46. The login and passZord to ZroBlack¶s GoDadd\ account also derives independent 

economic value because it is not generally known to ZroBlack¶s competitors. The login and 

password allow ZroBlack to access its webpage and (at one time) its emails that contained 

confidential documents and other information related to ZroBlack¶s customers. The login and 

password were also know only to Saenz to maintain their confidentiality.

47. After Saenz assigned all his interest in ZroBlack to me, he was no longer authorized

to use the laptop or access the information on it. He also no longer had authorization to access 

ZroBlack¶s domain name or its email server and emails; nor did he have authorization to delete 

the webpage and email server.

48. I made several attempts to regain possession of the laptop and the code it contained, 

as Zell as access to ZroBlack¶s domain name, Zebpage, and email server. ZroBlack and I have 

spent over $5,000 in attorne\¶s fees paid to Gunn, Lee, & Cave tr\ing to get the laptop and domain 

name back. Those fees include negotiations for the Release, wherein Saenz assigned all of his 

interest in ZroBlack to me, and fees trying to resolve the issue post-execution of the Release. 

Exhibit 25 is true and correct copies of the Gunn, Lee law firm¶s invoices to me shoZing the mone\ 

spent trying to recover the laptop and domain name. ZroBlack has also lost data because of Saen]¶s 

deletion of the email server. The value of the information exceeds $5,000. ZroBlack has also spent 

more than $5,000 trying to recover from the data loss, establishing new lines of communications 

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