EXHIBIT A 

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 1 of 51
IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

EL PASO DIVISION 

FREE AND SOVEREIGN STATE OF 

CHIHUAHUA, 

 

Plaintiff, 

v. 

CESAR HORACIO DUARTE JAQUEZ, 

BERTHA OLGA GOMEZ FONG, 

OLGA SOFIA DUARTE GOMEZ, 

OLGA DUARTE JAQUEZ, 

CESAR ADRIAN DUARTE, 

CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, 

MANUEL ALBERTO GARZA, 

44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC, 

Defendants. 

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Civil Action No. 3:20-cv-00086 

LIST OF COUNSEL OF RECORD 

Anthony G. Buzbee 

Christopher J. Leavitt 

Caroline E. Adams 

THE BUZBEE LAW FIRM 

600 Travis Street, Suite 6850 

Houston, TX 77002 

Telephone: (713) 223-5393 

Facsimile: (713) 223-5909 

tbuzbee@txattorneys.com 

cleavitt@txattorneys.com 

cadams@txattorneys.com 

Attorneys for Plaintiff 

R. Paul Yetter 

Bryce L. Callahan 

Matthew Zorn 

YETTER COLEMAN LLP 

811 Main Street, Suite 4100 

Houston, Texas 77002 

Telephone: (713) 632-8000 

Facsimile: (713) 632-8002 

pyetter@yettercoleman.com 

bcallahan@yettercoleman.com 

mzorn@yettercoleman.com 

Attorneys for Defendants 

App. 001

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 2 of 51
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R  A

C N. 2020DCV0628

Free and Sovereign State of Chihuahua VS Cesar Horacio Duarte Jaquez,

Bertha Olga Gomez Fong, Olga Sofia Duarte Gomez, Olga Duarte Jaquez,

Cesar Adrian Duarte, CAD Construction, Inc., Gabriela Armendariz

Chaparro, Manuel Alberto Garza, 44 Fountain Rd., LLC, and 110 S.

Festival, LLC

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Case Type: Other Civil

Date Filed: 02/19/2020

Location: 448th District Court

P I

Lead Attorneys

Defendant 110 S. Festival, LLC

Defendant 44 Fountain Rd., LLC

Defendant CAD Construction, Inc.

Defendant Chaparro, Gabriela Armendariz

Defendant Duarte Gomez, Cesar Adrian

Defendant Duarte Gomez, Olga Sofia

Defendant Duarte Jaquez, Cesar Horacio

Defendant Duarte Jaquez, Olga

Defendant Garza, Manuel Alberto

Defendant Gomez Fong, Bertha Olga

Plaintiff Free and Sovereign State of Chihuahua ANTHONY G BUZBEE

 Retained

713-223-5393(W)

E  O   C

OTHER EVENTS AND HEARINGS

02/19/2020 Original Petition (OCA) Doc ID# 1

02/19/2020 E-File Event Original Filing

02/20/2020 Request Doc ID# 2

02/25/2020 Citation

Duarte Jaquez, Cesar Horacio Unserved

Gomez Fong, Bertha Olga Served 03/20/2020

Response Due 04/13/2020

Returned 03/24/2020

Duarte Gomez, Olga Sofia Served 03/12/2020

Response Due 04/06/2020

Returned 03/17/2020

Duarte Jaquez, Olga Served 03/12/2020

Response Due 04/06/2020

Returned 03/19/2020

Duarte Gomez, Cesar Adrian Unserved

CAD Construction, Inc. Unserved

Chaparro, Gabriela Armendariz Served 03/05/2020

Response Due 03/30/2020

Returned 03/19/2020

Garza, Manuel Alberto Unserved

44 Fountain Rd., LLC Unserved

110 S. Festival, LLC Unserved

App. 002

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 3 of 51
CAUSE NO. ____________

FREE AND SOVEREIGN STATE OF § IN THE DISTRICT COURT OF

CHIHUAHUA §

Plaintiff, §

§ _______ JUDICIAL DISTRICT

vs. §

§ 

CESAR HORACIO DUARTE JAQUEZ, §

BERTHA OLGA GOMEZ FONG, §

OLGA SOFIA DUARTE GOMEZ, § EL PASO COUNTY, TEXAS

OLGA DUARTE JAQUEZ, §

CESAR ADRIAN DUARTE, §

CAD CONSTRUCTION, INC., §

GABRIELA ARMENDARIZ CHAPARRO, §

MANUEL ALBERTO GARZA, §

44 FOUNTAIN RD., LLC, AND §

110 S. FESTIVAL, LLC. §

Defendants. § JURY TRIAL DEMANDED

PLAINTIFF FREE AND SOVEREIGN STATE OF CHIHUAHUA’S

ORIGINAL PETITION, JURY DEMAND, AND REQUEST FOR DISCLOSURE

TO THIS HONORABLE COURT:

Plaintiff, Free and Sovereign State of Chihuahua (“Chihuahua”), files this Original Petition

against Defendants Cesar Horacio Duarte Jaquez, Bertha Olga Gomez Fong, Olga Sofia Duarte

Gomez, Olga Duarte Jaquez, Cesar Adrian Duarte, CAD Construction, Inc., Gabriela Armendariz

Chaparro, Manuel Alberto Garza, 44 Fountain Rd., LLC, and 110 S. Festival, LLC., and

respectfully shows this Honorable Court the following:

Summary of this Case

Cesar Horacio Duarte Jaquez was the governor of the Mexican state of Chihuahua from

2010 until 2016. His time as governor was marked by multiple controversies and reports of

rampant corruption. The extensive corruption in Duarte’s administration reached across the

borders of Mexico into the United State of America. Duarte orchestrated a scheme in which

hundreds of millions of dollars earmarked for social programs were diverted to an elaborate

Filed 2/19/2020 10:05 AM

2020DCV0628

Norma Favela Barceleau

El Paso County - 448th District Court

District Clerk

El Paso County

App. 003

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 4 of 51
2

network of phantom companies – among other misdeeds. One nefarious act of corruption and greed

by Duarte was when his administration purchased cancer medications at a 300% price inflation

rate with ties to his own businesses and administered them to the State’s child cancer patients. The

medication was purchased using the state’s monies to which Duarte and his administration stole

the excess and used it to purchase properties in the United States. Indeed, he is alleged to have

absconded with hundreds of millions of his state’s monies. This stolen money was used to make

investments and purchase luxury homes and cars all over the United States including Texas. As

the allegations against him grew, Mr. Duarte eventually fled Chihuahua, and then Mexico. Mr.

Duarte was later indicted in Mexico with more than 21 warrants for his arrest based on corruption

and fraud. Cesar Duarte is believed to be hiding in El Paso, Texas and Albuquerque, New Mexico.

The money stolen by Duarte rightfully belong to the people of the State of Chihuahua. The

State thus files this and other actions in an effort to recoup those funds stolen by Duarte and those

acting in concert with him. Chihuahua also seeks to recover assets purchased with such stolen

funds.

Each of the Defendants named above conspired with Cesar Horacio Duarte Jacquez to steal

government funds from the State of Chihuahua. Further, each of the named Defendants purchased

properties in Texas with the stolen money. The properties listed in rem are just a few of the many

purchased with stolen funds all across the United States and the world.

I.

Discovery Control Plan

1. Plaintiff intends to conduct discovery under Level 2.

II.

Parties

2. Plaintiff State of Chihuahua is a foreign state entity of Mexico.

App. 004

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 5 of 51
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3. Defendant Cesar Horacio Duarte Jaquez is a foreign individual who may be served with

process at his last known address at 343 Crimson Cloud, El Paso, Texas, or wherever he may be

found.

4. Defendant Bertha Olga Gomez Fong, is Cesar Horacio Duarte’s wife. She may be served

via personal service at her last known address at 343 Crimson Cloud, El Paso, Texas, or wherever

she may be found.

5. Defendant Olga Sofia Duarte Gomez is an individual residing in Texas. She may be served

with process at her last known address at 343 Crimson Cloud, El Paso, Texas 79912, or wherever

she may be found.

6. Defendant Cesar Adrian Duarte Gomez is an individual residing in Texas. He may be

served with process at his last known address at 378 Morning Star, El Paso, Texas 79912, or

wherever he may be found.

7. Defendant Olga Duarte Jaquez is an individual residing in Texas. She may be served with

process at her last known address at 100 Stern Drive, El Paso, Texas, 79932, or wherever she may

be found.

8. Defendant CAD Construction, Inc., is a domestic for-profit corporation. It can be served

via personal service via its registered agent, Cesar Adrian Duarte, at 343 Crimson Cloud, El Paso,

Texas 79912.

9. Defendant Gabriela Armendariz Chaparro is an individual residing in Texas. She can be

served with process at her last known address at 6928 Diamond Ridge Dr, El Paso, Texas, 79912,

or wherever she may be found.

App. 005

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 6 of 51
4

10. Defendant Manuel Alberto Garza is an individual residing in Texas. He can be served with

process at this last known address at 236 Hidden Crest Circle, El Paso, Texas, 79912, or wherever

he may be found.

11. Defendant 44 Fountain Rd., LLC, is a domestic limited liability company. It can be served

via personal service via its registered agent, Daniel S. Gonzalez, at 909 E. Rio Grande Ave., El

Paso, Texas, 79902.

12. Defendant 110 S. Festival, LLC, is a domestic limited liability company. It can be served

via personal service via its registered agent, Daniel S. Gonzalez, at 909 E. Rio Grande Ave., El

Paso, Texas, 79902.

In Rem Parties

13. Plaintiff makes claims against the following properties in rem.

14. 343 Crimson Cloud is a property located in El Paso, Texas; its record owner is Defendant

Bertha Olga Gomez Fong. The funds used to purchase this property were stolen from Chihuahua. 

15. 263 Everest Dr., is a property located in El Paso, Texas; its record owner is Defendant

CAD Construction, Inc. The funds used to purchase this property were stolen from Chihuahua.

16. 100 Stern Dr is a property located in El Paso, Texas; its record owner is Defendant Olga

Duarte Jaquez. The funds used to purchase this property were stolen from Chihuahua.

17. 6928 Diamond Ridge Dr. is a property located in El Paso, Texas; its record owner is

Defendant Gabriela Armendariz Chaparro. The funds used to purchase this property were stolen

from Chihuahua.

18. 236 Hidden Crest Cir. is a property located in El Paso, Texas; its record owner is Defendant

Manuel Alberto Garza. The funds used to purchase this property were stolen from Chihuahua.

App. 006

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 7 of 51
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19. 44 Fountain Rd is a property located in El, Paso, Texas; its record owner is Defendant 44

Fountain Rd., LLC. The funds used to purchase this property were stolen from Chihuahua.

20. 110 Festival Dr is a property located in El Paso, Texas; its record owner is Defendant 110

S. Festival, LLC. The funds used to purchase this property were stolen from Chihuahua.

III.

Venue and Jurisdiction

Plaintiff seeks damages in excess of $75,000.00, exclusive of interest and costs; however,

federal courts lack subject matter over this action, as there is no federal question and there is

incomplete diversity of citizenship due to the presence of a defendant who is a resident and citizen

of Texas. Removal would thus be improper. No party is asserting any claims arising under the

Constitution, treaties, or laws of the United States. Venue is proper in this County as at least one

defendant maintains a principal office here and most of the properties involved are here.

IV. 

Causes of Action

A. Conversion – All Defendants

Plaintiff incorporates the preceding paragraphs of this Petition as if set forth fully below.

Plaintiff owned, possessed, and had the right to the funds that were stolen by Cesar Duarte

and his network to invest into the above referenced assets. These funds were the property of State

of Chihuahua. Defendants are currently wrongfully exercising control over this property. 

Plaintiff has suffered injury because of these actions.

B. Theft Liability Act – All Defendants

Plaintiff incorporates the preceding paragraphs of this Petition as if set forth fully below.

App. 007

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 8 of 51
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Defendant Duarte unlawfully appropriated property with the intent to deprive the owner of

this property. In this case, the property belonged to the State of Chihuahua. Currently, this

property is owned or controlled by Defendants. 

C. Constructive Trust – All Defendants 

Plaintiff incorporates the preceding paragraphs of this Petition as if set forth fully below. 

Plaintiff seeks a constructive trust over Mr. Duarte and his associates’ interest in the subject

properties. Mr. Duarte and his associates conspired together and looted government coffers and

engaged in other graft that stole money from the State of Chihuahua. Mr. Duarte and his associates

took those funds and invested into the above referenced assets, among other things. Mr. Duarte

had a fiduciary relationship with the State of Chihuahua. More importantly, Mr. Duarte and his

associates committed both actual and constructive fraud in obtaining these funds. These funds

were then used to invest in properties in Texas. 

D. Civil Conspiracy – All Defendants

Plaintiffs would show that Duarte, together with the named Defendants, conspired with

Duarte and his associates to steal and embezzle, and to commit fraud on Plaintiff. The purpose of

the conspiracy was move as much money as possible from the State of Chihuahua to the United

States for the benefit of Mr. Duarte and his family. Duarte and the named Defendants had a

meeting of the minds on this objective and, as shown in detail above, together, made one or more

unlawful and overt acts towards this objective. As a result, Plaintiff suffered damages. Plaintiff

also seeks punitive damages.

E. Joint and Several Liability – All Defendants

Duarte and the other Defendants are joint and severally liable for all acts of Duarte and his

associates, the conspirators as referenced above. Duarte and the other Defendants planned and

App. 008

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 9 of 51
7

assisted in this conspiracy, and, as such, they are jointly and severally liable for all acts done by

any member of the conspiracy in furtherance of such.

F. Texas Penal Code 31.03(e)(7) – All Defendants

The previous paragraphs are incorporated herein. Defendants unlawfully appropriated

property with intent to deprive the owner, the State of Chihuahua, of its property. Defendants did not

have the effective consent of the State of Chihuahua. Additionally, the property at issue is stolen and

the various actors appropriated the property knowing it was stolen by another. 

V.

Damages

As a direct and proximate result of the foregoing events, Chihuahua suffered damages in

the form of stolen funds, all for which Plaintiff seeks recovery herein. 

VI.

Exemplary Damages

Plaintiff seeks to recover exemplary damages against all Defendants based on their

criminal conduct and resulting injuries and damages made the basis of this suit. Any caps or limits

on punitive damages should not be applied because Defendants’ conduct and violations of the Penal

Code, including 31.03, disqualifies them from the benefit of any caps. 

VII. 

Demand for Jury

Plaintiff demands a jury trial and has tendered the appropriate fee.

VIII.

Request for Disclosure

Pursuant to Tex. R. Civ. P. 194, Plaintiff requests that each Defendant disclose within

fifty (50) days of service of this Request for Disclosure, the information and/or material described

in Rule 194.2.

App. 009

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 10 of 51
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IX.

Prayer

For these reasons, Plaintiff asks that Defendants be cited to appear and answer, and that

they have judgment against Defendants for the following:

a. Actual damages within the jurisdictional limits of this Court, but no less than

$25,000,000; 

b. Exemplary damages;

c. Court costs;

d. Pre and post judgment interest; and

e. All other relief to which the Plaintiff is justly entitled. 

 Respectfully submitted,

THE BUZBEE LAW FIRM

By: /s/ Anthony G. Buzbee

Anthony G. Buzbee

State Bar No. 24001820

tbuzbee@txattorneys.com

Christopher J. Leavitt

State Bar No. 24053318

cleavitt@txattorneys.com

Caroline E. Adams

State Bar. No. 24011198

cadams@txattorneys.com

JP Morgan Chase Tower

600 Travis, Suite 6850

Houston, Texas 77002

Telephone: (713) 223-5393

Facsimile: (713) 223-5909

ATTORNEYS FOR PLAINTIFF

App. 010

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 11 of 51
Page 1 of 2

CIVCI08 Revised 9/3/99

CIVIL PROCESS REQUEST

FOR EACH PARTY SERVED YOU MUST FURNISH ONE (1) COPY OF THE PLEADING

FOR WRITS FURNISH TWO (2) COPIES OF THE PLEADING PER PARTY TO BE SERVED

CASE NUMBER: __________________________ CURRENT COURT: _____________________________________

TYPE OF INSTRUMENT TO BE SERVED (See Reverse For Types): _________________________________________________

FILE DATE OF MOTION: ________________________________________________________________________________

Month/ Day/ Year

SERVICE TO BE ISSUED ON (Please List Exactly As The Name Appears In The Pleading To Be Served):

1. NAME: ___________________________________________________________________________________________

ADDRESS: ________________________________________________________________________________________

AGENT, (if applicable): ________________________________________________________________________________

TYPE OF SERVICE/PROCESS TO BE ISSUED (see reverse for specific type): ____________________________________________

SERVICE BY (check one):

ATTORNEY PICK-UP CONSTABLE

CIVIL PROCESS SERVER - Authorized Person to Pick-up: ________________________ Phone: _____________

MAIL CERTIFIED MAIL

PUBLICATION:

Type of Publication: COURTHOUSE DOOR, or

NEWSPAPER OF YOUR CHOICE: _______________________________________

OTHER, explain ______________________________________________________________________________

******************************************************************************************************

 

2. NAME: ___________________________________________________________________________________________

ADDRESS: ________________________________________________________________________________________

AGENT, (if applicable): ________________________________________________________________________________

TYPE OF SERVICE/PROCESS TO BE ISSUED (see reverse for specific type): ____________________________________________

SERVICE BY (check one):

ATTORNEY PICK-UP CONSTABLE

CIVIL PROCESS SERVER - Authorized Person to Pick-up: _______________________ Phone: _____________

MAIL CERTIFIED MAIL

PUBLICATION:

Type of Publication: COURTHOUSE DOOR, or

NEWSPAPER OF YOUR CHOICE: _______________________________________

OTHER, explain ______________________________________________________________________________

ATTORNEY (OR ATTORNEY'S AGENT) REQUESTING SERVICE:

NAME: _____________________________________________ TEXAS BAR NO./ID NO. ____________________________

MAILING ADDRESS: ____________________________________________________________________________________

PHONE NUMBER: __________ _______________________ FAX NUMBER: ________ ______________________

area code phone number area code fax number

EMAIL ADDRESS: ______________________________________________________________________________________

2020DCV0628 448th JDC El Paso County, Texas

Plaintiff's Original Petition

February 19, 2020

Cesar Horacio Duarte Jaquez

343 Crimson Cloud, El Paso, Texas

Citation

✔ Court Records Research

Bertha Olga Gomez Fong

343 Crimson Cloud, El Paso, Texas

✔ Court Records Research

Christopher J. Leavitt 24053318

600 Travis Street, Suite 7300, Houston, TX 77002

713 223-5393 713 223-5909

cleavitt@txattorneys.com

Filed 2/20/2020 12:18 PM

2020DCV0628

Norma Favela Barceleau

El Paso County - 448th District Court

District Clerk

El Paso County

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App. 011

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 12 of 51
Page 1 of 2

CIVCI08 Revised 9/3/99

CIVIL PROCESS REQUEST

FOR EACH PARTY SERVED YOU MUST FURNISH ONE (1) COPY OF THE PLEADING

FOR WRITS FURNISH TWO (2) COPIES OF THE PLEADING PER PARTY TO BE SERVED

CASE NUMBER: __________________________ CURRENT COURT: _____________________________________

TYPE OF INSTRUMENT TO BE SERVED (See Reverse For Types): _________________________________________________

FILE DATE OF MOTION: ________________________________________________________________________________

Month/ Day/ Year

SERVICE TO BE ISSUED ON (Please List Exactly As The Name Appears In The Pleading To Be Served):

1. NAME: ___________________________________________________________________________________________

ADDRESS: ________________________________________________________________________________________

AGENT, (if applicable): ________________________________________________________________________________

TYPE OF SERVICE/PROCESS TO BE ISSUED (see reverse for specific type): ____________________________________________

SERVICE BY (check one):

ATTORNEY PICK-UP CONSTABLE

CIVIL PROCESS SERVER - Authorized Person to Pick-up: ________________________ Phone: _____________

MAIL CERTIFIED MAIL

PUBLICATION:

Type of Publication: COURTHOUSE DOOR, or

NEWSPAPER OF YOUR CHOICE: _______________________________________

OTHER, explain ______________________________________________________________________________

** ****************************************************************************************************

 

2. NAME: ___________________________________________________________________________________________

ADDRESS: ________________________________________________________________________________________

AGENT, (if applicable): ________________________________________________________________________________

TYPE OF SERVICE/PROCESS TO BE ISSUED (see reverse for specific type): ____________________________________________

SERVICE BY (check one):

ATTORNEY PICK-UP CONSTABLE

CIVIL PROCESS SERVER - Authorized Person to Pick-up: _______________________ Phone: _____________

MAIL CERTIFIED MAIL

PUBLICATION:

Type of Publication: COURTHOUSE DOOR, or

NEWSPAPER OF YOUR CHOICE: _______________________________________

OTHER, explain ______________________________________________________________________________

ATTORNEY (OR ATTORNEY'S AGENT) REQUESTING SERVICE:

NAME: _____________________________________________ TEXAS BAR NO./ID NO. ____________________________

MAILING ADDRESS: ____________________________________________________________________________________

PHONE NUMBER: __________ _______________________ FAX NUMBER: ________ ______________________

area code phone number area code fax number

EMAIL ADDRESS: ______________________________________________________________________________________

2020DCV0628 448th JDC El Paso County, Texas

Plaintiff's Original Petition

February 19, 2020

Olga Sofia Duarte Gomez

343 Crimson Cloud, El Paso, Texas 79912

Citation

✔ Court Records Research

Cesar Adrian Duarte Gomez

378 Morning Star, El Paso, Texas 79912

✔ Court Records Research

Christopher J. Leavitt 24053318

600 Travis Street, Suite 7300, Houston, TX 77002

713 223-5393 713 223-5909

cleavitt@txattorneys.com

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App. 012

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 13 of 51
Page 1 of 2

CIVCI08 Revised 9/3/99

CIVIL PROCESS REQUEST

FOR EACH PARTY SERVED YOU MUST FURNISH ONE (1) COPY OF THE PLEADING

FOR WRITS FURNISH TWO (2) COPIES OF THE PLEADING PER PARTY TO BE SERVED

CASE NUMBER: __________________________ CURRENT COURT: _____________________________________

TYPE OF INSTRUMENT TO BE SERVED (See Reverse For Types): _________________________________________________

FILE DATE OF MOTION: ________________________________________________________________________________

Month/ Day/ Year

SERVICE TO BE ISSUED ON (Please List Exactly As The Name Appears In The Pleading To Be Served):

1. NAME: ___________________________________________________________________________________________

ADDRESS: ________________________________________________________________________________________

AGENT, (if applicable): ________________________________________________________________________________

TYPE OF SERVICE/PROCESS TO BE ISSUED (see reverse for specific type): ____________________________________________

SERVICE BY (check one):

ATTORNEY PICK-UP CONSTABLE

CIVIL PROCESS SERVER - Authorized Person to Pick-up: ________________________ Phone: _____________

MAIL CERTIFIED MAIL

PUBLICATION:

Type of Publication: COURTHOUSE DOOR, or

NEWSPAPER OF YOUR CHOICE: _______________________________________

OTHER, explain ______________________________________________________________________________

** ****************************************************************************************************

 

2. NAME: ___________________________________________________________________________________________

ADDRESS: ________________________________________________________________________________________

AGENT, (if applicable): ________________________________________________________________________________

TYPE OF SERVICE/PROCESS TO BE ISSUED (see reverse for specific type): ____________________________________________

SERVICE BY (check one):

ATTORNEY PICK-UP CONSTABLE

CIVIL PROCESS SERVER - Authorized Person to Pick-up: _______________________ Phone: _____________

MAIL CERTIFIED MAIL

PUBLICATION:

Type of Publication: COURTHOUSE DOOR, or

NEWSPAPER OF YOUR CHOICE: _______________________________________

OTHER, explain ______________________________________________________________________________

ATTORNEY (OR ATTORNEY'S AGENT) REQUESTING SERVICE:

NAME: _____________________________________________ TEXAS BAR NO./ID NO. ____________________________

MAILING ADDRESS: ____________________________________________________________________________________

PHONE NUMBER: __________ _______________________ FAX NUMBER: ________ ______________________

area code phone number area code fax number

EMAIL ADDRESS: ______________________________________________________________________________________

2020DCV0628 448th JDC El Paso County, Texas

Plaintiff's Original Petition

February 19, 2020

Olga Duarte Jaquez

100 Stern Drive, El Paso, Texas, 79932

Citation

✔ Court Records Research

CAD Construction, Inc.

343 Crimson Cloud, El Paso, Texas 79912.

Cesar Adrian Duarte

Citation

✔ Court Records Research

Christopher J. Leavitt 24053318

600 Travis Street, Suite 7300, Houston, TX 77002

713 223-5393 713 223-5909

cleavitt@txattorneys.com

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App. 013

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 14 of 51
Page 1 of 2

CIVCI08 Revised 9/3/99

CIVIL PROCESS REQUEST

FOR EACH PARTY SERVED YOU MUST FURNISH ONE (1) COPY OF THE PLEADING

FOR WRITS FURNISH TWO (2) COPIES OF THE PLEADING PER PARTY TO BE SERVED

CASE NUMBER: __________________________ CURRENT COURT: _____________________________________

TYPE OF INSTRUMENT TO BE SERVED (See Reverse For Types): _________________________________________________

FILE DATE OF MOTION: ________________________________________________________________________________

Month/ Day/ Year

SERVICE TO BE ISSUED ON (Please List Exactly As The Name Appears In The Pleading To Be Served):

1. NAME: ___________________________________________________________________________________________

ADDRESS: ________________________________________________________________________________________

AGENT, (if applicable): ________________________________________________________________________________

TYPE OF SERVICE/PROCESS TO BE ISSUED (see reverse for specific type): ____________________________________________

SERVICE BY (check one):

ATTORNEY PICK-UP CONSTABLE

CIVIL PROCESS SERVER - Authorized Person to Pick-up: ________________________ Phone: _____________

MAIL CERTIFIED MAIL

PUBLICATION:

Type of Publication: COURTHOUSE DOOR, or

NEWSPAPER OF YOUR CHOICE: _______________________________________

OTHER, explain ______________________________________________________________________________

** ****************************************************************************************************

 

2. NAME: ___________________________________________________________________________________________

ADDRESS: ________________________________________________________________________________________

AGENT, (if applicable): ________________________________________________________________________________

TYPE OF SERVICE/PROCESS TO BE ISSUED (see reverse for specific type): ____________________________________________

SERVICE BY (check one):

ATTORNEY PICK-UP CONSTABLE

CIVIL PROCESS SERVER - Authorized Person to Pick-up: _______________________ Phone: _____________

MAIL CERTIFIED MAIL

PUBLICATION:

Type of Publication: COURTHOUSE DOOR, or

NEWSPAPER OF YOUR CHOICE: _______________________________________

OTHER, explain ______________________________________________________________________________

ATTORNEY (OR ATTORNEY'S AGENT) REQUESTING SERVICE:

NAME: _____________________________________________ TEXAS BAR NO./ID NO. ____________________________

MAILING ADDRESS: ____________________________________________________________________________________

PHONE NUMBER: __________ _______________________ FAX NUMBER: ________ ______________________

area code phone number area code fax number

EMAIL ADDRESS: ______________________________________________________________________________________

2020DCV0628 448th JDC El Paso County, Texas

Plaintiff's Original Petition

February 19, 2020

Gabriela Armendariz Chaparro

6928 Diamond Ridge Dr, El Paso, Texas 77912

Citation

✔ Court Records Research

Manuel Alberto Garza

236 Hidden Crest Circle, El Paso, Texas, 79912

Citation

✔ Court Records Research

Christopher J. Leavitt 24053318

600 Travis Street, Suite 7300, Houston, TX 77002

713 223-5393 713 223-5909

cleavitt@txattorneys.com

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App. 014

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 15 of 51
Page 1 of 2

CIVCI08 Revised 9/3/99

CIVIL PROCESS REQUEST

FOR EACH PARTY SERVED YOU MUST FURNISH ONE (1) COPY OF THE PLEADING

FOR WRITS FURNISH TWO (2) COPIES OF THE PLEADING PER PARTY TO BE SERVED

CASE NUMBER: __________________________ CURRENT COURT: _____________________________________

TYPE OF INSTRUMENT TO BE SERVED (See Reverse For Types): _________________________________________________

FILE DATE OF MOTION: ________________________________________________________________________________

Month/ Day/ Year

SERVICE TO BE ISSUED ON (Please List Exactly As The Name Appears In The Pleading To Be Served):

1. NAME: ___________________________________________________________________________________________

ADDRESS: ________________________________________________________________________________________

AGENT, (if applicable): ________________________________________________________________________________

TYPE OF SERVICE/PROCESS TO BE ISSUED (see reverse for specific type): ____________________________________________

SERVICE BY (check one):

ATTORNEY PICK-UP CONSTABLE

CIVIL PROCESS SERVER - Authorized Person to Pick-up: ________________________ Phone: _____________

MAIL CERTIFIED MAIL

PUBLICATION:

Type of Publication: COURTHOUSE DOOR, or

NEWSPAPER OF YOUR CHOICE: _______________________________________

OTHER, explain ______________________________________________________________________________

** ****************************************************************************************************

****

2. NAME: ___________________________________________________________________________________________

ADDRESS: ________________________________________________________________________________________

AGENT, (if applicable): ________________________________________________________________________________

TYPE OF SERVICE/PROCESS TO BE ISSUED (see reverse for specific type): ____________________________________________

SERVICE BY (check one):

ATTORNEY PICK-UP CONSTABLE

CIVIL PROCESS SERVER - Authorized Person to Pick-up: _______________________ Phone: _____________

MAIL CERTIFIED MAIL

PUBLICATION:

Type of Publication: COURTHOUSE DOOR, or

NEWSPAPER OF YOUR CHOICE: _______________________________________

OTHER, explain ______________________________________________________________________________

ATTORNEY (OR ATTORNEY'S AGENT) REQUESTING SERVICE:

NAME: _____________________________________________ TEXAS BAR NO./ID NO. ____________________________

MAILING ADDRESS: ____________________________________________________________________________________

PHONE NUMBER: __________ _______________________ FAX NUMBER: ________ ______________________

area code phone number area code fax number

EMAIL ADDRESS: ______________________________________________________________________________________

2020DCV0628 448th JDC El Paso County, Texas

Plaintiff's Original Petition

February 19, 2020

44 Fountain Rd., LLC

909 E. Rio Grande Ave., El Paso, Texas, 79902

Daniel S. Gonzalez

Citation

✔ Court Records Research

110 S. Festival, LLC

909 E. Rio Grande Ave., El Paso, Texas, 79902

Daniel S. Gonzalez

Citation

✔ Court Records Research

Christopher J. Leavitt 24053318

600 Travis Street, Suite 7300, Houston, TX 77002

713 223-5393 713 223-5909

cleavitt@txattorneys.com

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App. 015

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 16 of 51
THE STATE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday 

next following the expiration of twenty days after you were served this citation and petition, a default 

judgment may be taken against you." 

TO: 44 FOUNTAIN RD., LLC, which may be served with process by serving its registered, DANIELS. 

GONZALEZ at 909 E. RIO GRANDE, EL PASO, TEXAS 79902 or wherever he/she may be found 

-:.,~ 

C Greetings: '.::.;. 1;::-\ \ '_ ~ ~~.~ ·:t,. 

You are hereby commanded to appear by filing a written answer to the Pla.i.n,tiff'.s. Fr~an%,·-.-0_ 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for _._isci·o$urGt ot)~/:. 

before ten o'clock AM. of the Monday next after the expiration of twenty days after the te f•;serv~of · · : ---~'\-

this citation before the Honorable 448th Judicial District Court, El Paso County, xaS:ii"'8t==-t• 

House of said County in El Paso, Texas. ~ 

\ 

Said Plaintiff's Petition was filed in said court on this the 19th day of February, 2020 by, 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case\n ered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiff's demand is fully shown by a true and correct copy of the Plaintiff's Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law directs . 

. Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

Attest: 

By: 

NORMA FAVELA BARCELEAU District Clerk 

El Paso County, Texas 

~ U!iKJL Deputy 

JoAnnAcosta ' 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto.· 

App. 016

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 17 of 51
RETURN 

Came on hand on _____ day of _________ _, 20 __ , at ___ o'clock 

_M., and executed in _________________ County, Texas, by delivering to 

each of the within-named defendants, in person, a true copy of this Citation, having first endorsed thereon 

the date of delivery, together with the accompanying true and correct copy of the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure, at the 

following times and places, to-wit: 

NAME DATE TIME Place, and Course and Distance 

MONTH DAY YEAR Hour Min. .M. From Court House 

And not executed as to the defendant, ______________________ _ 

The diligence used in finding said defendant, being __________________ _ 

And the cause of failure to execute this process is: ------------------- And the information received as to the whereabouts of the said defendant, being _______ _ 

FEES-SERVING __ copy __ $ __ _ _ ______________ Sheriff 

_____________ County, Texas 

Total ________ $ ___ _ by ______________ , Deputy 

CERTIFICATE OF DELIVERY 

I do hereby certify that I delivered to ____________________ _ 

__________________ on the ___ day of _________ _ 

20 __ , at ___ o'clock _m. this copy of this instrument. 

_______________ , Sheriff/Agent 

______________ County, Texas 

By _____________ , Deputy/Agent 

SUBSCRIBED AND SWORN TO BEFORE ME ON THE ___ DAY OF _______ _, 20 __ . 

(SEAL) 

NOTARY PUBLIC, STATE OF TEXAS 

App. 017

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 18 of 51
THE STATE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday 

next following the expiration of twenty days after you were served this citation and petition, a def~lt 

judgment may be taken against you." ~·), 

r-'::', -~;~ 

TO: 110 S. FESTIVAL, LLC, who may be served with process by serving its registered ag~t. ~1se.:·> 

S. GONZALEZ at 909 E. RIO GRANDE, EL PASO, TEXAS 79902 or wherever he/she ~Y ~.fo~ :..~:{7-( 

~ ·.:~:' > 

Greetings: ..-0 

··•}' ·· .. ·· ~ 

You are hereby commanded to appear by filing a written answer to the Plainti ree an(H 

...,.. -~ .. Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Dis'@\ -at or~ 

before ten o'clock AM. of the Monday next after the expiration of twenty days after the date of\; i~e,of 

\ 

this citation before the Honorable 448th Judicial District Court, El Paso County, Texas, at the Court 

House of said County in El Paso, Texas. 

Said Plaintiff's Petition was filed in said court on this the 19th day of February, 2020 by Attorney at 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiff's demand is fully shown by a true and correct copy of the Plaintiff's Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law directs . 

... Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

RMA FAVELA BARCELEAU District Clerk --'-:.:.:....:..:..:.:!...!..!.-'-'-':..=.::::...:..:;.:....,:....:...:::;-==='-'=--

El Paso County, Texas . ~ 

By: --~-===~~~:..._ __ ~:..._ __ , _·72_· &-_· __ , Deputy 

~oAnn Acosta 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto." 

App. 018

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 19 of 51
RETURN 

Came on hand on _____ day of __________ , 20 __ , at ___ o'clock 

_M., and executed in _________________ County, Texas, by delivering to 

each of the within-named defendants, in person, a true copy of this Citation, having first endorsed thereon 

the date of delivery, together with the accompanying true and correct copy of the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure, at the 

following times and places, to-wit: 

NAME DATE TIME Place, and Course and Distance 

MONTH DAY YEAR Hour Min. .M. From Court House 

And not executed as to the defendant, ______________________ _ 

The diligence used in finding said defendant, being __________________ _ 

And the cause of failure to execute this process is: __________________ _ 

And the information received as to the whereabouts of the said defendant, being _______ _ 

FEES-SERVING __ copy __ $ __ _ _ _______________ Sheriff 

_____________ County, Texas 

Total ________ $ ___ _ by ______________ , Deputy 

CERTIFICATE OF DELIVERY 

I do hereby certify that I delivered to ____________________ _ 

__________________ on the ___ day of _________ _ 

20 __ , at ___ o'clock _m. this copy of this instrument. 

______________ _, Sheriff/Agent 

______________ County, Texas 

By _____________ , Deputy/Agent 

SUBSCRIBED AND SWORN TO BEFORE ME ON THE ___ DAY OF ________ , 20 __ . 

(SEAL) 

NOTARY PUBLIC, STATE OF TEXAS 

App. 019

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 20 of 51
.. THE STATE OF TEXAS -5 •·l'.) 

i· ,.-~, r:--::?, :,(. 

NOTICE _TO DE~ENDANT: "Y?u have been su~d. You ~ay_ e~ploy an attom!}'. l(you;,:or y~ 

attorney, do not file a written answer with the clerk who issued this cItatIon by 10:00 a.ITT. 011-t~e ~nd~-:~:-·r\ 

next following the expiration of twenty days after you were served this citation and ~etition: a ~fau.if :~\-;::. 

judgmentmaybetakenagainstyou." ,-:-\. ' 0 , ·'.··~<:'\ 

TO: BERTHA OLGA GOMEZ FONG, who may be served with process at 343 CRl~CL \.10~ ~,) 

PASO, TEXAS 79912 or wherever he/she may be found :..:. , . . r--:> . .. ' ,· c.,) ... 

Greetings: \ • \~-' <.J' 

You are hereby commanded to appear by filing a written answer to the Plaintiffs ~e and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure at or 

before ten o'clock AM. of the Monday next after the expiration of twenty days after the date of service of 

this citation before the Honorable 448th Judicial District Court, El Paso County, Texas, at the Court 

House of said County in El Paso, Texas. 

Said Plaintiffs Petition was filed in said court on this the 19th day of February, 2020 by Attorney at 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiff's demand is fully shown by a true and correct copy of the Plaintiff's Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the layv Q!r~cts. 

Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

Attest: NORMA FAVELA BARCELEAU District Clerk 

-· El Paso County, Texas 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto." 

App. 020

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 21 of 51
RETURN 

Came on hand on _____ day of __________ , 20 __ , at ___ o'clock 

M., and executed in _________________ County, Texas, by delivering to 

each of the within-named defendants, in person, a true copy of this Citation, having first endorsed thereon 

the date of delivery, together with the accompanying true and correct copy of the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure, at the 

following times and places, to-wit: 

NAME DATE TIME Place, and Course and Distance 

MONTH DAY YEAR Hour Min. .M. From Court House 

And not executed as to the defendant, ______________________ _ 

The diligence used in finding said defendant, being __________________ _ 

And the cause of failure to execute this process is: __________________ _ 

And the information received as to the whereabouts of the said defendant, being _______ _ 

FEES-SERVING __ copy __ $ __ _ _ _______________ Sheriff 

_____________ County, Texas 

Total ________ $ __ _ by ______________ , Deputy 

CERTIFICATE OF DELIVERY 

I do hereby certify that I delivered to ____________________ _ 

__________________ on the ___ day of _________ _ 

20 __ , at ___ o'clock _m. this copy of this instrument. 

_______________ , Sheriff/Agent 

______________ County, Texas 

By _____________ , Deputy/Agent 

SUBSCRIBED AND SWORN TO BEFORE ME ON THE ___ DAY OF ________ , 20 __ . 

(SEAL) 

NOTARY PUBLIC, STATE OF TEXAS 

App. 021

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 22 of 51
THE STATE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the MondaY., 

next following the expiration of twenty days after you were served this citation and petition, a defaulrs~1 

judgment may be taken against you." . ,·, '::: :::,:. I \-""} ~.,. ~ • 

,~., \ . <- } .:::'4 ....... , 

TO: CAD CONSTRUCTION, INC., which may be served with process by serving its registere(t.ag~ '-.~~-~ ._ 

CESAR ADRIAN DUARTE at 343 CRIMSON CLOUD, EL PASO, TEXAS 79912 or wh~r r hef,she::P · :~p'i°"· 

may be found \- .. rj, · '. · :,'. 

( (~,- ..-0 

. *~ 

Greetings: -~'\O _ ~\";-? · 

You are hereby commanded to appear by filing a written answer to the Plaintiff'~ and& 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Discl~~t or 

before ten o'clock AM. of the Monday next after the expiration of twenty days after the date of service of 

this citation before the Honorable 448th Judicial District Court, El Paso County, Texas, at the Court 

House of said County in El Paso, Texas. 

Said Plaintiffs Petition was filed in said court on this the 19th day of February, 2020 by Attorney at 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiffs demand is fully shown by a true and correct copy of the Plaintiff's Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law directs. 

Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto." 

App. 022

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 23 of 51
RETURN 

Came on hand on _____ day of __________ , 20 __ , at ___ o'clock 

_M., and executed in _________________ County, Texas, by delivering to 

each of the within-named defendants, in person, a true copy of this Citation, having first endorsed thereon 

the date of delivery, together with the accompanying true and correct copy of the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure, at the 

following times and places, to-wit: 

NAME DATE TIME Place, and Course and Distance 

MONTH DAY YEAR Hour Min. .M. From Court House 

And not executed as to the defendant, ______________________ _ 

The diligence used in finding said defendant, being __________________ _ 

And the cause of failure to execute this process is: __________________ _ 

And the information received as !O the whereabouts of the said defendant, being _______ _ 

FEES-SERVING __ copy __ $ __ _ _ _______________ Sheriff 

_____________ County, Texas 

Total ________ $ ___ _ by ______________ , Deputy 

CERTIFICATE OF DELIVERY 

I do hereby certify that I delivered to ____________________ _ 

__________________ on the ___ day of _________ _ 

20 __ , at ___ o'clock _m. this copy of this instrument. 

_______________ , Sheriff/Agent 

______________ County, Texas 

By _____________ , Deputy/Agent 

SUBSCRIBED AND SWORN TO BEFORE ME ON THE ___ DAY OF ________ , 20 __ . 

(SEAL) 

NOTARY PUIJLIC, STATE OF TEXAS 

App. 023

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 24 of 51
THE STATE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday 

next following the expiration of twenty days after you were served this citation and petition, a default 

judgment may be taken against you." '{.; 

!,''.~, ~:~ ~1 

TO: CESAR ADRIAN DUARTE GOMEZ, who may be served with process at 378 MOijt,IING'ST~, 0 -;.0

• 

::~~::: TEXAS 79912 or whe~ver h~she may be round I ~tr t ':;}? 

'~ ~ You are hereby commanded to appear by filing a written answer to the Plai~tj!:E., ·ee a~ 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disc e at ~ \ . <Ji 

before ten o'clock A.M. of the Monday next after the expiration of twenty days after the date of s rvice of 

this citation before the Honorable 448th Judicial District Court, El Paso County, Texas, at the Court 

House of said County in El Paso, Texas. 

Said Plaintiffs Petition was filed in said court on this the 19th day of February, 2020 by Attorney at 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiffs demand is fully shown by a true and correct copy of the Plaintiff's Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law directs. 

Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

Attest: 

By: 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto." 

App. 024

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 25 of 51
RETURN 

Came on hand on _____ day of __________ _, 20 __ , at ___ o'clock 

_M., and executed in _________________ County, Texas, by delivering to 

each of the within-named defendants, in person, a true copy of this Citation, having first endorsed thereon 

the date of delivery, together with the accompanying true and correct copy of the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure, at the 

following times and places, to-wit: 

NAME DATE TIME Place, and Course and Distance 

MONTH DAY YEAR Hour Min. .M. From Court House 

And not executed as to the defendant, ______________________ _ 

The diligence used in finding said defendant, being __________________ _ 

And the cause of failure to execute this process is: __________________ _ 

And the information received as to the whereabouts of the said defendant, being _______ _ 

FEES-SERVING __ copy __ $ __ _ _ _______________ Sheriff 

_____________ County, Texas 

Total ________ $ __ _ by ______________ , Deputy 

CERTIFICATE OF DELIVERY 

I do hereby certify that I delivered to ____________________ _ 

__________________ on the ___ day of _________ _ 

20 __ , at ___ o'clock _m. this copy of this instrument. 

_______________ , Sheriff/Agent 

______________ County, Texas 

By _____________ , Deputy/Agent 

SUBSCRIBED AND SWORN TO BEFORE ME ON THE ___ DAY OF ________ , 20 __ . 

(SEAL) 

NOTARY PUBLIC, STATE OF TEXAS 

App. 025

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 26 of 51
THE STATE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday 

next following the expiration of twenty days after you were served this citation and petition, a default 

judgment may be taken against you." 6 r--, ~; 

TO: CESAR HORACIO DUARTE JAQUEZ, who may be served with process at 343 C~IMSON f2, ...,::~· 

CLOUD, EL PASO, TEXAS 79912 or wherever he/she may be found .>. :'~ ':.i, {ii~ 

Greeting;ou are hereby commanded to appear by filing a written answer to the Pl J.:~"re~d '" ,- ~, " 

~- ~ Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Dis~ at 8£ 

before ten o'clock AM. of the Monday next after the expiration of twenty days after the date ?~ice ~ 

this citation before the Honorable 448th Judicial District Court, El Paso County, Texas, at the Court 

House of said County in El Paso, Texas. 

Said Plaintiff's Petition was filed in said court on this the 19th day of February, 2020 by Attorney at 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiff's demand is fully shown by a true and correct copy of the Plaintiff's Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law directs. 

Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

Attest: NORMA FAVELA BARCELEAU District Clerk 

. El Paso County, Texas 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto." 

App. 026

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 27 of 51
RETURN 

Came on hand on _____ day of __________ , 20 __ , at ___ o'clock 

_M., and executed in _________________ County, Texas, by delivering to 

each of the within-named defendants, in person, a true copy of this Citation, having first endorsed thereon 

the date of delivery, together with the accompanying true and correct copy of the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure, at the 

following times and places, to-wit: 

NAME DATE TIME Place, and Course and Distance 

MONTH DAY YEAR Hour Min. .M. From Court House 

And not executed as to the defendant, ______________________ _ 

The diligence used in finding said defendant, being __________________ _ 

And the cause of failure to execute this process is: __________________ _ 

And the information received as to the whereabouts of the said defendant, being _______ _ 

FEES-SERVING --copy --$ --- ________________ Sheriff 

_____________ County, Texas 

Total ________ $ __ _ by ______________ , Deputy 

CERTIFICATE OF DELIVERY 

I do hereby certify that I delivered to ____________________ _ 

__________________ on the ___ day of _________ _ 

20 __ , at ___ o'clock _m. this copy of this instrument. 

_______________ , Sheriff/Agent 

_______________ County, Texas 

By _____________ , Deputy/Agent 

SUBSCRIBED AND SWORN TO BEFORE ME ON THE ___ DAY OF _______ _, 20 __ . 

(SEAL) 

NOTARY PUBLIC, STATE OF TEXAS 

App. 027

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 28 of 51
THE STATE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday 

next following the expiration of twenty days after you were served this citation and petition, a default 

judgment may be taken against you." 

TO: GABRIELA ARMENDARIZ CHAPARRO, who may be served with process at 6928 DIAM,OND ~ RIDGE DR, EL PASO, TEXAS 79912 or wherever he/she may be found 1

;·.::: f::'., ~: ':_).! ' ..:>·· ~,,. .... 

:'- ·::. ~ ~)} \ -~. 

Greetings: N >f-'? 

,.n · · 1··• 

You are hereby commanded to appear by filing a written answer to t .s Fr-"f anl. ::: -,,• 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request or iosurf.pt qr . ·_··. 

before ten o'clock AM. of the Monday next after the expiration of twenty days after the 

1

~f se~ of 1f'·:. 

this citation before the Honorable 448th Judicial District Court, El Paso County, Tex.s, he Court 

House of said County in El Paso, Texas. 

Said Plaintiff's Petition was filed in said court on this the 19th day of February, 2020 by Attorney at 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiff's demand is fully shown by a true and correct copy of the Plaintiff's Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law dire~ts. 

Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

Attest: NORMA FAVELA BARCELEAU District Clerk 

y El Paso County, Texas 

By: C!Jff::/!~~, Depuzy 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto." 

App. 028

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 29 of 51
RETURN 

Came on hand on _____ day of __________ , 20 __ , at ___ o'clock 

_M., and executed in _________________ County, Texas, by delivering to 

each of the within-named defendants, in person, a true copy of this Citation, having first endorsed thereon 

the date of delivery, together with the accompanying true and correct copy of the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure, at the 

following times and places, to-wit: 

NAME DATE TIME Place, and Course and Distance 

MONTH DAY YEAR Hour Min. .M. From Court House 

And not executed as to the defendant, ______________________ _ 

The diligence used in finding said defendant, being __________________ _ 

And the cause of failure to execute this process is: __________________ _ 

And the information received as to the whereabouts of the said defendant, being _______ _ 

FEES-SERVING __ copy __ $ __ _ _ _______________ Sheriff 

_____________ County, Texas 

Total ________ $ __ _ by ______________ , Deputy 

CERTIFICATE OF DELIVERY 

I do hereby certify that I delivered to ____________________ _ 

__________________ on the ___ day of _________ _ 

20 __ , at ___ o'clock _m. this copy of this instrument. 

_______________ , Sheriff/Agent 

______________ County, Texas 

By _____________ , Deputy/Agent 

SUBSCRIBED AND SWORN TO BEFORE ME ON THE ___ DAY OF ________ , 20 __ , 

(SEAL) 

NOTA'RY PUBLIC, STATE OF TEXAS 

App. 029

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 30 of 51
THE STATE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday 

next following the expiration of twenty days after you were served this citation and petition, a default 

judgment may be taken against you." ::·; ' 0 

' 1--=• ~~ TO: MANUEL ALBERTO GARZA, who may be served with process at 236 HIDDEN CREs;t cn,f:,~E,,-::: 

EL PASO, TEXAS 79912or wherever he/she may be found ":"~. _,, <:..;, -~,:: 

t~ ft? 

Greetings: <.fl ·, ,. · ·' 

You are hereby commanded to appear by filing a written answer to the Plairttitf ree ~ 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Di~~I e. at i 

before ten o'clock A.M. of the Monday next after the expiration of twenty days after the date ~f s rvice df' 

this citation before the Honorable 448th Judicial District Court, El Paso County, Texas, at the Court 

House of said County in El Paso, Texas. 

Said Plaintiff's Petition was filed in said court on this the 19th day of February, 2020 by Attorney at 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiff's demand is fully shown by a true and correct copy of the Plaintiff's Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law direct$. 

Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

Attest: NORMA FAVELA BARCELEAU District Clerk 

By: 

. 'Ef Paso County, Texas 

------+-""-,...----------' c~UanStC Deputy JoAnnAcosta 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto." 

App. 030

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 31 of 51
RETURN 

Came on hand on _____ day of __________ , 20 __ , at ___ o'clock 

_M., and executed in _________________ County, Texas, by delivering to 

each of the within-named defendants, in person, a true copy of this Citation, having first endorsed thereon 

the date of delivery, together with the accompanying true and correct copy of the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure, at the 

following times and places, to-wit: 

NAME DATE TIME Place, and Course and Distance 

MONTH DAY YEAR Hour Min. .M. From Court House 

And not executed as to the defendant, ______________________ _ 

The diligence used in finding said defendant, being __________________ _ 

And the cause of failure to execute this process is: __________________ _ 

And the information received as to the whereabouts of the said defendant, being _______ _ 

FEES-SERVING __ copy __ $ __ _ _ _______________ Sheriff 

_____________ County, Texas 

Total ________ $ __ _ by ______________ , Deputy 

CERTIFICATE OF DELIVERY 

I do hereby certify that I delivered to ____________________ _ 

__________________ on the ___ day of _________ _ 

20 __ , at ___ o'clock _m. this copy of this instrument. 

_______________ , Sheriff/Agent 

______________ County, Texas 

By ____________ , Deputy/Agent 

SUBSCRIBED AND SWORN TO BEFQRE ME ON THE ___ DAY OF ________ , 20 __ . 

(SEAL) 

NOTARY PUBLIC, STATE OF TEXAS 

App. 031

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 32 of 51
THE STATE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday __ 

next following the expiration of twenty days after you were served this citation and petition, a defaulf\ 

judgment may be taken against you." c , .. c -~i. C" 1 ; - , '-i~.~·_.\ s~~~' 

TO: OLGA DUARTE JAQUEZ, who may be served with process at 100 STERN ORI~·:. L·.i'.. AS~ '

1 '·,, 

TEXAS 79932 or wherever he/she may be found ____ ·._, ~ ::·:\~:i:\ 

\

,... ·. c • .r, .. ,. '',I ..._ 

. - . ~ . 

Greetmg:ou are hereby commanded to appear by filing a written answer to the Plal~l~e ~ Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Dis~l,o~ at Af.'' ~ ' .. 

before ten o'clock AM. of the Monday next after the expiration of twenty days after the date of service of 

this citation before the Honorable 448th Judicial District Court, El Paso County, Texas, at the Court 

House of said County in El Paso, Texas. 

Said Plaintiff's Petition was filed in said court on this the 19th day of February, 2020 by Attorney at 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiff's demand is fully shown by a true and correct copy of the Plaintiff's Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law directs. 

Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

Attest: 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto.• 

App. 032

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 33 of 51
RETURN 

Came on hand on _____ day of __________ , 20 __ , at ___ o'clock 

_M., and executed in _________________ County, Texas, by delivering to 

each of the within-named defendants, in person, a true copy of this Citation, having first endorsed thereon 

the date of delivery, together with the accompanying true and correct copy of the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure, at the 

following times and places, to-wit: 

NAME DATE TIME Place, and Course and Distance 

MONTH DAY YEAR Hour Min. .M. From Court House 

And not executed as to the defendant, ______________________ _ 

The diligence used in finding said defendant, being __________________ _ 

And the cause of failure to execute this process is: __________________ _ 

And the information received as to the whereabouts of the said defendant, being _______ _ 

FEES-SERVING __ copy __ $ __ _ _ _______________ Sheriff 

_____________ County, Texas 

Total ________ $ __ _ by ______________ , Deputy 

CERTIFICATE OF DELIVERY 

I do hereby ce~ify that I delivered to ____________________ _ 

__________________ on the ___ day of _________ _ 

20 __ , at ___ o'clock _m. this copy of this instrument. 

_______________ , Sheriff/Agent 

______________ County, Texas 

By _____________ , Deputy/Agent 

SUBSCRIBED AND SWORN TO BEFORE ME ON THE ___ DAY OF ________ , 20 __ . 

(SEAL) 

NOTARY PUBLIC, STATE OF TEX.AS 

App. 033

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 34 of 51
THE STATE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the MondaY,,e:. 

next following the expiration of twenty days after you were served this citation and petition, a ~fault':-]1 

judgment may be taken against you." : ' ~'::. _·2t. . r·:~ i_ .. , ~:~), ~-:?. :,., -, ,....t ,. 1')-,-, 

TO: OLGA SOFIA DUARTE GOMEZ, who may be served with process at 343 CRIMil;.OUD"~L ·: :-·-. :: ·~; 

PASO, TEXAS 79912 or wherever he/she may be found , r-J ,_-.:_ · \ -, 

( <:, . c.J\ -~ . \ ' ·\ 

,.. . ~ . 

Greeting~ou are hereby commanded to appear by filing a written answer to the Plaintl~\ e :i ... \ ·. c.f\ 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for DisClf? at or 

before ten o'clock AM. of the Mor,day next after the expiration of twenty days after the date of service of 

this citation before the Honorable 448th Judicial District Court, El Paso County, Texas, at the Court 

House of said County in El Paso, Texas. 

Said Plaintiffs Petition was filed in said court on this the 19th day of February, 2020 by Attorney at 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiffs demand is fully shown by a true and correct copy of the Plaintiffs Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law directs. 

Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

NORMA FAVELA BARCELEAU 

El Paso County, Texas 

District Clerk 

l;{/ihu.... /) /\_,.._L.J7- By: _______ L_JL_LY-D ___ ..__ ___ , Deputy 

JoAnn Acosta 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto." 

App. 034

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 35 of 51
RETURN 

Came on hand on _____ day of __________ , 20 __ , at ___ o'clock 

M., and executed in _________________ County, Texas, by delivering to 

each of the within-named defendants, in person, a true copy of this Citation, having first endorsed thereon 

the date of delivery, together with the accompanying true and correct copy of the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure, at the 

following times and places, to-wit: 

NAME DATE TIME Place, and Course and Distance 

MONTH DAY YEAR Hour Min. .M. From Court House 

And not executed as to the defendant, ______________________ _ 

The diligence used in finding said defendant, being __________________ _ 

And the cause of failure to execute this process is: __________________ _ 

And the information received as to the whereabouts of the said defendant, being _______ _ 

FEES-SERVING __ copy __ $ __ _ _ _______________ Sheriff 

_____________ County, Texas 

Total ________ $ __ _ by ______________ , Deputy 

CERTIFICATE OF DELIVERY 

I do hereby certify that I delivered to ____________________ _ 

__________________ on the ___ day of _________ _ 

20 __ , at ___ o'clock _m. this copy of this instrument. 

_______________ , Sheriff/Agent 

______________ County, Texas 

By _____________ , Deputy/Agent 

SUBSCRIBED AND SWORN TO BEFORE ME ON THE ___ DAY OF ________ , 20 __ . 

(SEAL) 

NOTARY PUBLIC, STATE OF TEXAS 

App. 035

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 36 of 51
Filed 3/17/2020 10:30 AM

2020DCV0628

Norma Favela Barceleau

El Paso County - 448th District Court

District Clerk

El Paso County

THE STATE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday 

next following the expiration of twenty days after you were served this citation and petition, a default 

judgment may be taken against you." 

TO OLGA SOFIA DUARTE GOMEZ, who may be served with process at 343 CRIMSON CLOUD, EL 

PASO, TEXAS 79912 or wherever he/she may be found 

Greetings: 

You are hereby commanded to appear by filing a written answer to the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure at or 

before ten o'clock AM. of the Monday next after the expiration of twenty days after the date of service of 

this citation before the Honorable 448th Judicial District Court, El Paso County, Texas, at the Court 

House of said County in El Paso, Texas. 

Said Plaintiff's Petition was flied in said court on this the 19th day of February, 2020 by Attorney at 

Law, ANTHONY G BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

VS 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiffs demand is fully shown by a true and correct copy of the Plaintiff's Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law directs. 

Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

NORMA FAVELA BARCELEAU District Clerk 

El Paso County, Texas 

By: 

Rule 106: "•the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto." 

App. 036

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 37 of 51
FREE AND SOVEREIGN STATE OF 

CHIHUAHUA 

vs. 

CESAR HORACIO DUARTE 

JAQUEZ, ET AL 

CAUSE NO. 2020DCV0628 

IN THE 448TH JUDICIAL DISTRICT COURT OF EL PASO COUNTY, 

TEXAS 

AFFIDAVIT OF SERVICE 

BEFORE ME, the undersigned authority, 8~C;j)()J\G }- - ~Ct::1)\J~-ti{SERVER), personally appeared on this day and stated 

under oath as follows: 

1. My name Is ,' SERVER). I am over the age of eighteen (18), 1 am not 

a party to this case, and have no interest in · utcome. I am in all ways competent to make this affidavit 

and this affidavit is based on personal knowledge. The facts stated herein are true and correct, My business 

address 

~ 

is: ),.. , 1:- L n ,-.., N. \._~J~'\ r:;, \ ~\,,D i;:.1 :t:::'Q;;JQ , -----r'K 799 2.S 

(SERVER'S ADDRES!?) 

2. ON ..2-.L)- ?J'J?Q (DATE) AT .,,!:I : :'32.. (£) M (TIME) 

CITATION PLAINTIFF FREE AND SOVEREIGN STATE OF CHIHUAHUA'S ORIGINAL PETITION, JURY DEMAND, 

AND REQUEST FOR DISCLOSURE came to hand for delivery to OLGA SOFIA DUARTE GOMEZ. 

3, ON :3-12.. - 'lt;,ZO (DATE) AT '2i : .34 (A.) M (TIME) - The above named 

documents were delivered to: OLGA SOFIA DUARTE GOMEZ at: 

.3 CC'' F-1 

AT 

PSC# :-\] EXPIRAT N: -3/- 2._02_) 

R1c'rn>,£> 1;,_. 1b;Y)1'~e.:z---

AFFIANT PRINTED NAME 

SWORN TO AND SUBSCRIBED before me by hlc.hn.ll!). G.J:)IY'()i~~P~~ed on this -1.3_ day of 

r::::r::::\al\Cb • "-' 2020 to attest witness my hand and seal of office. 

NOTARY PUBLIC IN AND 

FOR THE STATE OF TEXAS 

2020.03,454776 

App. 037

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 38 of 51
Filed 3/19/2020 11:56 AM

2020DCV0628

Norma Favela Barceleau

El Paso County - 448th District Court

District Clerk

El Paso County

THE STATE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday 

next following the expiration of twenty days after you were served this citation and petition, a default 

judgment may be taken against you." 

TO: OLGA DUARTE JAQUEZ, who may be served with process at 100 STERN DRIVE, EL PASO, 

TEXAS 79932 or wherever he/she may be found 

Greetings: 

You are hereby commanded to appear by filing a written answer to the Plaintiffs Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure at or 

before ten o'clock AM. of the Monday next after the expiration of twenty days after the date of service of 

this citation before the Honorable 448th Judicial District Court, El Paso County, Texas, at the Court 

House of said County in El Paso, Texas. 

Said Plaintiff's Petition was filed in said court on this the 19th day of February, 2020 by Attorney at 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAO CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiffs demand is fully shown by a true and correct copy of the Plaintiffs Free 

and Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law directs. 

Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25th day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

El Paso, Texas 79901 

Attest: NORMA FAVELA BARCELEAU District Clerk 

El Paso County, Texas 

By: Cf!!lft:Aco~ Deputy 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto." 

App. 038

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 39 of 51
FREE AND SOVEREIGN STATE OF 

CHIHUAHUA 

vs. 

CESAR HORACIO DUARTE 

JAQUEZ, ET AL 

CAUSE NO. 2020DCV0628 

IN THE 448TH JUDICIAL DISTRICT COURT OF EL PASO COUNTY, 

TEXAS 

AFFIDAVIT OF SERVICE 

BEFORE ME, the undersigned authority, R\c:u)C)J\p,. l::,. DC(T),',~ti(SERVER), personally appeared on this day and stated 

under oath as follows: 

1. My name Is e~cbMD G... .Da N);'~\fZ(SERVER). I am over the age of eighteen (18), lam not 

a party to this case, and have no interest in ~utcorne. I am in all ways competent to make this affidavit 

and this affidavit is based on personal knowledge. The facts stated herein are true and correct. My business 

address 

~ is: )-: LL L !? r,, tJ . \._~~'\ D \'A\..~ E:,.\ :t::~0 r\)(,, 79925' 

(SERVER'S ADORES~} 

2. ON :3-4-- ZtlZD (DATE) AT ..!J : ..::32.. {D M (TIME) 

CITATION PLAINTIFF FREE AND SOVEREIGN STATE OF CHIHUAHUA'S ORIGINAL PETITION, JURY DEMAND, 

AND REQUEST FOR DISCLOSURE came to hand for delivery to OLGA SOFIA DUARTE GOMEZ. 

3. ON ,3-12..~ 2-t>ZO (DATE) AT <2, : 24 ( A.) M {TIME) -The above named 

documents were delivered to: OLGA SOFIA DUARTE GOMEZ at: 

(ADDRESS), by PE 

..=,::!.......:..,.1- EXPI /- 2.(YZJ ..... t r-cu J) h. . m e :z_.... 

AFFIANT PRINTED NAME 

SWORN TO AND SUBSCRIBED before me by ....,__=~="""'-=.a==-=-~ ::::,,gii"P1ared on this _Lj___ day of a::':)ax::'b • _, 2020 to attest witness my 

NOTARY PUBLIC IN AND 

FOR THE STATE OF TEXAS 

202.0.03,454776 

App. 039

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 40 of 51
Filed 3/19/2020 11:54 AM

2020DCV0628

Norma Favela Barceleau

El Paso County - 448th District Court

District Clerk

El Paso County

THE ST A TE OF TEXAS 

NOTICE TO DEFENDANT: "You have been sued. You may employ an attorney. If you, or your 

attorney, do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday 

next following the expiration of twenty days after you were served this citation and petition, a default 

judgment may be taken against you." 

TO: GABRIELA ARMENDARIZ CHAPARRO, who may be served with process at 6928 DIAMOND 

RIDGE DR, EL PASO, TEXAS 79912 or wherever he/she may be found 

Greetings: 

You are hereby commanded to appear by filing a written answer to the Plaintiff's Free and 

Sovereign State of Chihuahua's Original Petition, Jury Demand, and Request for Disclosure at or 

before ten o'clock A.M. of the Monday next after the expiration of twenty days after the date of service of 

this citation before the Honorable 448th Judicial District Court, El Paso County, Texas, at the Court 

House of said County in El Paso, Texas. 

Said Plaintiffs Petition was filed in said court on this the 19111 day of February, 2020 by Attorney at 

Law, ANTHONY G. BUZBEE, 600 TRAVIS, SUITE 7300, HOUSTON, TX 77002, in this case numbered 

2020DCV0628 on the docket of said court, and styled: 

FREE AND SOVEREIGN STATE OF CHIHUAHUA 

vs 

CESAR HORACIO DUARTE JAQUEZ, BERTHA OLGA GOMEZ FONG, OLGA SOFIA DUARTE 

GOMEZ, OLGA DUARTE JAQUEZ, CESAR ADRIAN DUARTE, CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, MANUEL ALBERTO GARZA, 44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC 

The nature of Plaintiffs demand is fully shown by a true and correct copy of the Plaintiff's Free 

and Sovereign State of Chihuahua's Origina, Petition, Jury Demand, and Request for Disclosure 

accompanying this citation and made a part hereof. 

The officer executing this writ shall promptly serve the same according to requirements of law, 

and the mandates thereof, and make due return as the law directs. 

Issued and given under my hand and seal of said Court at El Paso, Texas, on this the 25111 day of 

February, 2020. 

CLERK OF THE COURT 

NORMA FAVELA BARCELEAU 

District Clerk 

El Paso County Courthouse 

500 E. San Antonio Ave, RM 103 

EIPaso,Texas79901 

District Clerk 

El Paso County, Texas 

( -~-- 1 1/ , /A) 4. ,Hr' By: ___ -__,, ' L--____ l,,_tfLO!-C:J ____ v---__ , Deputy 

JoAnn Acosta 

Rule 106: "-the citation shall be served by the officer delivering to each defendant, in person, a true copy of the citation with the 

date of delivery endorsed thereon and with a copy of the petition attached thereto." 

App. 040

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 41 of 51
( 

FREE AND SOVEREIGN STATE OF 

CHIHUAHUA 

vs. 

CESAR HORACIO DUARTE 

JAQUEZ, ET AL 

CAUSE NO. 2020DCV0628 

IN THE 448TH JUDICIAL DISTRICT COURT OF EL PASO COUNTY, 

TEXAS 

AFFIDAVIT OF SERVICE 

BEFORE ME, the undersigned authority, k .'cllO.l,i\ G.-.b(XY)i{\().U~RVER), personally appeared on this day and stated 

under oath as follows: - ...S 

1. My name is 1 ~ b.. · Deim)\ ~ SERVER). I am over the age of eighteen (18), I am not 

a party to this case, and have no interest in its utcome. I am in all ways competent to make this affidavit 

and this affidavit is based on personal knowledge, The facts stated herein are true and correct. My business 

address is: • \_ r) \ G 

~ ,. . "'- OJ"\Pr'GDC-. ..-l-J -::.:i '~D ~ 7 9::)£; 

(SERVER'S ADORE ) ---

2. ON $-L\- 2() 2() (DATE) AT Q 3 4 (£} M (TIME) 

CITATION PLAINTIFF FREE AND SOVEREIGN STATE OF CHIHUAHUA'S ORIGINAL PETITION, JURY DEMAND, 

AND REQUEST FOR DISCLOSURE came to hand for delivery to GABRIELA ARMENDARIZ CHAPARRO. 

3. ON ~-E- 2.{) 2C) (DATE) AT ( a : 0 f5 rP) M (TIME) - The above named 

documents were delivered to: GABRIELA ARMENDARIZ CHAPARRO at: 

_D J'o..n-1or,J ~,I_Do E: ))fl. - £) ~~o 1 ·Jx 799 IQ. 

(ADDRESS), by PERSONAL Service 

r 

IGNAT E 

PSC#ft/o71 EXPIRATI 'fo-3/ ·· 2..0zJ 

Kl ci'\Di<n ~ , Do/YI ,'/2§ lj c_ -z_ 

AFFIANT PRINTED NAME 

SWORN TO AI\ID SUBSCREBED before me by f21•0J,o./2D f.,,. D()m,•~~P~~~red on this ----5_ day of 

~\.C. n 2020 to attest witness my hand and seal of office. 

NOTARY PUBLIC IN AND 

FOR THE STATE OF TEXAS 

2020.0:3.454761 

App. 041

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 42 of 51
Filed 3/24/2020 10:20 AM

2020DCV0628

Norma Favela Barceleau

El Paso County - 448th District Court

District Clerk

El Paso County

. . . . . . . .. .. . 

1i9~i'\i:,?t:~;~,t:%;f~tl:.tz:,~w1tb·w~•~imef!i~()fl c~!)l).p; Ji4··· 

Greetings: · · 

You are hereby·i;qrnmancteq •to• eppear.·by tlUng . 9 . wrift~n•·ansWerto the· Plat6tiff'$•·FritJ • and · 

Sqvel'eigi1 • State of Chihgahμa•~ • Origfoal . PetJtiPn, ;Jury· OemM1d; and Requestfor •Oi$<;1qsure • at ot· 

·:::::·~0~~t::::::a~:::ir:::::.:t:0

:::~:;;m;!-::::.~ 

Saiti••PlainfiffsPetitiortWa~ fiIEldtn~eid court~nthlsthe.19lh day of F~bru~ry, 202<lby.Altorneyat • 

law, ANTHONY: G:•BU.ZB.EEi.600.TRA\/lS; $l.JITE! 7$0(}; HOVST:ON •• rx•noo2, in tnist~s~ •nurnbered 

· l0,2ot>CVos2s on• th¢ t19q~¢tof said court; anti &tYled: · 

FREE ANO $0VEREIGN • S:TJl'lE OF CHH·tlJA.HtiA 

·cJ:$AR·.··· 

•HORACfO ·· ··· .. · .. 

DUARTJ; 

· .•• . •·•··. ·

~AQt.ll:Z,8ER1'HA 

·•· . , ... . . ··.·.·•· · ..•...• \I~ : . ···•···· ·· ·••·· ( ..•.•. ·....• . .·· .. · ·••.•·•··· •· ········ .·. ()LGA ~O:MEZ FONG,.OkGA SOflA DUARTE· 

GA:~r~::::~~,15!3!!~~44,:a~~lrl~tt;i~g;,rid 

·:~:~i~if !i?~! :=1Wii?i~~~.~~•~::~J~~:ttti:: 

and .the ~~i::::;heei:di,ti~~l~t:itr:f!tSl:::1~ei:w~i:6t!:tne. a;Cordjng . to• reqyirememts of. iaw; 

. . ' . .: . : . . :·-·· .· .. ... .... ::- . . ·: : ... :· ·:•: ·:-: ... :,· ... J< . ·::.·<: .· '.· ... . ··<·:: . . ·.:. ·· .. ·=.· :-: :•.·.:_.. . . . .. 

Feprnary

. . . .. ,~sμed and given unoer:n;ynand•afid $$al of saidCourtaf. El Pa$oi•Tex~s,• on• tJ-ti~.the ~5~day ·of · , '.4020, . . . . . . 

CtE:RKO'.FfHECQURT .· · ·· 

N!?'Pt1/\ FAVE~A $A8CELEAU . \ ~ : j ' ····• 

~"':;{~f!W cp~rthPU~• . ...... w\i1. 7 .r 500 g; Safi Antoq1q}\ve; RM 103 , -ri > < .. .... · ... • 

El Paso, T~~as 79901 ~"('··.o·\·u·N••.· .·••.·. e· .. ··•s·•. •.·.t•··.:··· . . . .. NOBMA FAVEL.n. aA~C~LEA.lJ.. · Df$trict Clerk 

l;l l?ci$o C::pqrity'; Texc1.s · 

; ~·"'::;<:'.t/Jj,.•, A·.·. n .. ld!J.'.·••· ·· !}·,:-4,} .. lL..: ... ·. .. ·•~.·,•·•.· ... • ~ :(..~ ~ -•.··· •·•·· J~ . O~puty .. (.;) · · · · · .J6Anri Abosta< · · · · · · .· · 

Rple )06: •;thi cital1on shali beserved by the officer qeliyering to each. defendant, in pe'$$ri .i true copy .of th~ .::it,ifion With the 

· da~e ofdeiivery endorsed thereoii and with a copy oflhe petition iittach$d thereto," 

App. 042

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 43 of 51
NO. 2020PCV0628 

FREE AND SOVEREIGN STATE OF CHIHUAHUA § 

§ 

§ 

vs. § 

§ 

CESAR HORACIO DUARTE JAQUEZ, ET AL § 

IN THE 448TH JUDICIAL DISTRICT COURT OF 

EL PASO COUNTY, TEXAS 

AFFIDAVIT OF SERVICE 

BEFORE ME, the under_Jgtpld~~rlty, ..• } OJS,.~rr9 (Process Server), personally appeared on 

this 2Qday of ~n!l] , 2020 and stated under oath as follows: 

1. My name ij~'JS ~r:r:A <server). lam over the age of eighteen (18), I am not a party to this 

case, and have no Interest In Its outcome. I am In all ways competent to mi:lke this affidavit and this affidavit Is 

based on personal knowledge. The facts st:ated herein are true and correct. My business address Is: 

19 \u, RcigJer S-h Nrarai 'F4.. . 33)30 (SERVER'S ADDRESS) 

2. ON ~ H 12.o (DATE) AT I Q : OQ <.[LM (tINE) C!TATION,PLAINllFF FREE 

AND sov~ GN ~TATE OF CHIHUAHUA'S ORIGINAL PETITION, JURY DEMAND, AND REQUEST FOR 

DISCLOSURE came to hand for dellvery to BERTHA OLGA GOMEZ FONG. 

M (TIME) The above named documents 

\3b 

FURTHER AFFIANT SAYETH NOT. 

ed on this 2C;> 

2020.03,458247 

App. 043

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 44 of 51
No. 2020DCV0628 

FREE AND SOVEREIGN STATE OF 

CHIHUAHUA, 

Plaintiff, 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§

§

§

§

§

§

§

§ 

§ 

§ 

IN THE DISTRICT COURT OF 

v. 

CESAR HORACIO DUARTE JAQUEZ, 

BERTHA OLGA GOMEZ FONG, 

OLGA SOFIA DUARTE GOMEZ, 

OLGA DUARTE JAQUEZ, 

CESAR ADRIAN DUARTE, 

CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, 

MANUEL ALBERTO GARZA, 

44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC, 

 

EL PASO COUNTY, TEXAS 

Defendants. 448TH JUDICIAL DISTRICT 

DEFENDANTS’ SPECIAL APPEARANCE TO OBJECT TO JURISDICTION 

Pursuant to Tex. R. Civ. P. 120a, defendants Cesar Horacio Duarte-Jaquez (“Mr. 

Duarte”) and Bertha Olga Gomez-Fong (“Ms. Gomez”) (collectively, “Defendants”), through 

their counsel, specially appear to object to personal jurisdiction and move for dismissal for lack 

of personal jurisdiction. Defendants lack sufficient minimum contacts with Texas to establish 

personal jurisdiction, and the exercise of jurisdiction over them would offend traditional notions 

of fair play and substantial justice. 

Texas Rule of Civil Procedure 120a allows defendants to appear specially, without 

making a general appearance, to object to this Court’s exercise of jurisdiction over them. 

Defendants give notice that all of their filings, including answers, either alone or jointly with 

other defendants, and other participation in this suit or any related matter is subject to, and does 

not waive, this special appearance. 

Filed 3/30/2020 8:36 AM

2020DCV0628

Norma Favela Barceleau

El Paso County - 448th District Court

District Clerk

El Paso County

App. 044

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 45 of 51
-2- 

Defendants respectfully request that the Court sustain their Special Appearance to Object 

to Jurisdiction and dismiss the Original Petition (“Petition”) filed by the Free and Sovereign 

State of Chihuahua (“Chihuahua” or “Plaintiff”). Defendants preserve and do not waive their 

right to amend this special appearance and to move to dismiss the Petition, including for lack of 

personal jurisdiction, in federal court. 

FACTUAL AND PROCEDURAL BACKGROUND

On February 19, 2020, Chihuahua filed the Petition giving rise to this action. Ct. Dkt. 1. 

Without providing any factual detail whatsoever, let alone any substantiating information, the 

Petition alleges that Mr. Duarte violated Mexican government procurement laws while he was 

the governor of Chihuahua from 2010 to 2016 by awarding contracts to contractors that would 

supposedly divert the government’s payments to Mr. Duarte. Pet. at 1-2. According to the 

Petition, all this happened in Chihuahua. Id. at 1-6. 

In addition to naming Mr. Duarte (a non-resident of Texas) as a defendant, Chihuahua 

named several other entities and individuals as defendants—mainly, members of Mr. Duarte’s 

family and one of their companies: Ms. Gomez (a non-resident of Texas), who is his spouse; 

Olga Sofia Duarte-Gomez, who is one of his two daughters; Cesar Adrian Duarte-Gomez, who is 

his son; Olga Duarte-Jaquez, who is his sister; CAD Construction, Inc., which is a company that 

belongs to Olga and Cesar Adrian Duarte, his daughter and son; and Gabriela ArmendarizChaparro, who is his sister-in-law. Id. at 2-4. The Petition alleges that some of Mr. Duarte’s 

relatives (but not Mr. Duarte) purchased properties in Texas with the funds that Mr. Duarte 

purportedly stole from Chihuahua. Id. The Petition fails to provide a single fact indicating where 

and how Mr. Duarte’s family received any funds from Mr. Duarte, however, or why the funds 

App. 045

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 46 of 51
-3- 

that Mr. Duarte’s family used to purchase properties in Texas have any connection of any kind 

with Mr. Duarte’s supposed misconduct. 

The Petition purports to plead six state law causes of action arising out of Mr. Duarte’s 

tenure as governor of Chihuahua: conversion, Theft Liability Act, constructive trust, civil 

conspiracy, joint and several liability, and Texas Penal Code 31.03(e)(7) (theft). Id. at 5-7. 

I. Chihuahua Failed to Plead Any Jurisdictional Allegations. 

“A court may assert personal jurisdiction over a nonresident defendant only if the 

requirements of both the Due Process Clause of the Fourteenth Amendment to the U.S. 

Constitution and the Texas long-arm statute are satisfied.” CSR Ltd. v. Link, 925 S.W.2d 591, 

594 (Tex. 1996). “The plaintiff has the initial burden of pleading sufficient allegations to bring 

the nonresident defendant within the provisions of the Texas long-arm statute.” Zamarron v. 

Shinko Wire Co., Ltd., 125 S.W.3d 132, 137 (Tex. App. 2003). “If the plaintiff does not plead 

jurisdictional allegations, i.e., that the defendant has committed any act in Texas,” the defendant 

can negate all bases of personal jurisdiction by presenting evidence that it is a nonresident. Id.

In its Petition, Chihuahua fails to plead any allegations that Mr. Duarte or Ms. Gomez 

reside in Texas (general jurisdiction); conduct continued and systematic business in Texas 

(general jurisdiction); or committed any tort in Texas (specific jurisdiction). As such, Chihuahua 

failed to plead any grounds for Texas courts to exercise personal jurisdiction over Defendants. 

II. Chihuahua Failed to Plead Minimum Contacts with Texas. 

A Texas court does not have jurisdiction over a nonresident defendant unless the plaintiff 

demonstrates that the nonresident defendant has purposefully established “minimum contacts” 

with Texas and the court’s exercise of jurisdiction over defendant comports with “fair play and 

substantial justice.” Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569, 575 (Tex. 2007); 

App. 046

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 47 of 51
-4- 

BMC Software Belgium, N. v. Marchand, 83 S.W.3d 789, 795 (Tex. 2002); Guardian Royal 

Exch. Assurance, Ltd. v. English China Clays, P.L.C., 815 S.W.2d 223, 226 (Tex. 1991). To 

establish minimum contacts, a plaintiff must demonstrate that the nonresident defendant availed 

itself purposefully of the privilege of conducting activities within Texas, and that the causes of 

action arise from the nonresident defendant’s contacts with Texas. See Moki Mac, 221 S.W.3d at 

575-76; Commonwealth Gen. Corp. v. York, 177 S.W.3d 923, 925 (Tex. 2005); BMC Software, 

83 S.W.3d at 795-96. 

The Petition is devoid of allegations that Mr. Duarte or Ms. Gomez purposefully availed 

themselves of the privilege of conducting activities in Texas or that the causes of action against 

them arise from any supposed connections between them and Texas. Therefore, the Court has no 

personal jurisdiction over Mr. Duarte or Ms. Gomez. 

CONCLUSION AND PRAYER

For these reasons, there are no grounds for a Texas court to exercise personal jurisdiction 

over defendants. Defendants have no minimum contacts with this State to justify a Texas court’s 

assumption of personal jurisdiction over them. This action continuing against them would offend 

traditional notions of fair play and substantial justice. Defendants respectfully ask the Court to 

sustain their special appearance and enter a final judgment dismissing the Petition. 

App. 047

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 48 of 51
-5- 

Dated: March 30, 2020 Respectfully submitted, 

/s/ R. Paul Yetter 

R. Paul Yetter 

State Bar No. 22154200 

Bryce L. Callahan 

State Bar No. 24055248 

YETTER COLEMAN LLP 

811 Main Street, Suite 4100 

Houston, Texas 77002 

(713) 632-8000 

(713) 632-8003 (Fax) 

ATTORNEYS FOR DEFENDANTS

CERTIFICATE OF SERVICE

I certify that a true and correct copy of this pleading was served via the Court’s e-filing 

service and/or by email on all counsel of record, on the 30th day of March 2020. 

/s/ Bryce L. Callahan 

Bryce L. Callahan

App. 048

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 49 of 51
No. 2020DCV0628 

FREE AND SOVEREIGN STATE OF 

CHIHUAHUA, 

Plaintiff, 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§

§

§

§

§

§

§

§ 

§ 

§ 

IN THE DISTRICT COURT OF 

v. 

CESAR HORACIO DUARTE JAQUEZ, 

BERTHA OLGA GOMEZ FONG, 

OLGA SOFIA DUARTE GOMEZ, 

OLGA DUARTE JAQUEZ, 

CESAR ADRIAN DUARTE, 

CAD CONSTRUCTION, INC., 

GABRIELA ARMENDARIZ CHAPARRO, 

MANUEL ALBERTO GARZA, 

44 FOUNTAIN RD., LLC, and 

110 S. FESTIVAL, LLC, 

 

EL PASO COUNTY, TEXAS 

Defendants. 448TH JUDICIAL DISTRICT 

ORIGINAL ANSWER SUBJECT TO SPECIAL APPEARANCE 

Subject to the previously filed Special Appearance, defendants Cesar Horacio DuarteJaquez, Bertha Olga Gomez-Fong, Olga Sofia Duarte-Gomez, Olga Duarte-Jaquez, Cesar Adrian 

Duarte-Gomez, CAD Construction, Inc., and Gabriela Armendariz-Chaparro (collectively, 

“Defendants”), through their counsel, file this Original Answer Subject to Special Appearance 

(“Answer”) to the Original Petition (“Petition”) of the Free and Sovereign State of Chihuahua 

(“Chihuahua” or “Plaintiff”). 

GENERAL DENIAL

Pursuant to Tex. R. Civ. P. 92, Defendants deny each and every, all and singular, of the 

allegations in the Petition and respectfully request that the Court require Chihuahua to prove its 

charges and allegations by a preponderance of the evidence, as required by the Constitution and 

laws of the State of Texas. Defendants respectfully reserve their right to amend this Answer after 

Filed 3/30/2020 8:41 AM

2020DCV0628

Norma Favela Barceleau

El Paso County - 448th District Court

District Clerk

El Paso County

App. 049

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 50 of 51
-2- 

they have the opportunity to more closely investigate these claims, as is their right and privilege 

under the Texas Rules of Civil Procedure and the laws of the State of Texas. 

PRAYER

Therefore, Defendants respectfully pray that the Court render judgment that Plaintiff 

takes nothing in this suit, that Defendants be awarded their costs, and for all other and further 

relief, general or special, at law or in equity, to which they are entitled. 

Dated: March 30, 2020 Respectfully submitted, 

/s/ R. Paul Yetter 

R. Paul Yetter 

State Bar No. 22154200 

Bryce L. Callahan 

State Bar No. 24055248 

YETTER COLEMAN LLP 

811 Main Street, Suite 4100 

Houston, Texas 77002 

(713) 632-8000 

(713) 632-8003 (Fax) 

ATTORNEYS FOR DEFENDANTS

CERTIFICATE OF SERVICE

I certify that a true and correct copy of this pleading was served via the Court’s e-filing 

service and/or by email on all counsel of record, on the 30th day of March 2020. 

/s/ Bryce L. Callahan 

Bryce L. Callahan

App. 050

Case 3:20-cv-00086-DCG Document 1-2 Filed 03/30/20 Page 51 of 51