1. 1 MAXWELL C AGHA
BANKER’S HILL LAW FIRM APC
2 160 Thorn Street, Suite 200
San Diego, California 92103
3
Telephone (619) 230-0330
4 Facsimile (619) 230-1726
5
6 Attorney for Plaintiffs Jose Aquino and Frontera
Television Network LLP
7
8
9 UNITED STATES DISTRICT COURT
10 SOUTHERN DISTRICT OF CALIFORNIA
11 EDWARD J. SCHWARTZ U.S. COURTHOUSE
12
13 JOSE AQUINO and FRONTERA ) Case No.
TELEVISION NETWORK LLP )
14 ) COMPLAINT FOR:
Plaintiff, )
15 ) 1. BREACH OF WRITTEN
vs. ) CONTRACT;
16 ) 2. PROMISSORY ESTOPPEL, IN
) THE ALTERNATIVE;
17 Jiramos S. A. De CV; Alejandro ) 3. INTENTIONAL
Carrillo Garza Sada; GM Global S. A. ) MISREPRESENTATION;
18 de CV; Mario Ignacio Moran Jimenez; ) 4. SPECIFIC PERFORMANCE;
and Does 1 through 100, inclusive ) 5. FRAUD RICO Violations;
19 ) 6. CONCEALMENT;
) 7. BREACH OF THE COVENANT
20 Defendants. ) OF GOOD FAITH AND FAIR
) DEALING
21
(Jury Trial Demanded)
22
23 Plaintiffs, Jose Aquino and Frontera Television Network LLP, (the “Plaintiffs”),
24 by and through their undersigned attorney, for their Complaint in this action, hereby
25 alleges against Defendants’ Jiramos S. A. De CV; Alejandro Carrillo Garza Sada; GM
26 Global S. A. de CV; Mario Ignacio Moran Jimenez; and Does 1 through 100 on personal
27 knowledge as follows:
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2. 1 INTRODUCTION
2 1. This action is filed by the victims of a conspiracy to provide television
3 network to advertise in the United States for PRI campaign for the political presidential
4 candidacy of Enrique Pena Nieto. Pursuant to meeting between the parties, a contract
5 was entered between the parties for political advertising campaign for PRI candidate.
6 Defendants executed a contract to obtained funding from the Mexican government to
7 advertise in the United States for PRI campaign for the political presidential candidacy of
8 Enrique Pena Nieto. Defendants’ and each of them converted the funds for their own
9 private use. Defendants’ and each of them refused to pay for the advertising campaign
10 for PRI candidate Enrique Pena Nieto. Defendants’ and each of them concealed the fact
11 that they converted the advertising funds for their own private and personal use. The
12 defendants - Jiramos S. A. De CV; Alejandro Carrillo Garza Sada; GM Global S. A. de
13 CV; Mario Ignacio Moran Jimenez - are the perpetrators of a fraudulent conspiracy and
14 the members of a racketeering enterprise with the object of converting campaign funds
15 for their personal use, and denying plaintiffs from receiving their just benefits from the
16 written contract in the way of that objective.
17 2. Plaintiff, Jose Aquino is the owner of a television broadcasting network
18 known as Frontera Television Network LLP which is a Nevada Limited Liability
19 Partnership.
20 3. Defendant, Alejandro Carrillo Garza Sada met with Plaintiff Jose Aquino
21 in November of 2011, Mr. Jose Aquino, is the owner and President of Frontera
22 Television Network, and Jose Aquino was invited by Alejandro Carrillo Garza Sada to
23 meet Pepe Carrillo at a breakfast at the Café de la O del Conjunto Arcos, and Jose
24 Aquino was presented a project to disseminate the image and positioning of the Lic.
25 Enrique Peña Nieto, the candidate of the PRI to the Presidency of the Republic, through
26 spectacular, magazines, radio, television, Internet and social networks to be operated in
27 the United States of America, using the structure and relations of Plaintiff Jose Aquino
28 with the media in the United States, project for which Plaintiff Jose Aquino subsequently
Complaint for Damages for RICO Violations racketeering enterprise
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3. 1 design a media Plan, for an amount of us $56 million US Dollars, being agreed under the
2 terms and conditions of the parties to the transaction. Defendant, Mario Ignacio Moran
3 Jimenez met with Plaintiff Jose Aquino in November of 2011, the owner and President
4 of Frontera Television Network, and Jose Aquino was invited to meet Pepe Carrillo at a
5 breakfast at the Café de la O del Conjunto Arcos, and Jose Aquino was presented a
6 project to disseminate the image and positioning of the Lic. Enrique Peña Nieto, the
7 candidate of the PRI to the Presidency of the Republic, through spectacular, magazines,
8 radio, television, Internet and social networks to be operated in the United States of
9 America, using the structure and relations of Plaintiff Jose Aquino with the media in the
10 United States, project for which Plaintiff Jose Aquino subsequently design a media Plan,
11 for an amount of us $56 million US Dollars, being agreed under the terms and conditions
12 of the parties to the transaction. Defendant, Alejandro Carrillo Garza Sada and
13 defendant, Mario Ignacio Moran Jimenez and Gisselle sister of Defendant, Mario
14 Ignacio Moran Jimenez all were the negotiators, as a matter of fact Defendant, Mario
15 Ignacio Moran Jimenez personally never was mentioned it was at all the times his sister
16 Giselle Moran and her company defendant, GM Global S. A. and defendant, Alejandro
17 Carrillo Garza Sada did all of the negotiating with the PRI , money was funded to Banca
18 Mifel in Virreyes Alicama 5 Mexico City to the account of Jiramos S.A C.V, both
19 defendants withdrew the money and split the money with the PRI Officials and never
20 Funded the project as was promise. Defendants used Plaintiff’s American companies to
21 justify a bonafide transaction, Plaintiff Jose Quino contacted the PRI officials - David
22 Lopez, Edwing Lino, Roberto Callejas, Alfredo Carrillo, and Jose Carrillo and Plaintiff
23 was threaten by it being stated to him that the money that was originated was funded by
24 companies belonging to the ZETAS cartel from drugs and for Plaintiff Jose Aquino to be
25 very careful not to make any noise or his life is in danger.
26 ///
27 ///
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Complaint for Damages for RICO Violations racketeering enterprise
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4. 1 4. At the same time, defendant, Alejandro Carrillo Garza Sada and
2 defendant, Mario Ignacio Moran Jimenez had secretly determined that they will use
3 Plaintiff’s American companies to convert campaign funds for their personal use, and
4 denying plaintiffs from receiving their just benefits from the written contract. As part of
5 that plan, the defendants and others acting with them made numerous fraudulent
6 misrepresentations to Plaintiff Jose Aquino and concealed numerous material facts from
7 Plaintiff, Jose Aquino which helped to induce plaintiffs to entering into the written
8 contract. As a condition to make a payment of $15 million as advance payment for the
9 realization of the project, defendant, Alejandro Carrillo Garza Sada decided that on
10 January 6, 2012, that he will enter into a contract between "Intellimedia" and SISA, a
11 company dedicated to providing services to the agricultural sector, property of Mr.
12 Alejandro Ramirez Gonzalez, General Director of the Confederation of Porcicultores of
13 Mexico, who entered into a contract with defendant Alejandro Carrillo Garza Sada and
14 who assumed the responsibility to pay plaintiff Jose Aquino and his company, as well as
15 monitor the implementation of the project in the United States, turning the purchase
16 orders where specified in a manner clear and accurate, means, amounts, squares and
17 markets to cover, as well as ways to do recruitment and testing of investments (billing),
18 that was designed to enrich defendant, Alejandro Carrillo Garza Sada and defendant,
19 Mario Ignacio Moran Jimenez and others who were acting in concert with them.
20 JURISDICTION AND VENUE
21 5. The Court has subject matter jurisdiction over this action pursuant to 18
22 U.S.C. § 1964(c) and 28 U.S.C. § 1331.
23 6. This action arises under the laws of the United States, in particular, the
24 Racketeer Influenced and Corrupt Organizations Act ("RICO"), 18 U.S.C. § 1961 et seq.
25 7. The Court has supplemental jurisdiction over the state law claims for relief
26 pursuant to 28 U.S.C. § 1367(a), since these claims arise from a common nucleus of
27 operative facts and are so intertwined with the federal claims for relief as to make an
28 exercise of the Court's jurisdiction appropriate.
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5. 1 8. Venue is proper under 18 U.S.C. § 1965(a) and 28 U.S.C. § 1391(b).
2 9. Defendants are subject to the personal jurisdiction of this Court inasmuch
3 as they are located in Mexico and have purposefully availed themselves of the privileges
4 of doing business in California with regard to the actions alleged herein, and such
5 jurisdiction is reasonable.
6 10. Venue is proper in this district because 1) Plaintiff does business within the
7 Southern District of California; 2) Defendant Jiramos S. A. De CV is an organization
8 conducting business in Mexico; 3) Defendant Alejandro Carrillo Garza Sada resides in
9 Mexico; 4) Defendant GM Global S. A. de CV is an organization conducting business in
10 Mexico; 5) Defendant Mario Ignacio Moran Jimenez resides in Mexico; 6) a substantial
11 part of the acts complained of occurred in the Southern District of California and 7) the
12 contract at issue was performed in the Southern District of California (28 U.S.C. §
13 1391(b)(2)).
14 11. Contrary to numerous false representations made to plaintiff Jose Aquino
15 by defendant Alejandro Carrillo Garza Sada and defendant Mario Ignacio Moran
16 Jimenez, from the beginning of Alejandro Carrillo Garza Sada and defendant Mario
17 Ignacio Moran Jimenez involvement with Enrique Pena Nieto’s media candidacy
18 Campaign, he and his co-conspirators engaged in a scheme that had as its object the
19 conversion of campaign funds from the candidate of the PRI to the Presidency of the
20 Republic, so that defendant Alejandro Carrillo Garza Sada and his co-conspirators could
21 justify converting the campaign funds from the candidate of the PRI to the Presidency of
22 the Republic, for their own private and personal use. The conduct by the Defendants
23 that effectively destroyed the economic viability of the campaign for the candidate for
24 the PRI for the Presidency of the Republic included converting the campaign funds from
25 the candidate of the PRI to the Presidency of the Republic, for their own private and
26 personal use and stating to Plaintiff Jose Aquino that the money that was originated was
27 funded by companies belonging to the ZETAS cartel from drugs and for Plaintiff Jose
28 Aquino to be very careful not to make any noise or his life is in danger, abandoning
Complaint for Damages for RICO Violations racketeering enterprise
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6. 1 agreed-upon financial plans for the campaign for the candidate for the PRI for the
2 Presidency of the Republic, and undermining a planned recapitalization of the campaign
3 that would have added new respectful investors.
4 12. Between October 2011 and 2012, defendants continued to make numerous
5 false representations and material omissions to Plaintiff Jose Aquino as they carried out
6 their plans to convert campaign funds received by the ZETAS cartel from drug activities
7 and remove plaintiffs from standing in the way of that objective. As a result, plaintiffs'
8 have received nothing from their work, while defendants’ having allowed plaintiffs’ to
9 use their American Companies to make the campaign successful in the United States of
10 America. This dilution gave defendants’ the power to dispose of the candidate for the
11 PRI for the Presidency of the Republic and thus carry out the objective of defendants'
12 conspiracy.
13 13. Upon information and belief, in or about October 2011, Francisco Torrez
14 invited plaintiff Jose Aquino to meet PRI official Alejandro Carrillo Garza Sada, Mario
15 Ignacio Moran Jimenez, Giselle Morgan, Alfredo Carrillo, Jose Carrillo, David Lopez
16 and Roberto Calleja, all represented to plaintiff Jose Aquino to be PRI representatives
17 running Candidate EPN campaign for president of Mexico, after plaintiff Jose Aquino
18 offered a package of $15,000,000 US dollars, defendants’ decided to increase the amount
19 to $56,000,000 US dollars, after the parties agreed, within the next 5 days the parties
20 proceeded to sign all agreements. Plaintiff Jose Aquino for Frontera Television
21 Network LLP with Jiramos and Mario Ignacio Moran Jimenez for GM Global S. A. De
22 CV. Jiramos was represented by Alejandro Carrillo Garza Sada and GM Global S. A.
23 De CV was represented by Giselle Moran and her brother Mario Moran in which both
24 were contracting and signing the main contract as representatives agents between
25 Frontera Television Network LLP and PRI officials ( David Lopez, Edwin Lino, Alfredo
26 Carrillo, Jose Carrillo, Hugo, and Roberto Calleja within approximately 15 days all the
27 parties met and agreed to all of the terms and conditions and they all met at a notary
28 office and execute the written agreement, within two weeks after money was funded by
Complaint for Damages for RICO Violations racketeering enterprise
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7. 1 David Lopez and Edwin Lino to Alejandro Carrillo Garza Sada company Jiramos,
2 defendants’ informed plaintiff Jose Aquino that in order to make all of this legal that they
3 wanted to exchange the existing agreement for a new agreement, we all agreed
4 supplement the new written agreement and sign the second agreement were Jiramos was
5 not going to fund money to Frontera Television Network LLP but rather defendants’
6 asked plaintiff Jose Aquino to bring a new company known as Intellimedia LP and then
7 defendants had plaintiff Jose Aquino to sign new agreements under Intellimedia LP and
8 from their side they brought a new company call SISA The National Association of
9 Porcicultores and Agriculture. The written agreements were signed, defendants’ signed
10 the agreement as well, and promised to provide funding in the amount of $5,000,000 US
11 Dollars by April 1, 2012, notwithstanding this never happened and since then
12 defendants’ all changed their email addresses and also changed their cell phone numbers
13 and they all hiding and refuses to answer any telephone calls from plaintiff or his
14 attorney.
15 14. Upon information and belief, plaintiff believe that SISA is also a
16 government entity and plaintiff believes that SISA is well involved with the acts
17 complained of herein. Plaintiff believes that SISA was a party to the fraud because the
18 SISA had no intention to pay plaintiff for the use of his American Companies but only
19 agreed to do so in order to justify the money to be withdrawn from sponsors and from the
20 State of Mexico to pay for illegal interviews that were not allowed by IFE. Upon
21 information and belief, plaintiff believe that the IFE is also a government entity that
22 regulates campaign money.
23 15. Plaintiff sent his attorney to talk to Edwin Lino, Alfredo Carrillo, David
24 Lopez, Jose Carrillo and Roberto Calleja, and even have exchanged emails and plaintiff
25 was threaten saying this money was contributed by the Zeta Cartel and that plaintiff Jose
26 Aquino should be very careful.
27 ///
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Complaint for Damages for RICO Violations racketeering enterprise
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8. 1 16. All of the defendants thus attained their mutual goal of carrying out a
2 scheme to deprive plaintiffs’ of their labor. The defendants also attained their goal of
3 converting the campaign funds from the candidate of the PRI to the Presidency of the
4 Republic, for their own private and personal use and stating to Plaintiff Jose Aquino that
5 the money that was originated was funded by companies belonging to the ZETAS cartel
6 from drugs and for Plaintiff Jose Aquino to be very careful and not to make any noise or
7 his life is in danger, abandoning the agreed-upon financial plans for the campaign for the
8 candidate for the PRI for the Presidency of the Republic, and undermining a planned
9 recapitalization of the campaign that would have added new respectful investors.
10 17. This Complaint alleges claims against defendants under both the
11 Racketeering Influenced and Corrupt Organizations Act, 18 U.S.C. § 1961 et seq.
12 ("RICO"), and applicable state law.
13 18. Plaintiffs seek redress for their injuries, including compensatory damages,
14 which are tripled under RICO, and punitive damages in an amount no less than US $100
15 million. In addition, this action seeks a constructive trust over the campaign for the
16 candidate for the PRI for the Presidency of the Republic, and injunctive relief prohibiting
17 the contraction, for any new campaign advertising for the PRI for the Presidency of the
18 Republic.
19 THE PARTIES
20 Plaintiffs
21 19. Plaintiff Jose Aquino is an individual with his principal place of business
22 in San Diego County, and San Bernardino County California. Jose Aquino is an
23 accomplished businessman is Tele-media.
24 20. Plaintiff Frontera Television Network LLP is a Limited Liability
25 Partnership organized under the Laws of the State of Nevada with its managing partner
26 address of 711 S. Carson Street Suite 4, Carson City NV 89701. The agent for service
27 of process is Resident Agents of Nevada, Inc., located at 711 S. Carson Street Suite 4,
28 Carson City NV 89701.
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