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Zapata Lawsuit Against U.S. Government

Zapata Lawsuit Against U.S. Government

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Published by Houston Chronicle
lawsuit
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Published by: Houston Chronicle on Feb 13, 2013
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02/13/2013

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Plaintiffs’ Original Complaint 
Page 1
U
NITED
S
TATES
D
ISTRICT
C
OURT
 S
OUTHERN
D
ISTRICT OF
T
EXAS
 B
ROWNSVILLE
D
IVISION
 
Mary M. Zapata, Individually and as Administrator §of the Estate of Jaime J. Zapata, Amador Zapata, Jr., §and Victor Avila, Jr. §§v. §§The United States of America; Manuel Barba; §Otilio Osorio; Ranferi Osorio; Kelvin Morrison; § Civil Action No.________________Blandon Derrick Shaffer; Robert Riendfliesh; §
JJ’s Pawn Shop, Inc.; Off 
-Duty Enterprises, Inc.; §Unknown FFL Dealer; BAE Systems, Inc.; §Department of Justice; Department of Homeland §Security; Kenneth Melson; William D. Newell; §Hector Tarango; David Voth; Juan Gelista; §Jerry Miles; Anthony Salisbury; Raul Aguilar; §and John and Jane Doe(s) §
P
LAINTIFFS
 
O
RIGINAL
C
OMPLAINT
 
TO THE HONORABLE UNITED STATES DISTRICT JUDGE:NOW COME, Mary M. Zapata, Individually and as Administrator of the Estate of JaimeJ. Zapata, Amador Zapata, Jr. and Victor Avila, Jr., Plaintiffs, and complain of Defendants, TheUnited States of America; Manuel Barba; Otilio Osorio; Ranferi Osorio; Kelvin Morrison;B
landon Derrick Shaffer; Robert Riendfliesh; JJ’s Pawn Shop, Inc.; Off 
-Duty Enterprises, Inc.;Unknown FFL; BAE Systems, Inc.; Department of Justice; Department of Homeland Security;Kenneth Melson; William D. Newell; Hector Tarango; David Voth; Juan Gelista; Jerry Miles;Anthony Salisbury; Raul Aguilar; and John and/or Jane Doe(s) directly responsible for decisionsmade with regards to gunrunning operations and the John and/or Jane Doe(s) straw purchasersnot yet identified and would respectfully show the Court as follows:
Case 1:13-cv-00022 Document 1 Filed in TXSD on 02/12/13 Page 1 of 39
 
Plaintiffs’ Original Complaint 
Page 2
I.
 
P
ARTIES
 
1.
 
Plaintiff Mary M. Zapata is an individual and Administrator of the Estate of JaimeJ. Zapata, duly appointed by the State of Texas on September 14, 2011, who permanently residesin Brownsville, Cameron County, Texas.2.
 
Plaintiff Amador Zapata, Jr. is an individual who permanently resides inBrownsville, Cameron County, Texas.3.
 
Plaintiff Victor Avila, Jr. is an individual who temporarily resides in Denver,Colorado.4.
 
Defendant Manuel Barba is an individual and federal prisoner who resides inHouston, Harris County, Texas. Defendant may be served with process at Federal DetentionCenter - Houston, 1200 Texas Avenue, Houston, Texas 77002. Defendant Barba previouslyresided in Baytown, Harris County, Texas.5.
 
Defendant Otilio Osorio is an individual and federal prisoner who resides inSeagoville, Dallas County, Texas. Defendant may be served with process at Federal CorrectionalInstitution - Seagoville, 2113 North Highway 175, Seagoville, Texas 75159. Defendant Osoriopreviously resided in Lancaster, Dallas County, Texas.6.
 
Defendant Ranferi Osorio is an individual and federal prisoner who resides inTexarkana, Bowie County, Texas. Defendant may be served with process at Federal CorrectionalInstitution
 – 
Texarkana, P.O. Box 7000, Texarkana, Texas 75505.7.
 
Defendant Kelvin Morrison is an individual and federal prisoner who resides inBeaumont, Jefferson County, Texas. Defendant may be served with process at FederalCorrectional Institution
 – 
Beaumont, P.O. Box 26020, Beaumont, Texas 77720.
Case 1:13-cv-00022 Document 1 Filed in TXSD on 02/12/13 Page 2 of 39
 
Plaintiffs’ Original Complaint 
Page 3
8.
 
Defendant Blandon Derrick Shaffer is an individual who resides in Baytown,Harris County, Texas. Defendant may be served with process at his residence, 509 Lloyd Ln.,Baytown, Texas 77521-4258, or wherever he may be found.9.
 
Defendant Robert Riendfliesh is an individual who resides in Dayton, LibertyCounty, Texas. Defendant may be served with process at his residence, 111 Rosewood Dr.,Dayton, Texas 77535, or wherever he may be found.10.
 
Defendant JJ’s Pawn Shop, Inc. is a Texas corporation that is
located inBeaumont, Jefferson County, Texas. Defendant may be served with process by serving itsregistered agent, James P. Hedrick, Jr., at 5640 College Street, Beaumont, Texas 77707.11.
 
Defendant Off-Duty Enterprises, Inc. is a Delaware corporation authorized toconduct business in Texas, and doing business as Off-Duty Armory in Burleson, JohnsonCounty, Texas. Defendant may be served with process by serving its registered agent, James F.Terrill, at 501 Hilltop Place, Joshua, Texas 76058.12.
 
Defendant Unknown FFL Dealer is a fictitiously-named defendant whose trueidentity is presently unknown to Plaintiffs. Plaintiffs will amend this compliant when UnknownFFL Dealer becomes known.13.
 
Defendant BAE Systems, Inc. is a Delaware corporation authorized to conductbusiness in Texas, and doing business in Sealy, Austin County, Texas. Defendant may be servedwith process by serving its registered agent, CT Corporation, at 350 North St. Paul Street, Suite2900, Dallas, Texas 75201.14.
 
Defendant United States of America may be served with process by serving theU.S. Attorney for the Southern District of Texas, Mr. Kenneth Magidson, at 1000 Louisiana,suite 2300, Houston, Texas 77002, and by sending a copy of the summons and complaint by
Case 1:13-cv-00022 Document 1 Filed in TXSD on 02/12/13 Page 3 of 39

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