The Editor: The Editor will provide you with a paragraph by paragraph response to the

complaint that was filed in the 131

st
district court in Bexar County (San Antonio) Texas.
The response is in blue.

Cause No. 2014-CI-11299

ELIA MENDOZA and ROSA ROSALES IN THE DISTRICT COURT
Individually and as members of the League
of United Latin American Citizens (LULAC)

v.

EDUARDO LAGUERRE, MAGDALENA 131
ST
Judicial District
RIVERA, RALINA CORDONA, ENRIQUE
DOVALINA, BALDOMAR GARZA, RAY
MANCERA and other un-named Defendants
Jointly and Severable

Defendants, BEXAR COUNTY, TEAXS

ORIGINAL COMPLAINT
1. Plaintiff Elia Mendoza is an individual who resides at 606 Glen Crest, San
Antonio, Bexar County, Texas 78229. Plaintiff Elia Mendoza is a member in good
standing and the State Director of LULAC a Texas Corporation with its principal place
of business in Texas and in the (District of Columbia)Washington D.C.. LULAC was
founded in 1929 in Texas and first incorporated in Texas in 1931.
2. Plaintiff Rosa Rosales is an individual who resides at 107 Janes Rae, San
Antonio, Bexar County, Texas 78201. Plaintiff Rosa Rosales is a member in good
standing and former national President of LULAC a Texas Corporation
3. Defendant Eduardo LaGuerra is an individual who reside at 46 Argy1e, Yompers,
N Y 1070 I. Defendant Eduardo LaGuerre may be noticed and served with process at the
same address.
4. Defendant Magdalena Rivera is an individual who resides at 555 Dartmoor Drive,

Crystal Lake, IL 60014. Defendant Magdalena Rivera may be noticed and served with
process at the same address.
5. Defendant Ralina Cardona is an individual who resides at 286 Alexander
Avenue, Mott Haven, NY 10454. Defendant Ralina Cardona may be noticed and served
with process at the same address.
6. Defendant Ricardo Dovalina is an individual who resides at 72290 Ashburn,
Houston, TX 77061. Defendant Ricardo Dovalina may be noticed and served with
process at the same address.
7. Defendant Baldomar Garza is an individual who resides in Houston, TX.
Defendant Baldomar Garza may be noticed and served with process at P.O. Box 88248,
Houston, TX 77288.
8. Defendant Ray Mancera is an individual who resides at 1644 Lomaland suite
105, El Paso, TX 79935. Defendant Ray Mancera may be noticed and served with
process at the same address.
Jurisdiction and venue
9. This Complaint involves claims against all the Defendants for committing law
fraud, tortuous interference, declaratory judgment and civil conspiracy. This Court has
jurisdiction over the parties as the Plaintiffs are residents of Bexar County Texas and at
least three of the Defendants are residents of Texas. This suit is brought for the
protection of LULAC a Texas Corporation and the Plaintiffs as individual members.
10. Venue of this action in this Court and district is proper in this district pursuant to
because some or all of the tortuous acts and fraud have been directed at LULAC, a
Texas corporation and its members. Thus, this Court has jurisdiction over the

Defendants.
Factual Background

11. The League of United Latin American Citizens or LULAC is the largest and
oldest Latino membership based organization in the United States. LULAC was founded
in Texas in 1929 and incorporated in the State of Texas in 1931.
12. Pursuant to its Constitution, By-laws and Protocol, LULAC is bound to hold an
annual convention with the responsibility among other to hold elections for national
officers.
13. As individual members of Texas LULAC and members of the LULAC national
board the Plaintiffs were voting delegates to the national convention in New York City,
New York on July12, 2014.
14. The individual Defendants herein, without authority from LULAC, individually
and together conspired with others to interfere with the LULAC national elections at the
LULAC National Convention held on July 12, 2014 in New York City, New York.
Editors Response: Vera sees two strangers in the corner and accuses them of being
engaged in a conspiracy. People who think like Vera are delusional paranoids.
Psychiatrists and Psychologists have treatment programs for people like that.
Their thinking when they are in positions of authority can bring harm to others.

15. Prior to the LULAC national elections of July 12, 2014, the individual
Defendants conspired together and with others and filed suit in the Supreme Court of the
State of New York, Bronx County, requesting a temporary restraining order (the "TRO")
and other relief that interfered with the national election of officers as mandated by the
LULAC Constitution, By-laws and Protocol. The sole purpose of the suit and TRO was

for the Defendants to usurp the national assembly and voting at the convention to allow
them to elect candidates of their choice and assume control of LULAC.
Editors Response: Vera does not know how the TRO was put together or who put
the TRO together. A person sneezing, according to Vera would be interfering with
the national convention. Rule 12 and 21 are not rules mandated by the LULAC
Constitution, By-laws and Protocol. Rule 12 and Rule 21 are extra legislative rules
concocted by the Rule Committee at Vera and Escobars directive. They were
created to keep the National Assembly of LULAC from getting a division of the
house after Vera, as Election Judge, had called the outcome of a stand up
assessment of who had voted for whom. The tradition in LULAC is to rely on
Roberts Rules of Order to have a vote count of who voted for whom. The Machine
took that provision in Roberts Rules by creating Rule 12. Challenges on a Vera
election call now had to go to Escobar, the Legal Advisor, who would simply say
Veras call was right and the challenger would now need 2/3rds of the delegates to
get a head count. Rul21 was another concocted rule to punish any challenger with
anything in the convention with mandatory expulsion from the League. Rule 12
and 21 are makeup rules not covered in the provisions of the LULAC Constitution.

The real purpose was to stop Luis Vera and Manuel Escobar from usurping the
Constitution right that the National Assembly has in holding elections and electing
its national officers by creating rules that denies them the right to an unfretted
count of the vote and whistle blower protection when any of the delegates
challenges the powers that be in LULAC.

16. The Defendants specifically requested and obtained an ex parte Temporary
Restraining Order late on the afternoon of Friday July 11, 2014, and delivered a copy of
the TRO to LULAC, its National President Margaret Moran and National Legal Advisor
Manuel G. Escobar, Jr. on Saturday, July 12, 2014 at approximately 11:15 am, as the
preliminary procedures for elections was ongoing. The Defendants purposely,
knowingly, negligently, and wantonly did this knowing they would interfere with the
LULAC national elections. (Ex. 1)
Editors Response: The only thing that the TRO interfered with was Vera,
Escobar, Moran and Rosales plans to steal the elections by using Rule 12 1nd 21 to
prevent a vote count and to go after any challengers to their rule.

17. Prior to their unauthorized and tortuous actions, the Defendants were in a

campaign to take control of LULAC, its National Board of Directors and National
Executive Committee by running a slate of candidates for national office, including a
candidate for national president.
Editors Response: Luis Vera, Manuel Escobar, Margaret Moran and Rosa
Rosales were in a campaign to maintain control of LULAC, its National Board of
Directors and national Executive Committee by running Roger Rocha and their
slate of candidates. That is normal in LULAC. There is nothing sinister in that.

18. Each individual Defendant acted individually and jointly in actions contrary to
the LULAC Constitution, By-laws and protocol.
Editors Response: Defendants did everything that they could do to protect the
interests of the National Assembly.

19. Prior to their unauthorized and unlawful action on Saturday, July 12, 2014 the
Defendants sought intervention of the New York state courts to interfere with the
LULAC national elections asking the State court to prohibit the LULAC's national
president and national legal advisor from conducting their duties as outlined in the
LULAC Constitution, By-laws and Protocol. The order prepared by the Defendants and
issued by the state court states;
"ORDERED, that the said Defendants LULAC, President Margaret Moran and
LULAC Legal Advisor, Manuel Escobar, be and each of them hereby is directed to
temporarily cease from taking any further actions with relation to Rules 12 and 21, and
they and each of them hereby is enjoined from in any way acting as president or Legal
Advisor of LULAC pertaining to said rules, elections, or credentialing under said
Convention Rules pending a [hearing] of this action."

Editors Response: The TRO issued by the New York State court neither
unauthorized nor unlawful. Seeking refuge from a disaster is not interfering with
an act of God. Seeking protection from the rape and pillage that Vera, Moran,
Escobar and Rosales were about to unleash on the National Assembly was a
defensive act. But for the TRO, Roger Rocha would have been declared the winner
by Vera and the Machine. The New York TRO did nothing to impede the
continuation of the election. What it impeded was the Machines plans to win the
election by Veras call that Rocha had won while not requiring the courting of the

number who of delegates who voted for each candidate and punishing any LULAC
whistle blower by expelling them from LULAC.
20. The court order obtained by the Defendants forced the national election to be
cancelled as no one in LULAC, including the national president or its legal advisor
could perform and conduct a fair or impartial election as outlined in the LULAC
Constitution, By-laws and Protocol.
Editors Response: The purpose of the court order was to conduct a fair and
impartial election, to keep Margaret Moran and Manuel Escobar from winning for
Roger Rocha and their slate of candidate by cheating.

21. The court also directed LULAC, its National President Margaret Moran, and
National Legal Advisor Manuel G. Escobar, Jr. to appear at a hearing in the Supreme
Court of the State of New York, County of Bronx on July 21, 2014 to determine why the
court should not grant the following relief if LULAC violated the TRO: (That hearing
has now been postponed. In reality it is a moot issue).
"1. Temporarily restraining Defendants LULAC, President Margaret Moran and
Legal Advisor Manuel Escobar from taking further actions with relation to Rules 12
and 21, which unilaterally usurp the powers of the LULAC National Assembly in
violation of LULAC's By-Laws and Constitution.

2. Judgment against Margaret Moran and Manuel Escobar in the amount of
$4,500,000.00 on behalf of LULAC for the loss, waste and damage resulting
from the breach of duty and negligence.

3. For the costs and disbursements of this action and for such other relief as the
court deems proper."

Editors Response: The hearing has not been cancelled. It has just been re-set for
another day at the request of Vera, Moran and Escobar. There is nothing moot
about that.

22. The duly appointed election judge at the LULAC National Convention, after
conferring with New York counsel, had no choice but to cancel the elections so as not to
violate the court's temporary restraining order and risk judgment against LULAC for

$4,500,000.00.
Editors Response: Luis Vera, the Election Judge, had another choice, continue the
election and see his Machine candidates voted down by the Maggie Rivera
delegates.

23. The Defendants after accomplishing their goal of interfering with the national
elections and the election was cancelled, began to hold and conducted their own
convention and elections, and elected what they claim to be the new LULAC National
officers. At that time the vast majority of the delegates had left the convention hall. The
LULAC national president and other were conferring with LULAC New York counsel
and LULAC counsel at this time.
Editors Response: Luis Vera is lying to the court in alleging that a vast majority
of the delegates had left the assembly floor. Delegates who supported Roger Rocha
left the assembly floor. They represented a minority of the delegates. 1,625
delegates were present and counted just at about 11:33 Am when Vera told the
National Assembly that he was going to recess until 2:00 PM. 825 delegates
remained on the floor to continue the convention. That is a majority by anybodys
math.

24. Defendant Magdalena Rivera had herself elected LULAC National President.
Editors Response: 820 delegates voted to elect Maggie Rivera as ht next National
president of LULAC.

25. Defendant Ralina Cardona had herself re-elected LULAC National Vice
President for the North East. Others involved in this civil conspiracy also had themselves
elected to a LULAC national office or aided the conspiracy in doing so.
Editors Response: 825 delegates voted to elect Ralina Cardona and the other
candidates who were running on Maggie Riveras slate.

26. Defendants Enrique "Rick" Dovalina and Baldomero Garza acted as legal
advisors to the other Defendants, and assisted or knew of the conspiracy to interfere with
the LULAC national elections prior to the elections. Each of these Defendants also

assisted and participated in the unlawful election. Defendant Baldomar Garza
accompanied Defendant Eduardo LaGuerre, who filed the suit in the Bronx, New York
to deliver a copy of the TRO o LULAC, President Margaret Moran and National Legal
Advisor Manuel G. Escobar.
Editors Response: 825 delegates voted to elect Maggie Rivera as ht next National
president of LULAC, including the defendants noted above, conspired to continue
the legal meeting of the National Assembly of LULAC. The Constitution of
LULAC requires a 1/3 of the registered delegates to maintain a quorum in a
LULAC convention of the national Assembly. 1,625 registered delegates on the
assembly floor multiplied by .33333% equals 542 needed to maintain a quorum.
825 delegates, who remained, constitute more than the 542 quorum minimum.

27. Defendant Ray Mancera acted as parliamentarian for the unlawful election, and
assisted or knew of the conspiracy to interfere with the LULAC national elections prior
to the election.
Editors Response: Ray Mancera acted as parliamentarian of a lawfully constituted
election. The conspiracy to interfere with the convention of the National Assembly
was a conspiracy of Vera, Escobar, Moran and Rosales.

28. Since 1929, LULAC has spent an enormous amount of resources developing and
marketing LULAC and the League of United Latin American Citizens. The public has
come to recognize the distinctive LULAC name and LULAC Marks, and associates the
name and marks with the Plaintiff herein. As a result, LULAC has developed a
significant amount of goodwill in association with the use of the LULAC Marks, and has
established an excellent reputation regarding the quality of its advocacy in issues
important to the Latino community. The LULAC National Board of Directors has
developed a reputation of competence and credibility in the corporate, political, judicial
and advocacy communities throughout the United States of America. LULACs
reputation is known throughout the United States and Puerto Rico, and it is known for its

advocacy in education, immigration, worker rights, civil rights, and other issues
important to the Latino and minority communities. LULAC asserts its advocacy by
various means including litigation.
Editors Response: The LULACs reputation that developed under the leadership
of Rosales and Margaret Moran has been one of ruthlessness, cheating, theft of
LULAC resources, taking hundreds of thousands of dollars under the table, all to
advance their goals and not the goals of LULAC.

29. The individual Defendants, without authorization from LULAC, have begun to
disrupt the ongoing functions of the national organization and demanding control of
LULAC. The Defendants attempt to circumvent the LULAC Constitution, By-laws and
Protocol, together with the duties and responsibilities of the constitutionally elected
LULAC National President Margaret Moran and National Legal Advisor Manuel G.
Escobar, Jr. and the decisions of the LULAC National Board of Directors are causing
irreparable harm to LULAC, its members including the individual member Plaintiffs
herein.
Editors Response: Demanding control of LULAC is an electoral process. Not
wanting to share in that process are the doings of Vera, Escobar, Moran and
Rosales. They think that they own LULAC, that anybody who challenges their
illegal electoral acquisition of the seat of LULAC authority is doing something
wrong. The Machine operatives in LULAC have forgotten what the LULAC
electoral process is all about. They have it in their small dictatorial mind that when
they run an election, the only possible outcome is for them to come out the winners.
It is Luis Vera, Margaret Moran, Manuel Escobar and Rosa Rosales who are
causing irreparable harm to LULAC and its members. The damage is the
thousands of dollars that each delegate spend to travel to New York City to attend a
convention that Luis Vera on his own, without the consent of the National
Assembly decided to cancel that has led to this total chaos. The value of harm
could number in the millions of dollars, for which there will now have to be an
accounting for.

30. Immediately after their unlawful election the Defendants and others who
conspired with them began announcing the election of new LULAC national officers by

means of electronic mail to the LULAC membership, its corporate partners and the
world in general through an internet blog, the Voice of the Mainland and other social
media such as Facebook. The Defendants also issued press statements. The defendants
supporters have given live radio interviews to announce their takeover of LULAC.
Editors Response: There was no announcement by anybody on the Maggie Rivera
side that there had been a takeover of LULAC. Any announcements being
communicated just relayed the facts to the public that Maggie Rivera and her slate
of candidates had won the elections for national offices in LULAC.

Tortuous Interference With National Elections
31. The allegations set forth in paragraphs 1 through 30 are incorporated by reference
as if fully set forth herein.
32. Plaintiff will show that Defendants had knowledge that the LULAC national
elections were to take place on Saturday, July 12, 2012. Further, LULAC will show that
Defendants knew of the presence of the National President Margaret Moran, National
Legal Advisor Manuel G. Escobar, Jr. and other LULAC National Board members at the
LULAC convention site in New York City during all times pertinent thereto. Despite
such knowledge, Defendants did not inform such individuals of their intent to secure the
temporary restraining order which disrupted the LULAC national elections.
Editors Response: There was no announcement by anybody on the Maggie Rivera
side that there had been a takeover of LULAC. Any announcements being
communicated just relayed the facts to the public that Maggie Rivera and her slate
of candidates had won the elections for national offices in LULAC

33. In furtherance of their scheme and plot, Defendants secured the temporary
restraining order at issue in these proceedings on Friday, July 11, 2014, and failed to
inform or otherwise notify the Plaintiff, or its representatives that the temporary
restraining order had been obtained or the contents of the restraining order. Instead, the

Defendants waited until the start of the elections process, and without prior notice,
provided LULAC and its representatives a copy of the restraining order at a time when
the LULAC could not challenge the temporary restraining order nor seek a clarification
of the terms and conditions of the temporary restraining order.
Editors Response: There is nothing illegal about ex-parte TROs. They are meant
to be surprises. The TRO that the Editor is commenting on , the TRO against
Eduardo LaGuerre, Maggie Rivera and others was filed in the Bexar County
courthouse on Friday at 4:09 PM and hand delivered the next day to some of the
parties at the meeting of the National Executive Committee in Washington,

34. The LULAC national elections are an integral part of the relationship between the
LULAC and its membership, including plaintiffs. Indeed, the delegates who attended the
LULAC National Convention attended with the expectation that they would cast their
vote to elect their national officers. Such is the contractual bond between LULAC and its
membership. However, due to the callous and indifferent conduct of the Defendants,
LULAC's membership was precluded from exercising the most significant right afforded
to them by the LULAC Constitution, By-laws and Protocol.
Editors Response: Defendants wanted fair and clean elections. They did not want
the elections stolen away from them by Luis Vera, Margaret Moran, Manuel
Escobar and Rosa Rosales. That was the purpose of their TRO.

35. Pleading further, Plaintiff will show that Defendants conspired by concerted
action to tortuously interfere with the LULAC national election and to effectuate a denial
of the rights afforded LULAC members to elect their national officers and which has
resulted in Plaintiffs injuries and damages.
Editors Response: Luis Vera cancelled the convention. That was his doing
exclusively.

36. Pleading further, Plaintiff will show that Defendants acted with malicious intent

for the reason that they sought to interfere with LULAC's membership's right to elect
officers of their own choice. Such conduct was carried out of spite and ill will toward
LULAC and its membership thereby causing economic injury to LULAC and its
membership.
Editors Response: Defendants wanted to prevent the elections from being stolen
from them. They asked the court to issue the TRO to restrain Margaret Moran
and Manuel Escobar from using Rule 12 and 21 to steal the election from them.

37. Plaintiffs will also ,show that unless defendants are immediately restrained from
continuing their actions that irreparable harm will be done to LULAC, its members
including the Plaintiffs herein.
Editors Response: What harm?

Jury Demand
LULAC hereby demands a trial by jury for all issues so triable and alleged in this
Complaint.
Prayer
WHEREFORE, Plaintiff, LULAC, respectfully prays that this Court enter
judgment as follows:
a. That Defendants, Eduardo LaGuerre, Magdalena Rivera, Ralina Cardona,
ENRIQUE "RICK" Dovalina, Baldomero Garza and Ray Mancera, jointly and
severable, and the LULAC officers, agents, employees, attorneys, corporations, or
companies under the control of Defendants, and all other persons in active concert
and/or participation with Defendants, be preliminarily and permanently enjoined from
engaging in the acts of officers of LULAC to which they believe they may have been
elected on July 12, 2014.

Editors Response: Several events are still left to play out.

b. That Defendants be found liable, jointly and severally, to LULAC all
damages suffered by LULAC and its members as a result of Defendants acts complained
of herein, including but not limited to actions which caused the cancellation of the
LULAC national election of officers.
Editors Response: Vera cancelled the LULAC national election of officers.
Nobody told him to cancel the convention.

c. A finding that Defendants' acts, jointly and severally, were deliberate and
willful, that this is an exceptional case and that LULAC be awarded enhanced damages,
exemplary damages, attorneys' fees, and costs of court;
Editors Response: Plaintiffs have not established damages.

d. Ordering that pending the court's decision on the issues in the complaint
that all national officers of LULAC holding office prior to July 12, 2014 remain in the
status quo as provided in Article VIII, Section 6, Paragraph b of the LULAC
constitution, By-laws and Protocol.
Editors Response: That is being complied with.

e. That Plaintiff, LULAC, be awarded all of its damages, including but not
limited to its economic damages against Defendants, jointly and severally, and that
Plaintiff be further awarded exemplary damages against the same Defendants, jointly
and severally.
Editors Response: Plaintiffs have not cited any level of economic damage.
f. That Plaintiff, LULAC, be awarded prejudgment and post-judgment
interest and for such other and further relief to which Plaintiff, LULAC and its members,

may show themselves justly entitled.
Editors Response: Plaintiffs have not established why they are owed
anything. They have failed to prove up damages. They have failed to establish a
case against Defendants. The convention was cancelled by Luis Vera. The court
order did not instruct him to cancel the convention. If there are any damages
owed, it would be Luis Vera who has the greatest exposure to the tune of three
million dollars ($3,000,000.00), give or take a few dollars.

Respectfully Submitted



________________________________
Luis Roberto Vera, Jr.
State Bar No. 20546740
The Law Offices of Luis Roberto Vera, Jr.
& Associates
1325 Riverview Towers
111 Soledad
San Antonio, Texas 78205-2260
Tel 210-225-3300
Fax 210-225-2060
lrvlaw@sbcglobal.net

ATTORNEYS FOR PLAINTIFF




















SUPPORTING AFFIDAVIT

Elia Mendoza appeared in person before me today and stated under oath: "My name
is Elia Mendoza. I am competent to make this affidavit.
"I am an individual and member and good standing in LULAC (the League of United
Latin American Citizens) I am also the Texas State LULAC Director. Texas LULAC
represents over one third of membership of LULAC. The facts stated in this complaint are
within my personal knowledge and to the best of my belief are true and correct.

______________________________________
Elia Mendoza



STATE OF TEXAS

COUNTY OF BEXAR

SIGNED under oath before me on July 12
th
, 2014, Elia Mendoza that the above
statements are true and correct.

______________________________________
Notary Public, State of Texas