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Editorial Comments on Complaint of Mendoza Et Al v LaGuerre

Editorial Comments on Complaint of Mendoza Et Al v LaGuerre

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Published by: Editor on Jul 21, 2014
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09/12/2014

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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.
Editor’s Resp
onse: 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

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