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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW MEXICO




CRYSTAL AMAYA, BRAD CATES,
BRIAN MOORE, AND KIM RONQUILLO,

Plaintiffs,

vs.

SAM BREGMAN, MICHAEL CORWIN,
J AMIE ESTRADA, ANISSA GALASSINI-
FORD, and J ASON LOERA,

Defendants.




Case No. ______________________







COMPLAINT FOR VIOLATIONS OF THE FEDERAL WIRETAP ACT, THE STORED
COMMUNICATIONS ACT AND CONSPIRACY TO VIOLATE THE FEDERAL
WIRETAP ACT
Plaintiffs Crystal Amaya, Brad Cates, Brian Moore, and Kim Ronquillo (collectively,
Plaintiffs), by and through their undersigned counsel, for their Complaint against Defendants
Sam Bregman (Defendant Bregman), Michael Corwin (Defendant Corwin), J amie Estrada
(Defendant Estrada), Anissa Galassini-Ford (Defendant Galassini-Ford), and J ason Loera
(Defendant Loera) (collectively, Defendants), allege the following upon knowledge as to
their own conduct and upon information and belief as to the conduct of others:
1. Without authorization and in blatant disregard for individual privacy and federal
law, Defendants illegally and surreptitiously hijacked, intercepted, stole, accessed, disclosed, and
used Plaintiffs private and confidential e-mail communications. Plaintiffs email
communications were, unknown to the email senders and intended recipients, diverted to an
account controlled by the Defendants so that the sender and intended recipients were unaware of
INTRODUCTION
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the hijacking. This diversion occurred contemporaneously with the transmission of the emails
and occurred for every email that was sent to an @susana2010.com email address during the
time the interception/hijacking was in placeregardless of the sender and regardless of the
content of the email.
2. After the diversion and interception of the emails to the account controlled by
Defendants, the emails were intentionally and willfully disclosed and used amongst the
Defendants, eventually resulting in public disclosure of the stolen emails. The stolen emails that
Defendants intercepted, accessed, disclosed, and used included personal and private emails.
3. Defendants engaged in this pattern of conduct in order to use the emails for their
own illegal and improper reasons, whether to score political points, to attempt to embarrass
individuals and/or simply to invade their privacy. In doing so, Defendants intentionally,
wantonly, and maliciously violated the Federal Wiretap Act (18 U.S.C. 2511) and the Stored
Communications Act (18 U.S.C. 2701). Defendants also conspired together to violate the
Federal Wiretap Act.
4. Plaintiff Crystal Amaya is a resident of New Mexico.
PARTIES
5. Plaintiff Brad Cates is a resident of New Mexico.
6. Plaintiff Brian Moore is a resident of New Mexico.
7. Plaintiff Kim Ronquillo is a resident of New Mexico.
8. Defendant Sam Bregman is a resident of Bernalillo County, New Mexico, the
Chairman of the New Mexico Democratic Party, and an attorney employed at Bregman &
Loman, P.C. Defendant Bregman established Grassroots New Mexico, a political committee that
paid fees to Defendant J ason Loera.
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9. Defendant J ason Loera is a resident of Bernalillo County, New Mexico and was a
Democratic consultant who received fees from the political committee called Grassroots New
Mexico. While executing a search warrant of Defendant Loeras home related to the criminal
investigation of the stolen emails, the FBI discovered other criminal activity and, in J une 2013,
Defendant Loera, was indicted for possession of child pornography.
10. Defendant Estrada is a resident of Bernalillo County, New Mexico. Defendant
Estrada was, for a short time in 2009, the Campaign Manager for Governor Susanna Martinez
during her run for Governor of New Mexico in the 2010 general election. Defendant Estrada
was originally indicted by the U.S. Attorneys Office for the District of New Mexico in late May
2013 for hacking the campaigns email system. That indictment was superseded in late October
2013. A second superseding indictment was filed against Defendant Estrada in May 2014. See
Second Superseding Indictment, Doc. 55, United States v. Estrada, Case No. 1:13-cr-01877-WJ
(D. N.M. filed May 21, 2014) [hereinafter, Estrada Second Superseding Indictment]. On J une
16, 2014, Defendant Estrada entered into a plea agreement. See Plea Agreement, Doc. 79,
United States v. Estrada, Case No. 1:13-cr-01877-WJ (D. N.M. filed May 16, 2014) [hereinafter,
Estrada Plea Agreement].
11. Defendant Michael Corwin is a resident of Bernalillo County, New Mexico and is
a private investigator who advertises an expertise on finding information about people, a
Democratic operative, and the Executive Director and Lead Researcher at Independent Source
PAC, a liberal political committee adverse to Governor Susana Martinez.
12. Defendant Anissa Galassini-Ford is a New Mexico resident. In 2010, for a short
period of time, Defendant Galassini-Ford served as a personal assistant to Susana Martinez
during the gubernatorial campaign. Susana Martinez terminated Defendant Gallasini-Fords
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position with the campaign and she was not hired for any position with the administration after
the election.

JURISDICTION AND VENUE
13. This Court has original jurisdiction over the Stored Communications Act claims
within this Complaint pursuant to 28 U.S.C. 1331 and 18 U.S.C. 2707.
14. This Court has original jurisdiction over the Federal Wiretap Act claims within
this Complaint pursuant to 28 U.S.C. 1331 and 18 U.S.C. 2520.
15. This Court has personal jurisdiction over the Defendants who each reside and
conduct business in this judicial district.
16. Venue is proper pursuant to 28 U.S.C. 1391(b)(1) and (2) because all of the
Defendants reside in this judicial district and, alternatively, because a substantial part of the
events or occurrences giving rise to Plaintiffs claims occurred in this judicial district.
FACTUAL ALLEGATIONS
17. In the summer of 2009, Susana Martinez began to prepare a campaign to run for
Governor of the State of New Mexico in the November 2010 election.
The Campaign and Domain
18. On or about J uly 18, 2009, through the online service known as GoDaddy.com, an
early supporter of Susana Martinez candidacy registered an internet domain at
www.susana2010.com (Website Domain). Among other things, registering an internet domain
such as www.susana2010.com allows the registrant to set up a website at that internet address
and to establish email addresses corresponding to that internet address. All of the email
addresses ended with: @susana2010.com.
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19. The Website Domain was registered for a period of two one-year terms. As such,
after the Website Domain was renewed at the end of the first term, the Website Domain was set
to expire on or about J uly 18, 2011. As a matter of policy, however, GoDaddy.com affords the
registrant of a domain a 42-day grace period, after expiration, within which to renew a domain.
Consequently, even though the Website Domain was set to expire on or about J uly 18, 2011, for
42 days after that date the owner of the Website Domain had the exclusive right of renewal.
After expiration of the 42-day grace period, the Website Domain would be publically available
for purchase. See Estrada Second Superseding Indictment at 3.
20. Administrative access to the Website Domain was controlled by means of a
username and password (credentials). These credentials were required to make any
administrative changes to the Website Domain, including but not limited to, posting content to
the website associated with the Website Domain, and creating new email accounts associated
with the Website Domain. Further, only an individual with access to the credentials would have
the ability to renew the Website Domain upon its expiration in J uly 2011. Id. at 4.
21. Shortly after the Website Domain was registered by a supporter, it was donated to
the Martinez organization for use in the upcoming November 2010 gubernatorial campaign.
The credentials to the Website Domain were provided to top campaign staff.
22. As the Martinez campaign organization grew, the Website Domain and
associated email addresses became important communication tools.
23. Plaintiffs Ronquillo and Moore were assigned and used an email address at the
Website Domain: kronquillo@susana2010.com and bmoore@susana2010.com. These email
accounts were used for various purposes, including communications between members of the
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campaign staff as well as personal communications. Plaintiffs Amaya and Cates sent emails to
individuals with a @susana2010.com email address.

Defendant Estrada Joins the Campaign and Obtains the Credentials to the Domain
24. In or about J uly 2009, Defendant Estrada joined the Martinez campaign as
campaign manager.
25. In this capacity, Defendant Estrada was provided with the credentials associated
with the Website Domain.

Defendant Estrada is Removed from the Campaign
26. After serving as campaign manager for a short while, Defendant Estrada was
removed from the campaign in or about December 2009. Id. at 8. One of the reasons for
removal may have been Defendant Estrada inappropriately accessing and reading then-candidate
Martinez emails. See Application for a Search Warrant and Affidavit in Support of an
Application Under Rule 41 For a Warrant to Search and Seize, Doc. 1, at 8, In the Matter of
the Search of: 2540 Firewheel Avenue SW, Los Lunas, NM 87031, Case 1:12-mr-00852-ACT (D.
N.M. filed Sept. 18, 2012).
27. On December 23, 2009, Defendant Estrada sent an email expressing frustration
regarding his removal: I cant understand how she wouldnt think there are political
consequences for treating me poorly and unfairly. Id.
28. In his plea agreement, Defendant Estrada admitted: I knew and understood that
my separation from the campaign ended my authority to access any and all campaign accounts,
including the GoDaddy Domain registration account and the campaign email accounts. See
Estrada Plea Agreement at 8.d.

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Problems arise with the Website Domain and the Associated @susana2010.com Email
Addresses

29. After Martinez was elected in November 2010 (hereafter, Governor Martinez),
Plaintiffs and many others continued to use the email accounts associated with the Website
Domain.
30. On or about J uly 18, 2011, however, Governor Martinez and her staff began
receiving reports that emails sent to addresses at the Website Domain were bouncing back to the
sender. It was soon determined that the emails were not being delivered as intended, because the
Website Domain had expired.
31. Members of Governor Martinez staff immediately began efforts to re-register the
Website Domain, which would allow the associated email addresses to be activated. These
efforts were unsuccessful, however, because no one on the staff could locate or recall the
credentials associated with the Website Domain.
32. In an effort to locate these credentials, on or about J uly 18, 2011, individuals
affiliated with Governor Martinez campaign called and sent text messages to Defendant Estrada
to retrieve the credentials. Defendant Estrada did not take the calls nor reply to their messages,
but instead posted a message on his Facebook page on J uly 20, 2011, that said: Beware the
snakes who stab you in the back, and then call you out of thin air, all because they apparently
want something from you. See United States Response to Defendant J amie Estradas Motion to
Compel Discovery and Set Briefing Schedule, Doc. 42, United States v. Estrada, Case 1:13-cr-
01877-WJ (filed March 24, 2014). Defendant Galassini-Ford responded to Defendant Estradas
post by writing: Lack of knowledge and disorganization on their part, does not constitute an
emergency on your part. Id.
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33. Having been unsuccessful in their attempts to re-register the Website Domain, the
Governors staff believed that it, along with the associated email addresses, had simply expired
and was no longer in use or could be used.
Defendant Estrada Renews the Website Domain and Changes the Settings for
Incoming Emails Directing them to his Personal Email Account

34. On or about J uly 29, 2011, during the 42-day grace period provided by GoDaddy,
Defendant Estrada logged onto GoDaddy.com using the credentials associated with the Website
Domain, which he had obtained as Campaign Manager for Governor Martinez 2010 campaign.
In an effort to cover the tracks of his theft and dishonesty and because of his lack of
authorization to control and administer the account, Defendant Estrada altered the associated
customer profile using the alias Sylvia Tacori, a fictitious name that he made up, with a
corresponding street address of 1644 E. Evans, Denver, Colorado 80210the location of a
Chipotle restaurant. Defendant Estrada then renewed the Website Domain under the alias
Sylvia Tacori and paid for the renewal using a pre-paid gift card that contained no identifying
customer information. See Estrada Second Superseding Indictment at 11; Estrada Plea
Agreement at 8.g. An affidavit filed in the criminal case details how the FBI linked Sylvia
Tacori to Defendant Estrada despite his efforts to hide his dishonest and fraudulent actions. See
Application for Search Warrant and Affidavit in Support of an Application Under Rule 41 For a
Warrant to Search and Seize, Doc. 1, at 19-41, In the Matter of the Search of: 2540
Firewheel Avenue SW, Los Lunas, NM 87031, Case 1:12-mr-00852-ACT (D. N.M. filed Sept.
18, 2012).
35. In his plea agreement, Defendant Estrada admitted that he renewed the Website
Domain using a false name in the event it was ever discovered that the Domain had been
renewed so that the renewal would not be traced back to [him]. See Estrada Plea Agreement at
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8.g. He further admitted that he used a pre-paid gift card to pay for the renewal of the
Domain, again so that the renewal would not be traced back to [him]. Id.
36. At the same time as he renewed the Website Domain, Defendant Estrada changed
the settings as they related to the handling of incoming email messages. While the Website
Domain was previously set to direct all incoming email messages to a mail server managed by
the Martinez campaign, Defendant Estrada changed that setting and directed all incoming email
messages sent to the associated email addresses (@susana2010.com) to a Google email account
maintained and controlled by Defendant Estrada. See Estrada Second Superseding Indictment at
12; Estrada Plea Agreement at 8.h.
37. In his plea agreement, Defendant Estrada admitted: I arranged for email
messages intended for recipients at the Domain to be routed to me. As a consequence of my
redirecting the emails, they would not bounce back to the sender informing them that they had
not reached their intended recipient. Rather, such messages would be diverted to the email
account that I controlled. See Estrada Plea Agreement at 8.h.
38. As a result of this change, hundreds of email messages intended for recipients at
their @susana2010.com account, including Plaintiffs emails, would no longer reach their
intended recipient. Rather, such messages would be contemporaneously diverted to an email
account controlled by Defendant Estrada at the time the emails were sent, and thereby
intercepted. Defendant Estrada admitted that, At all relevant times I knew and understood that I
was not a party to the communications expressed in those emails. At all relevant times I knew
and understood that no parties to those communications, senders or recipients or otherwise, knew
of or consented to my interception of those communications. Id. at 8.i.
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39. Consequently, between approximately J uly 29, 2011, and J une 15, 2012,
Defendant Estrada intentionally intercepted hundreds of stolen emails sent to the email addresses
associated with the Website Domain, including any such emails sent by or to the Plaintiffs. See
Estrada Plea Agreement at 8.j. Because the emails were intercepted by Defendant Estrada and
thus received, the senders of emails were unaware that all such emails were diverted, hijacked
and intercepted, and thus never received by the intended recipients. Nor would the intended
recipients be aware that they had been sent emails that were never received.
40. In or about mid to late J une 2012, Defendants disseminated the stolen emails to
media outlets and an email from Martinezs email account associated with the Website Domain
was published. The release of this email prompted Governor Martinez and her staff to be
concerned that the Website Domain had not in fact simply expired. See Application for a Search
Warrant and Affidavit in Support of an Application Under Rule 41 for a Warrant to Search and
Seize, Doc. 1, at 14, In the Matter of the Search of 6230 St. J osephs Ct NW, Albuquerque, NM
87120, Case 1:12-mr-01007-WDS (D. N.M. filed November 19, 2012) [hereinafter Affidavit in
Support of Search Warrant at 6230 St. J osephs Ct NW, Albuquerque, NM 87120].
41. After becoming aware that the Website Domain was still active and that emails
intended for recipients at their @susana2010.com email addresses were likely being diverted to
an unknown destination, the original creator of the account, contacted GoDaddy and informed
them that the Website Domain and associated email addresses had been hijacked. GoDaddy
investigated the situation and determined that someone had indeed fraudulently used his
credentials to re-register the Website Domain. Accordingly, on or about J une 19, 2012,
GoDaddy canceled the account associated with the Website Domain and returned it to the
original creator of the account. See Estrada Second Superseding Indictment at 14.
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Defendant Estrada Discloses Private and Confidential E-mail Messages Intended for
Plaintiffs to Defendants Loera and Galassini-Ford

42. Upon information and belief, after illegally intercepting and accessing the emails
intended for Plaintiffs, Defendant Estrada, with the assistance and/or knowledge of the other
Defendants hereto, culled through the hijacked emails and began to leak selected emails in an
attempt to injure, damage and harm Governor Martinez and senders, recipients or persons
mentioned in the private emails.
43. Defendant Estrada admitted that [t]here came a time when I made a decision to
share the emails that I had intercepted. I gave the emails to Governor Martinezs political
opponents knowing that certain emails would be disseminated to others. See Estrada Plea
Agreement at 8.l.
44. Defendants Estrada, Galassini-Ford, and Loera knew each other and
communicated on a regular basis. According to the FBI, [d]uring a review of the evidence
seized from Estradas residence, numerous text messages, chat conversations, and emails were
identified between Estrada, Ford, and J ason Loera which confirms that Ford, Estrada, and J ason
Loera, know each other and communicated on a regular basis. See Application for a Search
Warrant and Affidavit in Support of an Application for a Search Warrant, Doc. 1, 43, In the
Matter of the Search of Information Associated with Various Email Accounts that is Stored at
Premises Controlled by Google, Inc., Case 1:12-mr-00973-KBM (D. N.M. filed Nov. 7, 2012)
[hereinafter, Affidavit in Support of Search Warrant of Information Associated with Various
Email Accounts that is Stored at Premises Controlled by Google, Inc.].
45. Defendant Estrada provided Plaintiffs private and confidential emails and
hundreds of other stolen emails to Defendant Loera.
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46. Upon information and belief, multiple email accounts maintained and controlled
by Defendant Loera contained numerous emails that were intended for Plaintiffs (or sent by
Plaintiffs), during the period of time that the Website Domain and associated email addresses
were compromised by Defendant Estrada. See Affidavit in Support of Search Warrant at 6230
St. J osephs Ct NW, Albuquerque, NM 87120, at 21-28.
47. Defendants Estrada and/or Loera shared Plaintiffs private and confidential emails
and hundreds of other emails with Defendants Bregman, Corwin, Galassini-Ford and others, who
would be likely to attempt to use the stolen emails to injure, harm and damage Governor
Martinez and others.
48. Upon information and belief, an email account maintained and controlled by
Defendant Galassini-Ford (FORDANISSA@GMAIL.COM) contained emails that were intended
for Plaintiffs, during the period of time that the Website Domain and associated email addresses
were compromised by Defendant Estrada. See Affidavit in Support of Search Warrant of
Information Associated with Various Email Accounts that is Stored at Premises Controlled by
Google, Inc., at 30.].; Application for a Search Warrant and Affidavit in Support of an
Application Under Rule 41 For a Warrant to Search and Seize, Doc. 1, 24-30, In the Matter of
the Search of 5044 Woodhaven DR NE, RIO RANCHO, NM 87144, Case 1:12-mr-01008-WDS
(D. N.M. filed Nov. 19, 2012).
Defendant Loera Discloses Private and Confidential E-mail Messages Intended for
Plaintiffs to Defendants Corwin and Bregman

49. Upon information and belief, Defendant Loera, directly or by and through others,
provided stolen emails to Defendant Corwin, a political opposition researcher who runs the
Independent Source PAC (ISPAC), a liberal political committee.
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50. Upon information and belief, an email account maintained and controlled by
Defendant Corwin contained emails that were intended for Plaintiffs (or sent by Plaintiffs),
during the period of time that the Website Domain and associated email addresses were
compromised by Defendant Estrada.
51. Upon information and belief, Defendant Loera, directly or by and through others,
provided the stolen emails to Defendant Bregman.
52. Upon information and belief, an email account maintained and controlled by
Defendant Bregman contained emails that were intended for Plaintiffs (or sent by Plaintiffs),
during the period of time that the Website Domain and associated email addresses were
compromised by Defendant Estrada.
Defendants Corwin and Bregman Disclose Private and Confidential E-mail Messages
Intended for Plaintiffs to Others

53. In mid-J une 2012, Defendant Corwin published one of the intercepted emails on
ISPACs website and a Santa Fe publication disseminated a story which included the stolen
email.
54. In addition, upon information and belief, Defendant Corwin disclosed and
disseminated the private and confidential email messages of Plaintiffs to the New Mexico
Attorney Generals Office and others, including partisan political bloggers, Democratic political
operatives, reporters and the media.
55. Upon information and belief, Defendant Corwin disclosed private and
confidential emails to other unknown individuals and otherwise misused the stolen emails,
including Plaintiffs emails.
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56. Upon information and belief, Defendant Bregman disclosed the private and
confidential emails to other unknown individuals and otherwise misused the stolen emails,
including Plaintiffs emails.
57. Upon information and belief, all Defendants had knowledge of the illegal
interception of Plaintiffs emails, described above, while the interception was ongoing as a result
of Defendant Estradas actions, and/or assisted with the interception and/or cooperated with the
interception and/or conspired together to continue the ongoing unlawful email interceptions in
order to use and disclose the stolen emails.
CLAIMS FOR RELIEF
COUNT ONE: VIOLATION OF 18 U.S.C. 2511(1)(a)
THE FEDERAL WIRETAP ACT
(Against Defendant Estrada for Intentional and Contemporaneous Interception)

58. Plaintiffs incorporate Paragraphs 1 through 57 as if fully set forth at length herein.
59. At all relevant times herein, subject to specific exceptions (not applicable here),
18 U.S.C. 2511(1)(a) prohibited the intentional interception of any electronic communications
between two parties without the consent of one or both parties to that communication.
60. By engaging in the conduct described above, Defendant Estrada intentionally and
contemporaneously intercepted Plaintiffs electronic communications, without their consent,
thereby violating 18 U.S.C. 2511(1)(a).
61. Defendants Estradas actions were unlawful, willful, wanton, and malicious, and
were intended for the purpose of harming Plaintiffs.
62. Pursuant to 18 U.S.C. 2520, Plaintiffs are entitled to relief for Defendant
Estradas violations of 18 U.S.C. 2511(1)(a).
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63. By reason of the foregoing, as a result of Defendants conduct described herein,
Plaintiffs are entitled to recover the maximum statutory damages, punitive damages, and
attorneys fees and costs available under 18 U.S.C. 2520.
COUNT TWO: VIOLATION OF 18 U.S.C. 2511(1)(c) & (d)
THE FEDERAL WIRETAP ACT
(Against All Defendants for Disclosure and/or Use)

64. Plaintiffs incorporate Paragraphs 1 through 63 as if fully set forth at length herein.
65. At all relevant times herein, 18 U.S.C. 2511(1)(c) prohibited the intentional
disclosure, or endeavor to disclose, to any other person the contents of any electronic
communication, knowing or having reason to know that the information was obtained through
the interception of an electronic communication.
66. At all relevant times herein, 18 U.S.C. 2511(1)(d) prohibited the intentional use,
or endeavors to use, the contents of any wire, oral, or electronic communication, knowing or
having reason to know that the information was obtained through the interception of a wire, oral,
or electronic communication in violation of this subsection.
67. After illegally intercepting private and confidential emails intended for Plaintiffs,
Defendant Estrada intentionally disclosed and used Plaintiffs electronic communications.
68. Defendant Estrada knew, should have known, or had reason to know that the
electronic communications relating to the @susana2010.com email accounts that he disclosed
and used were obtained through the interception of electronic communications because he
himself actively arranged for and engaged in the interception of the electronic communications.
69. Defendants Loera, Bregman, Corwin, and Galassini-Ford intentionally disclosed
and/or used Plaintiffs stolen electronic communications.
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70. Based on the communications between and among the various Defendants and the
actions of the various Defendants, as described herein, and the contents of the emails,
Defendants Loera, Bregman, Corwin, and Galassini-Ford knew, should have known, or had
reason to know that any electronic communications that they received from any of the other
Defendants, or any other individual that related to the @susana2010.com email accounts, were
obtained through the wrongful and illegal interception of electronic communications.
71. By engaging in the aforesaid conduct, Defendants violated 18 U.S.C.
2511(1)(c) & (d).
72. At all relevant times, Defendants did not have authorization to use or disclose
Plaintiffs electronic communications.
73. Defendants actions were unlawful, willful, wanton, and malicious, and were
intended for the purpose of harming Plaintiffs and many others.
74. Pursuant to 18 U.S.C. 2520, Plaintiffs are entitled to relief for the Defendants
violations of 18 U.S.C. 2511(1)(c) & (d).
75. By reason of the foregoing, as a result of Defendants conduct described herein,
Plaintiffs are entitled to recover the maximum statutory damages, punitive damages, and
attorneys fees and costs available under 18 U.S.C. 2520.
COUNT THREE: CONSPIRACY TO VIOLATE 18 U.S.C. 2511
THE FEDERAL WIRETAP ACT
(Against All Defendants)

76. Plaintiffs incorporate Paragraphs 1 through 75 as if fully set forth at length herein.
77. The acts and conduct of the Defendants, as set forth herein, constitute conspiracy
under the Federal Wiretap Act.
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78. Defendants agreed, conspired, reached a common understanding, and had the
common purpose to unlawfully and without authorization intercept, access, disclose, and/or use
electronic communications intended for Plaintiffs.
79. Defendants unlawfully and without authorization intercepted, accessed, disclosed,
and/or used the electronic communications intended for Plaintiffs in furtherance of their common
plan.
80. Defendants actions were unlawful, willful, wanton, and malicious, and were
intended for the purpose of harming Plaintiffs and many others.
81. As a direct and proximate result of the actions taken pursuant to Defendants
unlawful conspiracy, Plaintiffs are entitled to recover the maximum statutory damages, punitive
damages, and attorneys fees and costs available under 18 U.S.C. 2520.
COUNT FOUR: VIOLATION OF 18 U.S.C. 2701
STORED COMMUNICATIONS ACT
(Against Defendant Estrada)

82. Plaintiffs incorporate Paragraphs 1 through 81 as if fully set forth at length herein.
83. At all relevant times, the Stored Communications Act (SCA) (18 U.S.C. 2701
et seq.) was in full force and effect and governed the accessing of facilities through which
electronic communication service is provided.
84. The SCA broadly defines an electronic communication as any transfer of
signs, signals, writing, images, sounds, data, or intelligence of any nature transmitted in whole or
in part by a wire, radio, electromagnetic, photoelectronic or photooptical system that affects
interstate or foreign commerce . . . 18 U.S.C. 2711(1); 18 U.S.C. 2510(12).
85. Pursuant to the SCA, electronic storage means any temporary storage of a wire
or electronic communication incidental to the electronic transmission thereof. 18 U.S.C.
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2711(1); 18 U.S.C. 2510(17)(A). This type of electronic storage includes communications in
intermediate electronic storage that have not yet been delivered to their recipient.
86. Congress enacted the SCA to prevent unauthorized persons deliberately gaining
access to, and sometimes tampering with, electronic or wire communications that are not
intended to be available to the public. Senate Report No. 99-541, S. REP. 99-541, 35, 1986
U.S.C.C.A.N. 3555, 3589.
87. As such, the SCA mandates that it is unlawful for a person to intentionally access
without authorization a facility through which an electronic communication service is provided,
or intentionally exceed an authorization to access that facility. 18 U.S.C. 2701(a).
88. Between approximately J uly 29, 2011, and J une 15, 2012, Defendant Estrada
violated 18 U.S.C. 2701(a) by intentionally and without Plaintiffs authorization, accessing
electronic communications intended for Plaintiffs while said electronic communications were in
electronic storage systems.
89. In addition, upon information and belief, after intercepting the electronic
communications, Defendant Estrada would periodically access those emails while in electronic
storage systems.
90. Defendant Estradas actions were unlawful, willful, wanton, and malicious, and
were intended for the purpose of harming Plaintiffs.
91. Pursuant to 18 U.S.C. 2707, Plaintiffs are entitled to relief for Defendant
Estradas violations of 18 U.S.C. 2701(a).
92. By reason of the foregoing, as result of Defendant Estradas conduct described
herein, Plaintiffs seek recovery of the maximum statutory damages, punitive damages, and
attorneys fees and costs available under 18 U.S.C. 2707.
Case 1:14-cv-00599-KBM-SMV Document 1 Filed 06/27/14 Page 18 of 20
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WHEREFORE, Plaintiffs request a trial by jury and that judgment be entered against
Defendants as follows:
1. Statutory damages as authorized under the Federal Wiretap Act and/or the Stored
Communications Act and/or pursuant to conspiracy to violate the Federal Wiretap Act, pursuant
to 18 U.S.C. 2707(c) and 18 U.S.C. 2520(c);
2. Punitive damages as authorized under the Federal Wiretap Act and/or the Stored
Communications Act and/or pursuant to conspiracy to violate the Federal Wiretap Act, pursuant
to 18 U.S.C. 2707(c) and 18 U.S.C. 2520(b);
3. Attorneys fees and costs pursuant to 18 U.S.C. 2520(b) and 18 U.S.C.
2707(b); and
4. Such further and additional relief as this Court may find to be fair and equitable.
Dated: J une 27, 2014.
Respectfully submitted

LAW OFFICE OF ANGELO J . ARTUSO


By: /s/ Angelo J. Artuso
Angelo J . Artuso
P.O. Box 51763
Albuquerque, NM 87181-1763
(505) 306-5063
NM State Bar No. 6958


Mark Braden
BAKER & HOSTETLER LLP
Washington Square, Suite 1100
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036-5304
(202) 861-1504 Office
(202) 861-1783 Facsimile

Theodore J . Kobus, III
Case 1:14-cv-00599-KBM-SMV Document 1 Filed 06/27/14 Page 19 of 20
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45 Rockefeller Plaza, 14
th
Floor
New York, NY 10111
(212) 589-4200 Office
(212) 589-4201 - Facsimile

Eric A. Packel
Circa Centre, 12
th
Floor
2929 Arch Street
Philadelphia, PA 19104-2891
(215) 564-3031 Office
(215) 566-3439 - Facsimile


Attorneys for Plaintiffs




Pursuant to D.N.M. LR 83.3, I hereby certify that co-counsel in this matter Mr. E. Mark
Braden is an attorney in good standing with the State Bar of the District of Columbia; Mr.
Theodore J . Kobus III is an attorney in good standing with the State Bar of the State of New
York, and Mr. Eric A. Packel is an attorney in good standing with the State Bar of the State of
Pennsylvania.


By: /s/ Angelo J. Artuso
Angelo J . Artuso

Case 1:14-cv-00599-KBM-SMV Document 1 Filed 06/27/14 Page 20 of 20