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EXHIBIT 1

EXHIBIT LIST
Exhibit # Description
1 Secretary of State search for GMT Promotions
2 Secretary of State search for Jesse Bruce
3 Affidavit of Sgt. Anthony Chavarria
4 Affidavit of Dep. Alejandro Luna
5 Violations Chart
6 Instagram video (alcohol, shots fired)
7 Tik Tok video (alcohol, letterman jacket)
8 Video of assault on social media
9 Tax assessor record on 5801 Fort Defiance
10 Secretary of State on Mansion Promotions LLC
11 Beati Transportation assumed name certificate
12 Indictment of Priscilla Chavez
13 Indictment of Gabriel Chavez
14 Sex Offender Public Search
15 Priscilla Chavez Bond Violation
16 Gabriel Chavez Bond Violation
17 Priscilla Chavez Bond Order 08/08/2019
18 Priscilla Chavez Bond Order 10/25/2019
19 Gabriel Chavez Bond Order 08/08/2019
20 Affidavit of Javier Jimenez, emails, motion and order
21 Priscilla Chavez felony case public record
22 Party promotion on social media
23 Instagram party promotion
24 Instagram Mansion Boys promotion
25 Instagram party promotion $20 cover
8/11/22, 11:12 AM BUSINESS ORGANIZATIONS INQUIRY

TEXAS SECRETARY of STATE


JOHN B. SCOTT

GLOBAL PERSON SEARCH


This search was performed with the following search parameter:
PERSON NAME
: GMT Promotions Ent

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https://direct.sos.state.tx.us/corp_inquiry/corp_inquiry-find.asp 1/1
EXHIBIT 2
8/11/22, 11:13 AM BUSINESS ORGANIZATIONS INQUIRY

TEXAS SECRETARY of STATE


JOHN B. SCOTT

GLOBAL PERSON SEARCH


This search was performed with the following search parameter:
PERSON NAME
: Jesse Hayward Bruce Jr

There are no records which match your inquiry. 

Return to Order
New Search

Instructions:

To view additional information pertaining to a particular filing select the number associated with the name.
To place an order for additional information about a filing select the radial button listed under 'Mark' that is
associated
with the entity and press the 'Order' button.

https://direct.sos.state.tx.us/corp_inquiry/corp_inquiry-find.asp 1/1
EXHIBIT 3
AFFIDAVIT

STATE OF TI'XAS s
$
COUNTY OF EL PASO $

Before me the undersigned authority, on this day, personally appeared Anthony


Chavarria, who being duly swom and upon oath stated:

"My name is Anthony Chavania. I am over 2l years ofage, olsound mind, capable of
making this affidavit. I have personal knowledge olthe facts stated within this document, affirm
the facts stated herein are true and correct to the best ofmy k-nowledge, and I am competent to
testify to these facts.

I am employed with thc EL Paso County Sherifls Olfice in I)l Paso County, Texas stnce
October of2Ol2.l am presently assigned to the Montana Patrol Station as a Deputy Sergeanl and
have bcen assigned as such since December of 2019. I have received training in the following
areas, including, but not limited to, Human Trafficking/Prostitution, narcotics dctection,
undercover operations, and surveillancc techniques.

Since April oI 2022, the Montana Patrol Station has responded to numerous calls for
Service out of 5081 Fort Defiance and surrounding residential areas. The residential
area is "out of the way" of most traffic and is not accustomed to heavy traffic flow. Since
the large parties began in April of this year, the increase in both foot and vehicle traffic
has reached overuhelming numbers for our small station patrol force to deal with alone.
on any given Saturday night since April, the quiet neighborhood around Fort Defiance is
flooded with easily 100 to 200 vehicles. Foot traffic is virtually uncountable as vehicles
park on both sides of the road for multiple blocks leading away from 5081 Fort Defiance.
On Saturday evenings, my patrol force of 5 to 6 people is overwhelmed by 300 to 400
juveniles and young adults. calls for service include shots fired, neighbors complaining
of unknown subjects in their yards, thefts, driveways being blocked, assaults,
aggravated assaults, intoxicated subjects in public, and sexual assaults. Not to mention
we still have the rest of the county spanning from Hueco Tanks to Horizon BLVD and
lnterstate 10 to answer calls.

on saturday June lBth I was assigned to a graveyard shift 6PM to 6AM. Before the
evening began, we all knew the home located at 5081 Fort Defiance would be hosting a
large mansion party. Despite knowing what the evening would eventually bring for us, a
briefing was held to prepare my patrol units for the night's events. on this night our
focus was to dissuade vehicles from reaching 508 1 Fort Defiance by increasing traffic
stops in the area. My hope was the people we encountered would spend their evening
in another location, or at least think twice about going to the large party. The idea wasn't
to hand out citations but try and warn people about the potential dangers they could
face if the party was the ultimate destination. Unfortunately, despite the increased
amounts of traffic stops and citizen interactions, 5081 Fort Defiance and surrounding
areas were flooded with vehicles and party-goers who obviously appeared to be
juveniles between the ages of 1 5 to 1 9.

Some of my patrol units were pulled away during the evening for other calls for service.
Two patrol units and I stayed in front of 5081 Fort Defiance for most of the night. Blocks
of residential areas were filled with vehicles. Fire hydrants, stop signs, driveways etc.
were covered or blocked by vehicles. Vehicles were even left parked in the middle of
the roadways. We attempted to get vehicles moved but waiting hours for a tow truck to
go back and forth was not feasible considering the sheer amount of illegally parked
vehicles. During the evening, I observed at least 150 to 200juveniles walking in and out
of the party. I also observed most persons carried backpacks and coolers. At that time
cu rfew was not enforceable. To those that agreed to talk with me, I learned the ages of
most party goers were 15 to 23. What worried me the most were the large amount of
extremely young females walking into the party. The males I spoke with stated that
most of the females inside the home were around the ages of 15 to 1 8. I also learned
the backpacks and coolers being carried in by party goers contained either narcotics or
alcohol, or both. Without probable cause to search a backpack or cooler, my patrol units
and I were helpless in stopping most of the coolers and backpacks from entering the
property. Getting consent from a juvenile is much harder than it seems, as juveniles
would rather laugh and record us than comply with the law or listen to reason.

My patrol units and I stayed in front of the home until 4 am. When the juveniles began
coming out of the party between the hours of 3am to 6am, the residential area fills with
intoxicated drivers, juveniles asleep or passed out on the shoulders of the roadway etc.
It ls common to see fights, crying females, lost military males needing a way back to the
barracks etc. On this evening fights were broken up due to our presence. Young
females ages 15 to 1B were walking around intoxicated in swimsuits with multiple males
following them. Bottles of alcohol littered the ground, vehicles drove off with no lights
on, and in the distance we could here a few rounds from a firearm go off, The three to
four of us that were available did our best to get everyone out safely, and as orderly as
possible.

At approximately 5 AM dispatch notified us of an unconscious female in the roadway in


front of 5081 Fort Defiance. A few seconds later, dispatch advised us that CPR was in
progress as the female was not breathing. Upon my arrival, I observed Deputy D Fierro
and Deputy M Mata with the female. I also observed two fire trucks and multiple medical
personnel around the female as they were attempting to get her to breathe. There was a
crowd of about 4 to 5 juveniles watching. I met with a female juvenile who admitted she
was 16, and the girl medics were working on was her cousin. The female was obviously
distraught and worried about her cousin. The female admitted to me her cousin was
also 16. They had arrived at the party with friends and were drinking inside. The
Female admitted no one checks for lD's even though the home staffs its own security
force. The Female stated it is easy to get alcohol inside as several bars are setup to sell
alcohol. The Female admitted she and her cousin had consumed an unknown amount
of alcohol. while this was happening, I noticed three males behind some vehicles as
well as medical personnel. I approached them and learned there was a second male
unconscious. The male was also not breathing. Medical personnel reacted quickly and
a Narcan was deployed on the male, and he began to breathe after. Narcan is also
known as naloxone hydrochloride. NARCAN is used to treat and reverse opioid
overdose. Deputies have been trained by our narcotics division that opioid overdose is a
leading cause for accidental deaths. Therefore, each deputy has been supplied with
NARCAN to use in medical emergencies such as the one we encountered. lthen
learned medical personnel were able to assist the female in breathing. lt is my firm
belief that if medical personnel did not get there when they did, those two individuals
would have surely died, on the roadway, directly in front of 5081 Fort Defiance, All this
happened with the employed security force of 5081 Fort Defiance watching from behind
their large gate which was secured with multiple padlocks.

From June lBth to present day, the madness which occurs on Saturday nights has
continued. ln fact, the promoters for the large parties have gone as far as hosting a
party on Fridays and Saturdays. This has put an immeasurable amount of stress on the
EI Paso County Sheriffs Office, the residents around 5081 Fort Defiance, and the
community. Every Friday and Saturday it is the same story. Hundreds of vehicles are
expected in the area. Several violent crimes will occur. Hundreds of lntoxicated
juveniles will fill the streets and roadways despite law enforcement attempting to
dissuade them from attending the party. lt is only after the dust settles, reports are
made, parents are called to pick up their 1S-year-old lntoxrcated daughter who is spitting
at law enforcement officers who have her in custody, or until a serious crime occurs that
light is shed on this issue. lt is my firm belief that attempting to dissuade juveniles from
potential dangers does not prevent them from attending the party. Only by eliminating
access to this large home can the dangers of "mansion parties" be a thing of the past.

SGT Anthony Chavarria 6187


El Paso County S eriff s Officc
Montan Stati n
^t
Z. €t8-z
AFFIANT

SWORN TO
A ,)-
AND SUBSCRIBED before me on this
n- ')_
the J& dav of

NOTARY d te of Texas
Comm ne es: 20-.

Juan lbarra
NOTARY PUBLIC
tD# 13186525-0
ln and lor the Slate oi Texas
I\ry commission ei ires
1-23
EXHIBIT 4
AFFIDAVIT

STATI, OF TEXAS $
$
COUNTY OF EL PASO $

Before me the undersigned authority, on this day, personally appeared Alejandro Luna.
who being duly swom and upon oath stated:

"My name is Alejandro Luna. I am over 36 years ofage, ofsound mind, capable of
making this affidavit. I have personal knowledge ofthe facts stated within this document, affirm
the facts stated herein are true and correct to the best of my knowledge, and I am competent to
testify to these facts.

I am employed with El Paso County SheriflOffice in El Paso County, Texas since


05/03/20,l0. I am presently assigned to Patrol Deputy/ East Montana Patrol Station, and have
been assigned as such since March 2019. I have received training in the following areas,
including, but not limited to narcotics detection, patrol, and surveillance techniques.

On August 06,2022 at 0108 hours while conducting area patrol in an officially marked El Paso
County Sherills Office patrol unit on the 5100 block of Bradley Rd Iocated in El Paso County,
TX, I observed a motor vehicle park with its passenger door open. It should be noted that the
residence located at 5081 Fort Defiance was having a party and a lot ofthe party goers leave
their cars parked on the side of the road. Also, a lol ofthe party goers walk back to their
vehicles highly intoxicated.

I made a u-tum to see if I observed anybody inside the open car. As I approach the vehicle I
observed a male subject lying face down on the dirt area with weeds. The male subject
appeared to not be moving. I stopped to check on the well-being ofthe male subject. As I got
offthe unit the male subject slide on the dirt to the side ofthe car. I approached the male subject
and noticed the passenger area of the car to have vomit. I also noticed the dirt area around the
male subject to be wet. I also noticed that the male subject shirt was wet and he had a dark
substance coming out ofhis mouth. As I asked the male subject if he was ok. I noticed the
male subject was highly intoxicated and was having a hard time sitting up and kept lalling back
on his back. Male subject kept trying to vomit and appeared as if he was going to choke. I
requested life ambulance to my location as I feared the male subject was not only highly
intoxicated but appeared to have taken an unknown illegal substance.

I asked the male subject for his name and he stated that his name was Luis. I asked Luis if he
was at the party located at 5081 Fort Defiance and he stated yes. I asked him if his fiiends were
inside the party and his stated yes. Through the course of my interaction with Luis, Luis was
having a hard time talking and listening to me. Luis also could not maintain his balance as we
had sat him up for his safety. Luis' mouth had a dark substance coming out of it and he kept
biting and twisting his jaw.
I asked Luis what he had consumed other than alcohol and he stated that he had taken weed.
THC. Cocaine and probably something else. When I asked him if he had consumed does drugs
inside the party, Luis was not able to give me an answer. I asked Luis if he bought does drugs
inside the party and again Luis did not answer me.

Deputy Esparza located a paper with a copy ofLuis' Texas identification card. The
identification card identified Luis as Varela, Luis Alberto. Deputy Esparza also checked ifthe
vehicle retumed to the Victim. The vehicle did return to the Victim. We checked inside the
vehicle and around the vehicle for the keys and were unable to located them. As we were not
able to locate the keys and the vehicle had several windows open and the Victim was getting
transported, I impounded the vehicle for sale keeping. At approximately O 125 hours Life
Ambulance and Montana Vista FD anived at my location and began treating the subject. While
the subject was inside the ambulance I asked him to call his friend to see if they had the keys to
his vehicle. Victim was unable to unlock his phone. At O 138 hours the Victim was transported
to Sierra Providence East Campus Hospital lbr treatment via Lile Unit 65.

At 021I hours the Victim's vehicle was impounded by AD Wrecker. At 0600 hours I was
notified by Deputy Esparza that the subject he had anested with 3 SO Criminal Warrants and
Possession ofControl substance had the kev to the Victims vehicle.

My interactions with the Victim were recorded using my department issued Axon Bodycam and
uploaded into Evidence.com with ID #202209082.

I have worked this party located at 5081 Fort Defiance several times when I'm on duty, working
the graveyard shift. I have encountered underage drinking, intoxicated j uveniles, juveniles in
possession of alcohol.

Alejandro Luna #5435


El Paso Countl' Sheriff Office
East Montana Patrol Station

SWORN TO AND SUBSCRIBED before me on this the / /A day of


A','t? ?-,oZL

NOTARY P
.7 or e State of Texas
Commis expires: ,20-.

Juan lbarra
NOTABY PUBLIC
lDn 13186525.8
ln and Jor lhe Stale ol Texas
I
EXHIBIT 5
DATE CASE NUMBER OFFENSE OFFICER DESCRIPTION DEFENDANT DOB CODE VIOLATION COUNT

Social Media Video of inside party. Shows a fight TX PENAL CODE 22.01(a)(1) 1

8/6/2022 2022-09088 Poss CS PG2>=1G<4G Dep. M. Esparza #8097 On 08/06/22 at 0344 hrs. Deputy conducted a traffic stop on a dark Toyota Corolla for no license Carrillo, Derek, Gallegos, Andy 2/9/2004 THSC Ch. 481 -- Juvenile 1
plate light. Deputy came in contact with the driver/OF#1 and other passengers OF#2, juvenile Ingram, Emilia Leanna 02/27/2005
OF#3 and IO inside the vehicle who stated they were leaving a Mansion party on Fort Defiance. 12/08/2005
After investigation, deputies located a white vape pen containing THC, marijuana, a pink vape
pod containing nicotine, and White Owl Cigarillos. The OF#1 was released on non-arrest for the
charge of Poss of CS and released on the First Change Program for POM. OF#2 and juvenile OF#3
were cited for Minor in Poss of Tobacco. IO was booked at the EPCDF for 3-Criminal Warrants
and 4-Traffic Warrants woth EPSO.

THSC Ch. 481 2


TABC 105.06 1
8/6/2022 2022-09085 Poss CS PG2<1GM Dep. E. Martinez #8661 On 08/06/22 at 0150 hrs. Deputy conducted a traffic stop on a white passenger car for a 1/17/2005 THSC Ch. 481 2
8/6/2022 2022-09082 Info/Sick Party Dep. A. Luna #5435 defective
On license
08/06/22 platehrs.
at 0108 light. Deputy
Deputy wasmade contact
patrolling thewith
5100the driver/OF
block of Fortand passengers
Defiance when IO#1,
he IO#2, TABC 11.01 or 61.01 1
observed a vehicle with an open door and observed a male subject/VI lying face down on a dirt
area with weeds. Deputy made contact with the VI who is 21 yrs of age and observed he was
highly intoxicated to the point the VI could not balance himself. Deputy observed vomit and dark
substance emitting from the VI's mouth and kept bitting twisting his jaw. Deputy asked the VI if
he was attending the party at 5081 Fort Defiance and he stated yes. The VI stated he consumed
alcohol, THC, weed, cocaine, and another unknown substance inside the party. Deputy asked the
VI if he consumed or bought the drugs inside the party and the VI did not answer. The VI was
taken local hospital for treatment.

THSC Ch. 481 3


8/5/2022 2022-09081 Poss CS PG2<1GM, POM <2oz, Minor
Dep.inG.Poss
Pinaof#3340
Alcohol On 08/05/22 at 2323 hrs. Deputy arrived to assist Sgt. J. Soria on traffic stop in which the vehicle Chavez Cano, Kevin 7/11/2003 THSC Ch. 481 -- Juvenile 3
was stopped for speeding. Sgt. Soria made contact with the driver/OF and immediately observed
TABC 106.05 1
7/31/2022 2022-08821 Robbery Dep. J. Segura #8889 On 07/31/2022 at 0230 hrs. Deputy Segura and Deputy V. Delgadillo #6742 were dispatched to TX PENAL CODE 29.02 1
Sierra Providence East Medical Center and met with VI who was in trauma room. VI stated he is
an active soldier with the US ARMY and was attending a party at 5081 Fort Defiance with other
soldiers. VI stated when he was leaving the party he was approached by two unknown OF's and
who jumped him and stole his Apple IPhone 11 and the shoes he was wearing. VI stated he lost
conscious and when he regained it he was being assisted by other indivuals. VI stated he was
taken back to Ft. Bliss and was seen by a nurse on base; however, she referred that him to a local
hospital due to his injuries. Detective M. Fernandez #3320 conducted a follow up on 08/04/22 at
1410 hrs with the VI who stated he located his cellphone at 5081 Fort Defiance after he kept
calling it numerous times and was answered by one of the security guards. VI was asked if he was
drinking at the party and he refused to answer. The VI was asked if he observed any illegal drugs
while attending the party and he did not cooperate as he also refused to answer or provide any
additional information.

7/31/2022 2022-08811 POM <2oz Dep. E. Woods #9174 While patrolling the 14100 block of Fort Defiance Deputy Woods and Deputy Valencia observed a Almeida, Alexis 4/5/2004 THSC Ch. 481 1
tan Toyota Corolla travelling with two flat rear tires. Deputies conducted a traffic stop and made
contact with the driver. Deputies detected an odor of marijuana emitting from inside of the
vehicle and observed a 30-pack of Budweiser in the back seat. Driver stated he was driving to a
party on Fort Defiance. After investigation, the OF was cited for Minor in Possesssion of alcohol.
The OF was released under the First Chance Program.

TABC 106.05 1
7/31/2022 2022-08806 POM <2oz Dep. M. Saenz #8499 While patrolling the 14100 block of Fort Defiance Deputy observed an underage male subject/OF Gaither, Madoc 3/25/2003 TABC 106.05 1
to be in possession of alcohol. Deputy made contact with the OF who is 19 yrs of age and
observed him to be in possession of a 12-pack of Twisted Tea Hard Iced Tea alcoholic beverage.
The OF stated he was going to a party at 5081 Fort Defiance. While conducting a pat down for
officer safety, the OF stated he was also in possession of marijuana in which he had in hisfront
right pocket. OF was released under the First Chance Program for POM and was issued a citation
for Minor in Possession of Alcohol.
THSC Ch. 481 -- Juvenile 1
7/30/2022 2022-08803 Parking on Roadway Dep. F. Medina #3923 At 2319 hrs. while Deputy was conducting area patrol at the 5000 block of Fort Defiance he TABC 106.05 1
observed a blue Ford Mustang to be parked on the middle of the roadway. The vehicle was
causing a hazard for other vehicles to which other drivers had to swerve onto the opposite lane
of travel to avoid a collision. When the wrecker arrived, the Deputy was approached by the
owner/OF of the vehicle who was identified by an active military ID and 22 yrs of age. The OF
stated he was attending a party at 5081 Fort Defiance. The driver was issued a citation for
violating Texas Transporation Code 545.301. The OF made arrangements with AD Wrecker to
release his vehicle.

7/30/2022 2022-08802 Poss of CS PG 1/1-B <1G, Poss of Dep. W. Lamoy #8740 At 2256 hrs. Deputy conducted traffic stop on a blue Lincoln for Unauthorized Use of Dealer Tag. Gutierrez, Joshoa 4/22/2005 THSC CH. 481 3
CS PG 2 >=1G<4G, Poss of CS PG Deputy made contact with the driver/OF#1 who is 17 yrs of age and stated he was dropping off
3 <28G, Unl Carry Weapon his friends at a party located at 5081 Fort Defiance. After investigation, OF#1 was in possession
of Xanax, Cocaine, a vape pen containing THC, and a loaded black handgun was located
underneath the driver seat. OF was booked at EPCDF for Poss of CS PG 1/1-B <1G, Poss of CS PG
2 >=1G<4G, Poss of CS PG 3 <28G, Unl Carry Weapon. Another juvenile/OF#2 who was a
passenger in the vehicle was listed as an active runaway with EPPD and was also found to be
possession of a vape pen containing THC. The juvenile/OF#2 was referred to EPPD. The narcotic
case for juvenile /OF#2 was referred to JPD.

THSC Ch. 481 -- Juvenile 1


7/30/2022 2022-08773 Poss of CS PG 2<1G Dep. M. Saenz #8499 At 0255 hrs. while Deputy was patrolling the 5081 block of Fort Defiance, he observed four Cano, Ryan 8/7/2006 THSC Ch. 481 -- Juvenile 2
juveniles attemtping to hide behind a trash dumpster. Deputy made contact with four juveniles
who also appeared to try and hide something. After investigation, juvenile OF#1 an juvenile OF#2
were each in possession of a vape pen containing THC. Juvenile OF#1 and juvenile OF#2 stated
they were attending a party at the residence and were waiting for the Uber to arrive and pick
them up.

7/30/2022 2022-08770 Poss CS PG 2>=1G<4G Dep. W. Lamoy #8740 At 0031 hrs. Deputy conducted a traffic stop on a silver passenger car for not having a visible Gonzalez, Mireya 9/14/2007 TABC 106.05 1
license plate light. Deputy made contact with the juvenile/OF who stated she was going to a
party at 5081 Fort Defiance. After investigation, the juvenile/OF was in possession of alcohol (1-
open bottle of Smirnoff and a case of White Claw alcoholic beverages), 2-vape pens containing 1
gram each of THC, and marijuana. OF was cited for Minor in Possession of Alcohol and released
to mother. Deputy was unable to process the juvenile/OF for narcotics due to shortage of
deputies and officer safety.
THSC Ch. 481 -- Juvenile 3
7/17/2022 2022-08178 Info / Injured Party Det. A. Blackard #4799 At 0146 hrs. while patrolling the area at approximately the 5000 Block of Fort Defiance, Detective Evidence - Firearm 1
observed a subject standing in the middle of the roadway flagging him down. Detective observed
IO who is 21 yrs of age bend over and placed something on the ground. Detective advised IO to
stand in front of his unit for officer safety. Detective observed IO walk to the driver’s side
window and stated he shot himself with his gun on his penis. Detective observed a small spot of
blood on IO's pants in the groin area. Detective and Deputy H. Delgadillo #9136 secured the
weapon because of the amount of people walking in the area. IO stated he was going to the
party located at 5081 Fort Defiance and he had his gun in his waistband of his pants. IO stated
he went to adjust his pants and when he grabbed his waistband his gun went off and shot
himself in the penis. Detective asked IO why he was taking a gun into a party and he stated, “It’s
a party anything can happen.”

7/16/2022 2022-08169 Aslt Public Servant Dep. C. Ochoa #9214 At 0216 hrs . Deputy was breaking up a fight at 5081 Fort Defiance Dr and observed a female that TX PENAL CODE 22.01(a)(1) 1
was in the scuffle pushing and shoving multiple female party attenders. Deputy grabbed the
female and I took her down to the ground to stop her assault. As Deputy was attempting to
restrain her, a male attempted to grab the Deputy and pulled him away clearly interfering with
the situation. Deputy grabbed the male and put him on the ground. Deputy was assaulted by an
unknown OF and was struck on the forehead with an unknown object sustaining minor
superficial scratches to the forehead. Deputy did not consent to the assault and did not feel pain.
Deputy did not wish to file any charges.

TX PENAL CODE 22.01(b)(1) 1


7/16/2022 2022-08170 INFORMATION Dep. W. Lamoy #8740 On 07/16/2022 at 0249hrs. while conducting area patrol at the 4900 block of Fort Defiance, TX PENAL CODE 22.01(a)(1) 2
Deputy was flagged down by parents in reference to their juvenile daughters (13 and 17 years
old) inside of a party at 5081 Fort Defiance. During the investigation a physical altercation broke
out between 8-10 subjects in front of the property. While attempting to stop the physical
altercation, Deputy was struck in the face by an unknown subject. Deputy did not feel pain when
he was struck in the face.
TX PENAL CODE 22.01(b)(1) 1

7/16/2022 2022-08149 Aslt Cause Bodily Inj Dep. W. Lamoy #8740 At 0124hrs. Deputy was dispatched to 5060 Fort Defiance, located in El Paso County, Texas in TX PENAL CODE 22.01(a)(1) 1
reference to an assault call. Deputy arrived and met with VI who is 19 yrs of age and stated while
he was at a party at 5081 Fort Defiance, he was struck in the face by an Unknown OF, causing
him pain and visible injury. Deputy observed blood on the VI's face as well as dried blood on his
clothing. Deputy also observed a large gash above VI's left eye. VI stated he did not give any
person permission to cause him pain and injury by striking him in the face. VI stated he did not
wish to file criminal charges against Unknown OF for Assault Causes Bodily Injury

7/12/2022 video Minors consuming TikTok Video of juveniles "chugging" various types of hard liquor. Outside, shots fired. TABC 106.04 3

7/12/2022 video Minors consuming TikTok Video of juveniles "chugging" various types of hard liquor. TABC 106.04 5
Evidence - Firearm 1
7/10/2022 2022-07880 Agg Aslt w/Deadly Weapon Dep. R. Aguilar #9289 At 0359 Hours, Deputy M. Bustillos #6932 and Deputy R. Aguilar #9289 were dispatched to 5081 TX PENAL CODE 22.02(a)(2) 3
Fort Defiance located in El Paso County, Texas 79938 in reference to a shots fired call. Deputies
arrived at 0408 Hours and met with the Victims (3) who stated that on today’s date at
approximately 0340 Hours, they were assaulted with a deadly weapon by Unknown Offender(s)
while leaving a house party located at 5081 Fort Defiance in El Paso County, Texas 79938. After
investigation, deputies learned that an argument between subjects turned into a physcial fight.
Unknown Offender(s) took out a handgun and began to shoot mulitple times striking VI#1 in the
left calf. VI#1 was transported to local hospital for medical assistance. All Victims (3) stated they
did not wish to file any charges. Deputy observed a vehicle to have several bullet holes and was
disabled after being shot as it had unknown vehicle fluid coming out from under the engine

TABC 105.06 1
7/9/2022 2022-07867 Poss of CS PG2<1G Dep. C. Medina #6200 On 07/09/2022 at 2302 hrs, Deputy Medina was patrolling the 5000 block of Fort Defiance when Myles, Elexis Kachelle 11/26/2001 THSC CH. 481 1
he observed vehicle not equipped with two headlamps. Deputy conducted a traffic stop. Deputy
immediately detected a strong odor of marijuana emitting from inside of the vehicle. After
investigation, Deputy located a black pouch labeled Mountaintop Ext Cannabis Confections with
a THC warning located in front of a pouch in the driver’s side door panel. The OF stated she was
on her way to a party at Fort Defiance.

7/3/2022 2022-07536 Poss of CS / Poss of Drug Para. Dep. Degadillo, Hugo 9136 At 0002 hours Deputy Delgadillo was patrolling the 4900 block of Fort Defiance, in El Paso Perez, Jonathan Jesus 1/12/2002 THSC CH. 481 2
County, Texas when he observed a blue Ford Fusion making a left turn and failing to signal intent.
Deputy conducted a traffic stop and made contact with the driver / IO and passenger / OF.
Deputy detected the strong odor of burnt marijuana emitting from inside the vehicle. Deputy
asked IO when the last time was someone had smoked marijuana inside the vehicle. IO said a
group of friends had smoked inside the vehicle before going to the party. After investigation, OF
claimed full ownership of the drugs and said the marijuana was inside a small backpack he had
wrapped around his person. OF said he bought the cigars and later stuffed them with marijuana.
While checking the backpack Deputy also located a vape pen containing a brown waxy like
substance Tetrahydrocannabinol (THC).
7/2/2022 2022-07530 POM<2oz / Poss of Drug Para. Dep. M. Mata #9172 At approximately 2235 hours, Deputy D. Fierro #6745 and Deputy Mata were patrolling the 5000 Borunda, Ashley 2/13/2003 THSC Ch. 481 -- Juvenile 1
block of Fort Defiance located in El Paso County, Texas. Deputies observed a black Nissan Altima
with a defective tail lamp. Deputies conducted a traffic stop and came in contact with the driver
/ OF. Deputy Mata asked the driver for her driver’s license, and she stated he did not have one.
While speaking with the driver Deputy Mata smelled an odor of marijuana and observed open
containers of unknown alcoholic beverages on the floorboard behind the driver’s seat. Deputy
observed an open case of Michelob Ultra beer on the floorboard of the front passenger side of
the vehicle. For those reasons, Deputy Mata asked the driver and the passengers IO#1 and IO#2
to step out of the vehicle. After investigation, Deputies located a glass marijuana pipe inside the
glove box that belonged to the driver / OF. After speaking with IO #1 and IO#2, Deputies learned
that the juveniles were on their way to a party at 5081 Fort Defiance. Citations were issued to all
three juveniles for Minor in Possession/Consumption of Alcohol under citation numbers
EPSO0281871, EPSO0281872, and EPSO0281873. The POM was submitted as Non-Arrest.

TABC 106.05 2
6/26/2022 2022-07218 DWI Dep. J. Segura #8889 At approximately 0526 hours, Deputy E. Valenzuela #6920 and Deputy Segura were dispatched to Lespron, Jeshua 4/7/2004 TX PENAL CODE 49.04 1
5040 Fort Defiance., El Paso County, Texas reference motor vehicle accident. Deputy Segura
observed a Gray Hyundai Elantra parked off the roadway facing northbound on Fort Defiance
and having damage to the front left quarter panel. Deputy Segura also observed a Green Dodge
Challenger approximately 50 yards behind the Hyundai facing southbound off the road having
damage to the left driver door, rear left quarter panel, and rear left wheel. Deputies arrived and
met with the OF who stated he was leaving a party when an unknown group of individuals
started hitting his car. OF stated he attempted to leave and that’s when he collided with an
unoccupied vehicle. After further investigation, Deputy Segura believed the driver/offender was
intoxicated and did not have control of his physical and mental faculties to operate a motor
vehicle in a public place. OF provided a sample of breath which showed BrAC of 0.145 and 0.146.
OF was placed under arrest.

TABC 105.06 1
6/26/2022 2022-07216 POM<2oz / Unl Car Weapon Dep. E. Machado At 0450hrs. Deputy Machado conducted a traffic stop on a black 2015 Audi A4 at the 14100 block Silva, Johan 2/1/2002 TX PENAL CODE 46.02 1
of Fort Defiance Dr, in El Paso County, Texas. After further investigation the driver/OF of the
vehicle was discovered to be in possession of .24 ounces of Marijuana and to be unlawfully
carrying a weapon (a black 9mm Handgun). OF stated he purchased the marijuana at a party at
5081 Fort Defiance. Statement made by OF was recorded on bodycam and is labeled under this
case number at evidence.com. The OF refused to answer questions once his Miranda Warnings
were given. OF was booked at EPCDF.

THSC Ch. 481 1


TABC 105.06 1
6/19/2022 2022-06907 Injured/Sick Party Dep. M. Mata #9172 Aat 0456 hours. Deputy Mata and Deputy D. Fierro #6745 were dispatched to 5081 Fort Defiance TABC 11.01 or 61.01 2
reference an unconscious subject. Upon arrival Life Ambulance was on scene providing medical
assistance on a white male / VI#1 who is 23 yrs of age and and a white female / VI#2 who is
approximately 16 yrs of age. Deputies observed both VI#1 and VI#2 were unconscious on the
roadway in front of the property. Both male and female (who was a juvenile) were administered
NARCAN. Both VI#1 and VI#2 were transported to Sierra Providence East via Life Unit #32 for
further medical evaluation. Deputies met with IO who stated he VI#1 was attending the party
inside of the residence. Detective J. Gutierrez #5045, Detective E. Orozco #3797, and Sgt. J. Ibarra
#5099 conducted a follow investigation with VI#1 who is an active Ft. Bliss Army soldier on the
premises of Ft. Bliss along with CID Military. VI#1 who stated he was ok and was back at work.
VI#1 stated he did not know the juvenile female/VI#2. VI#1 stated to detectives that he
consumed alcohol prior to attending the party and once he arrived he also consumed alcohol
while inside of the property. VI#1 stated he did not recall taking any narcotics as he blacked out
at the party but did observe people intoxicated. VI#1 stated his medical records showed that he
was overdosed on ecstasy and meth. Detectives met with IO#2 who is also an active soldier and
stated he recalled smelling burnt marijuana while he was inside of the party. IO#2 stated there
was an entrance fee and alcohol for sale. IO#2 stated he lost some of his personal property
(phone,keys) when he went swimming and blacked out once he consumed alcohol. IO#2 also
stated he did not know the juvenile female/VI#2. Detectives then met with IO#3 who is also an
active soldier who stated he observed underage females showing their breasts as well as alcohol
sales, and entrance fees. IO#3 stated he also observed people with alcohol. IO#3 stated he did
not know the juvenile female/VI#2. Detective Gutierrez was unable to locate the juvenile
female/VI#2 for a follow up as no information was provided.
THSC Ch. 481 -- Juvenile 1
TABC 105.06 1
TABC 106.06 1
TABC 106.04 1
6/19/2022 2022-06905 DWI Dep. V. Delgadillo #6742 On 06/19/2022 at 0344 Hrs. Deputy Delgadillo was patrolling the area of Fort Defiance Rd. and Cardona, Ricardo 1/10/2002 TX PENAL CODE 49.04 1
Santa Fe Trail in El Paso County Texas 79938. Deputy observed a silver 2016 Chrysler 200 bearing
TX registration PNY9140 driving erratically.Deputy conducted a traffic stop on the silver Chrysler
which came to a stop at 4301 Flagger St. El Paso County Texas 79938. Deputy made contact with
the driver/OF. It was determined the OF had driven while intoxicated. The OF agreed to give a
sample of his breath which later yielded results B.A.C. of 0.093 and 0.087. The OF stated he was
coming from a party at 5081 Fort Defiance.
TABC 105.06 1
6/19/2022 2022-06904 Aslt Cause Bodily Inj Dep. M. Mata #9172 Aat 0258 hours, Deputy Mata was dispatched to 5081 Fort Defiance located in El Paso County, TX PENAL CODE 22.01(a)(1) 1
Texas 79938 reference assault that just occurred. Deputies met with the Victim (who is under the
age of 21) who stated on Sunday June 19th, 2022, at approximately 2330 hours. he and his
friends arrived at a party at the said location. The Victim stated that he had been drinking
alcoholic beverages while attending the party. It shall be noted that the Victim is 19 years of age.
TABC 106.03 2
6/12/2022 2022-06600 Abandoned Property Dep. A. Bueno #8450 At approximately 0930 Hours. Deputy was flagged down at Fort Defiance/Indian Wells Dr., EL
Paso County, Tx in reference to abandoned property. RP stated she was leaving her residence
when she observed the brown wallet to be in the middle of the road. RP stated she stopped and
picked up the wallet. RP furthermore stated there was a large gathering at 5081 Fort Defiance
Dr. El Paso County, Tx on 06/11/2022 at unknown hours. The Victim’s property was submitted
into evidence.
5/28/2022 2022-05957 Agg Aslt w/Deadly Weapon Dep. R. Aguilar #9289 Deputy M. Bustillos #6932 and Deputy Aguilar #9289 were dispatched to 1801 N. Oregon located had TX PENAL CODE 22.02(a)(2) 1
in El Paso, Texas, in reference to information on an aggravated assault. Deputies arrived at 1415
Hours and met with the Victim who stated that on 05/28/2022 at approximately 2200 Hours he
was shot with a handgun by an Unknown Offender(s) while attending a house party located at
5081 Fort Defiance in El Paso County, Texas. The Victim stated he wishes to file criminal charges
against the unknown Offender(s). Deputies met with IO#3 who is VI's girlfriend and stated she
and the VI began to drink alcohol as soon as they got to the party. Deputies met with IO#2 who
stated she was "faded" and recalls being told of the VI being shot.

4/17/2022 2022-000128 POM<2oz / Unl Car Weapon Sgt. N. Juarez #2070 Car driving down Fort Defiance ahd red lights on the front, a transportaion code violation. Grajeda, Angel 3/12/2004 THSC Ch. 481 4
(contable) Constable pulled himover and made contact. He dtected a strong odor of marihuana coming
from the inside of the car, and saw a plastic bin with marihana and psilocybin in plain view. They
also saw a plastic baggie with cocaine in the driver's door handle area. the passanger had THC in
his pocket. The driver also had a handgun in the glove box.

Evidence - Firearm 1
4/17/2022 2022-04121 DWI Dep. I. Moreno #8820 At 0155 hours Deputy D. Guerrero #8413 and Deputy Moreno were conducting area patrol on Erives, Lucas Adrian 5/1/1999 TX PENAL CODE 49.04 1
the 14000 block of Santa Fe Trail, in El Paso County, Texas. Deputies observed the OF driving a
silver passenger car failing to maintain a single lane and changing between lanes without
signaling intention at the 14000 block of Santa Fe Trail. Deputies conducted a traffic stop at the
4700 block of Flager St and through the course of the investigation, deputies observations and
the OFFENDER’s statement, it was determined the driver/ OF was operating a motor vehicle
while intoxicated in a public place. The OF stated he consumed alcohol at a party at 5081 Fort
Defiance.
4/16/2022 2022-04117 Man Del CS Dep. I. Moreno #8820 Deputy D. Guerrero #8413 and Deputy Moreno were conducting area patrol in the area of 4400 Lemus, Eddie 3/18/2006 THSC Ch. 481 1
Block of Flager St, El Paso, Texas when they observed a silver passenger car, traveling
northbound on Flager St, without its headlights. Deputies conducted a traffic stop on said vehicle
at the 4484 block of Flager St. Deputies observed a black backpack being tossed from the
OFFENDER’s vehicle onto the desert area. After investigation, the juvenile OFFENDER stated “it
was a backpack, containing carts”. Deputies then spoke to the OFFENDER who admitted the
backpack was his and was planning on selling it at a party located on 5081 Fort Defiance.
Deputies conducted a search of the vehicle and located 2 boxes of Alprazolam (Xanax) and 1 box
with 3 cartridges each containing 1 gram of THC. Subsequently the backpack contained 11 boxes
containing 5 cartridges of 1 gram of THC(Cake). 1 cartridge containing 1 gram of THC(Cake), 4
boxes containing 1 cartridge each of 1 gram of THC (Cali Plug), 2 boxes containing 1 cartridge
each containing 1 gram of THC (Muha Meds) and 2 more boxes of Alprazolam (Xanax).
4/15/2022 2022-04082 DWI Dep. E. Romero #8954 At approximately 2252 hours. Deputy N. Telles #8674 and Deputy Romero were conducting Reyes, Alfredo 7/31/2002 TABC 106.06 1
stationary patrol in a clearly marked El Paso County Sheriff’s Office patrol unit #1911 at the
13800 block of Santa Fe Trail, El Paso County, Texas. Deputies observed a blue Kia passenger
vehicle traveling westbound on Santa Fe Trail with their Texas Temporary Registration not
secured making the registration unreadable violating Texas Administrative Code 215.151. A
traffic stop was initiated and revealed the driver/OFFENDER showed signs of intoxication. The
OFFENDER was placed under arrest for operating a motor vehicle in a public place while
intoxicated. The OFFENDER was also wanted for an outstanding criminal warrant. While at the
Montana Patrol Station, the OFFENDER provided a sample of his breath. The results of the
Intoxilyzer Test were 0.121 BrAC on the first test and 0.124 BrAC on the second test. The
Underage OF stated he consumed alcohol at 5081 Fort Defiance on DWI questionnaire.

TABC 106.04 1
4/3/2022 2022-03517 Aslt Cause Bodily Inj Dep. M. Esparza #8097 At approximately 0036 hours. Deputy was dispatched to 5081 Fort Defiance in reference to a TX PENAL CODE 22.01(a)(1) 1
subject disturbance, and met with the Victim who stated he had been assaulted by the Offender
as he was in a fight with another male, causing him pain and discomfort while he was dancing at
the party he was attending. The Victim stated at no time did he gave the Unknown Offender
permission to assault him. The Victim stated he did not desire prosecution for the Assault.
Deputy arrived and observed several subjects exiting the property by jumping the property gate
and running towards the roadway. Deputy exited his unit to disperse the crowd in a safe manner.

4/3/2022 2022-03520 Injured/Sick Party Dep. I. Moreno #8820 At 0231 hours, while responding to a Subject Disturbing call at 5081 Fort Defiance, Deputy TABC 106.04 1
Moreno observed the VI who is 19 yrs of age to be highly intoxicated and not conscious being
escorted by "Spearforce" Security from a party which took place at 5081 Fort Defiance. The VI
was then left in front of the house with Security Officer watching over him. While being under
Security's care, the VI fell to the ground hitting his head on the concrete and causing a laceration
to his left eyebrow. Life was requested on scene. At 0232 hours Life Medics arrived and treated
the VI who was then transported to Del Sol Medical Center(10301 Gateway West Blvd) by Life
Unit #45. It should be noted that the VICTIM before being transported had gained some
consciousness. No follow up due to no risk loss of life.

3/21/2022 2022-03018 Burglary of Vehicle Dep. J. Gonzalez #6915 Deputy was flagged down at the East Montana Patrol Station by the Victim who stated on TX PENAL CODE 30.04 1
03/20/2022, he went to a house party at 5081 Fort Defiance in El Paso County, Texas. Victim
stated he arrived at the house party at approximately 0000 hours, parked his vehicle outside of
the residence, along the shoulder of the roadway. He left the party at approximately 0300 hours
and noticed his Bluetooth receiver had been stolen. Victim's wallet was also stolen. Victim met
with security that worked during the party. who said they wouldcall him f anybody turned in the
above-mentioned items.
EXHIBIT 6
EXHIBIT 7
EXHIBIT 8
EXHIBIT 9
2021 TAX STATEMENT

Certified Owner: Legal Description:


CHAVEZ RAUL III & PRISCILLA 42 HACIENDAS DEL NORTE #3 LOT 40
5081 FORT DEFIANCE DR
EL PASO, TX 79938-8530

Legal Acres: 2.4300


Account No: H010-000-0420-0400 Prop. ID. No.: 30007 Parcel Address:5081 FORT DEFIANCE DR
As of Date: 08/02/2022 Print Date: 08/02/2022
Market Value Appraised Assessed Capped Homesite Agricultural Non-Qualifying
Land Improvement Value Value Value Value Market Value Value
$39,366 $1,393,213 $1,432,579 $1,432,579 $683,816 $1,432,579 $0 $0
Taxing Assessed Exemptions Taxable Tax
Tax
Unit Value (100%) Code Amount Value Rate
COUNTY OF EL PASO $1,432,579 CAP, HOM $753,763.00 $678,816 0.4701810 $3,191.66
Amount saved by additional sales tax revenue $811.31
EL PASO COMMUNITY COLLEGE $1,432,579 CAP, HOM $748,763.00 $683,816 0.1347600 $921.51
UNIVERSITY MEDICAL CENTER $1,432,579 CAP, HOM $748,763.00 $683,816 0.2581450 $1,765.24
CLINT ISD $1,432,579 CAP, HOM $773,763.00 $658,816 1.3403000 $8,830.11
HACIENDAS DEL NORTE WTR D $1,432,579 CAP, HOM $748,763.00 $683,816 0.1969310 $1,346.65
EMERG. SERVICES DIST. #2 $1,432,579 CAP, HOM $748,763.00 $683,816 0.1000000 $683.82
Total Tax: $16,738.99
Total Tax Paid to date: $0.00
Exemptions: Total Tax Remaining: $16,738.99
CAP CAPPED HOM HOMESTEAD
AMOUNT DUE IF PAID BY:
08/31/2022 19 + up to 20% 09/30/2022 20 + up to 20% 10/31/2022 21 + up to 20% 11/30/2022 22 + up to 20% 01/02/2023 23 + up to 20% 01/31/2023 24 + up to 20%
$23,903.30 $24,104.15 $24,305.02 $24,505.88 $24,706.77 $24,907.63
FOR CHANGES IN MAILING ADDRESS/OWNERSHIP OR ISSUES CONCERNING VALUE/EXEMPTIONS OR RENDITIONS, PLEASE CONTACT THE
CENTRAL APPRAISAL DISTRICT AT 915 780-2131. PLEASE VISIT OUR WEBSITE TO PAY ONLINE AT www.elpasotexas.gov/tax-office OR PAY BY
PHONE AT (915) 212-0106
School Information:
CLINT ISD 2021 M&O .96030000 I&S .38000000 Total 1.3403000 2020 M&O 1.0547000 I&S .34000000 Total 1.3947000
~~H01000004200400.2021_.pdf~~

4.1.74
PLEASE CUT AT THE DOTTED LINE AND RETURN THIS PORTION WITH YOUR PAYMENT.
Print Date: 08/02/2022

PLEASE NOTE YOUR ACCOUNT NUMBER ON YOUR CHECK AND MAKE CHECKS PAYABLE TO:

TAX ASSESSOR-COLLECTOR
PO BOX 2992

*H01000004200400*
EL PASO, TEXAS 79999-2992
915 212-0106

H010-000-0420-0400 AMOUNT PAID:


CHAVEZ RAUL III & PRISCILLA
5081 FORT DEFIANCE DR
EL PASO, TX 79938-8530 $___________________._____

202100030007 000 0002390330 6


EXHIBIT 10
7/12/22, 12:07 PM BUSINESS ORGANIZATIONS INQUIRY - VIEW ENTITY

TEXAS SECRETARY of STATE


JOHN B. SCOTT

BUSINESS ORGANIZATIONS INQUIRY - VIEW ENTITY


Filing Number:  803407462  Entity Type:  Domestic Limited Liability Company (LLC) 
Original Date of Filing:  August 29, 2019  Entity Status:  In existence 
Formation Date:  N/A     
Tax ID:  32071795267  FEIN:   
Duration:  Perpetual     
Name:  Mansion Promotions LLC 
Address:  5081 FORT DEFIANCE DR

EL PASO, TX 79938-8530 USA 

ASSOCIATED
REGISTERED AGENT  FILING HISTORY  NAMES  MANAGEMENT  ASSUMED NAMES  ENTITIES  INITIAL ADDRESS 

Name  Address  Inactive Date 


Gabriel A Chavez  5081 Fort Defiance DR.  
EL Paso, TX 79938 USA 

Order
 
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order for additional information about a filing press the 'Order' button.
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EXHIBIT 11
EXHIBIT 12
EXHIBIT 13
EXHIBIT 14
4/14/22, 8:38 AM Gabriel Anthony Chavez - Sex Offender in El Paso, TX 79938 - TX0626818020211129

Gabriel Anthony Chavez Registered Sex


Offender
Gabriel Anthony Chavez Registration Details
Last Known Address:
5081 FORT DEFIANCE DR, , TX 79938

Gabriel Anthony Chavez - Registered Sex Offender


Criminal Record of Gabriel Anthony Chavez (/ads.html?firstName=Gabriel Anthony&lastName=Chavez&city=El Paso&state=Texas&type=offender-details1)
DOB:
1985-01-25
Race:
White
Sex:
Male
Eyes:
Brown
Height:
5 ft 3 in
Hair:
Black
Weight:
120 lbs.

Offense or Statute
Offense/Statute:
Aggravated Sexual Assault Of A Child
Disposition Date:
26 September 2002

View Gabriel Anthony Chavez's Criminal Record (/ads.html?firstName=Gabriel Anthony&lastName=Chavez&city=El Paso&state=Texas&type=OffenderD_Text)

Alias(es)
Gabriel Chavez

Gabriel Renteria

Gabriel A Chavez

Gabriel Anthony Renteria

Collected from this official state registry website or page:


https://publicsite.dps.texas.gov/SexOffenderRegistry/Search/Rapsheet?Sid=06268180
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*No representation is made that Gabriel Anthony Chavez is currently on the state's offenders registry. All names presented here were gathered at a past date.
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4/14/22, 8:38 AM Gabriel Anthony Chavez - Sex Offender in El Paso, TX 79938 - TX0626818020211129

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EXHIBIT 15
EXHIBIT 16
EXHIBIT 17
EXHIBIT 18
EXHIBIT 19
EXHIBIT 20
AFFIDAVIT

STATE OF TEXAS $
s
COUNTY OF EL PASO S

Before me the undersigned authority. on this day. personally appeared [NAME], who
being duly swom and upon oath stated:

"My name is Javier Jimenez. I am over 51 years ofage, ofsound mind, capable of
making this affidavit. I have personal knowledge ofthe facts stated within this document, affirm
the facts stated herein are true and correct to the best ofmy knowledge, and I am competent to
testiry to these facts.

I am employed with El Paso County Sheriff s Office in EI Paso County, Texas since
O2/Ol/1994. lam presently assigned to the Montana Patrol Station as a Deputy Sheriff and have
been assigned as such since 06/0111996. I have received training in the following areas,
including. but not limited to traffic enforcement. narcotic detection, criminal law enforcement.

On 0410312022 was working the Montana Area and was dispatched to 508'1 Fort
Deflance El Paso County Texas in reference to a large house party While the patrol
units and were on our way to the location S.O. Dispatch advised that there was
possibly a gun involved As we got to the area of the said location I noticed that there
were several vehicles (approximately 100) parked on the shoulders of the roadways.
also noticed that there were several people walking the streets.

As we arrived noticed that there were several people inside the fenced- in property as
well as outside the property I noticed that majority of the people appeared to be minors
/ juveniles. There were approximately 800 to 900 people at the said location to include
inside the property As we exited our units we could hear several people using profanity
toward us and began getting irate that we were there. We were advised that there was
a male that had been assaulted at the house party at the said location I had Deputy
Miguel Esparza handle that call as the rest of us attempted to calm down the_other
people and clear out the party Forthe safety ofthe First Responders I had Deputy
Esparza transport the VICTIM to 13900 Montana to be evaluated for his injuries

I had to request additional units to my location due to the ratio of people to officers The
security that was hired for the house party would not allow us to enter the property and
f we attempted to get close to the residence they would close the gate while we were
standing in front of the property I noticed that several juveniles were exiting the house
party and appeared to be intoxicated. also noticed that some of the people that were
exiting appeared to be U.S Military based on their demeanor and on comments they
made (eg are we going back to base)
advised the secunty offcers that needed to speak to the home owner Priscilla
Chavez A few minutes later Chavez came out from the property and
dentified herself with a Texas Driver's License told her that we had been here before
for issues and she stated that she remembered and made a comment that she
remembered that it was approximately two years ago. I did not slate anything
further in regards to that and allowed Chavez to speak. Chavez stated that
she had permission to have the parties at her residence Chavez stated that she had
permit that was rssued by Judge Diane Navarrete. asked Chavez rf she had a copy of
that order and she stated that she did but that t was inside the residence asked her
if she could get t and if she could also provide me with a copy of t so that we could
have it on record which she replied that she would

Chavez exited her residence a few minutes tater but stated that she was not able to
locate it at that time provided Chavez my business card with my contact lnformation
and asked her to send me a copy of the order which she agreed to do

A few days later received a phone call from her attorney's receptionist that they
would be sending me the order in a few days A few days later received an email
from Chavez attorney and the order was provided

I have been to the said residence several times in the past few years in reference to the house
parties. There have been several calls on loud music, assaults, subjects with guns, shots
fired, and injured parties. All the times that I have been dispatched to the residence I have
noticed several hundred people in the residence and walking the streets in the immediate
area. Majority of the people were.iuveniles that were causing a disturbance or were
intoxicated. The parties also have music playing which is at a very high volume which causes
a disturbance to the neighbors in the area. The parties have gone from approximately 9:00
pm to approximately 5:00 am. I have been assigned to the Montana station for several years
and have noticed that the parties are getting bigger in regards to the people. Which creates
more types of calls as assaults and shots fired etc. I believe that if the parties continue there
will be more VICTIMS of assaults and injured people, Not to mention the number of
intoxicated individuals that are leaving the party that create a danger to the public

NAME/BADGE NUMBER
AGENCY
TlNIT/ASSIGNMENT

AFFIAN

SWORN TO AND SUBSCRIBED before me on this the lln day of


A,1rtl zozz
NOTARY PUBLIC in and for the State of Texas
Commission expires: / - z) - ?> ,20 t)
uan ra
NOTABY PUBLIC
tDf 1318652t8
ln and lor the State ot Texas

01-
Subject: Re: Priscilla Chavez,5081 Fort Defiance, El

Juan lbarra (Sgt.) Paso, TX 79938

From: Juan lbarra (Sgt.)


Sent: Thursday, August 1 1, 2022 12.34
You don't often get emailfrom rav@velardelaw.com- Learn why this is
PM important
To: Javier Jimenez
Subject: Priscilla Chavez, 5081 Fort
A[,
Defiance, El Paso, TX 79938
signed order.pdf Enclosed is a fully executed copy of the order
Attachments:
granting Ms. Chavez to host social gatherings in the
rear portion of her property. Please advise if there
are any questions or concerns.

From: Omar Montoya (Sgt.) <OMontova @eocountv.com>


On Mon, Apr LL, 2022 al8:09 PM Javier Jimenez
Sent: Monday, Apt la,207210:17 AM <JJimenez@epcounty.eeE> wrote:
To: Paul Soria (Lt.) <PSoria@eocountv.com>
Cc: Amy Monsivais <AMonsivais(oeocountv.com>
Good Evening,
Subject: Fwd: Priscilla Chavez, 5081 Fort Defiance, El Paso, TX 79938
Thank You for your assistance in this matter and I
Just received this from Attorney Velarde.
will wait for your email,
Sent from my iPhone
Deputy Javier Jimenez #2008

Begin forwarded message


From: Ray Velarde <rav(ovelardelaw.com>
From: Ray Velarde <rav(ovelardelaw.com> Sent: Monday, April LL,2022 1:37 PM
Date: April 18,2022 at 10:14:08 AM MDT To:.Javier Jimenez <JJimer'tez@ep countv.com>
To: Javier Jimenez <JJimenez e ou m Cc: Priscllla Chavez <Jeepsrt8,cc@gry]all.com>
"omar Montoya (Sgt.)" Subiect: Priscilla Chavez,5081 Fort Defiance, El
<OMontova(aeDcountv.com> Paso, TX 79938
cc: Priscilla Chavez <Jeepsrt8.cc@gmail.com>

1 2
above. lf you have received this message in error,
You don't often get emailfrom ray@velardelaw.com. Learn why this is
please immediately notify us by telephone to
important
arrange for the return of the transmitted
documents to us, and you are hereby notified that
any disclosure, copying, distribution, Mal-use, or
lrepresent Ms. Chavez in connection to the above- taking any of action in reliance on the contents of
named property. I understand that your office is this message is strictly prohibited.
requesting paperwork where Ms. Chavez is
allowed to conduct the Batherings she has at her
address. I am awaiting the Court to provide the
paperwork your office is requesting I understand
your office has an interest in these matters. Rest
assured lwill forward to you as soon as possible. Ray Velarde
Thank you ! Aftorney at Law
1216 Montana Avenue
El Paso, Texas 79902
TeI: 91s-s32-6oo3

-CONFIDENTIATITY NOTICE.
Ray Velarde
The documents accompanying this message
Aftorney at Law transmission contain confidential information which
is legally privileged. This information is intended
r216 Montana Avenue only for the use of the recipient named above. lf
you have received this message in error, please
El Paso, Texas 79902 immediately notify us by telephone to arrange for
the return of the transmitted documents to us, and
Tel: 91S-SB2-6oo3 you are hereby notified that any disclosure,
copying, distribution, Mal-use, or takinB any of
-CONFIDENTIALITY NOTICE. action in reliance on the contents of this message is
The documents accompanying this message strictly prohibited.
transmission contain confidential information
which is legally privileged. This information is
intended only for the use of the recipient named
3 4
IN THE CRIMINAL DISTRICT COURT AT LAW NUMBER ONE
OF EL PASO COUNTY, TEXAS

STATE OFTEXAS s
$
v $ CAUSE NO:20160D02383
S
PRISCILLA CHAVEZ S

DEFENDANT'S AMENDED MOTION TO MODIFY TERMS A}ID


CONDITIONS OF RELEASE

TO TI{E HONORABLE JI]DGE OF SAID COURT:

COMES NOW Priscilla Chavez by and through her undersigned attomey, Ray Velarde,

and petitions this Honorable Court to modif, the terms and conditions of release filed in the

above-captioned case and as cause for said Motion will show the Court the following:

I.

On July 25,2016, this Honorable Court entered an Amended Personal Bond Agreement in

the above-captioned case, pursuant to a Personal Bond Violation that was filed on July 25,2019,

attached hereto as Exhibit 'A." Said Order provides, among other things, that Defendant:

"Give Sample of Urine Request: Use no Illegal Drug or Alcohol"

II.
Defendant appeals to the Court to modift the Amended Personal Bond Agreement so that

Defendant can subcontract a poftion of her property to an event planning company, GMT

Promotions Entertainment, to host social events for income purposes. Attached hereto as Exhibit

"B" is a copy of the Rental Agreement. Also, attached hereto as Exhibit "C" is a collection of

pictures that pinpoint the part ofthe house that is going to be used by the promoter.

Defendant understands that as a provision ofthe Personal Bond Agreement the Defendant

is not to use, sell or distribute alcoholic beverages. Defendant advises the Court that all events held

1
at her property fie held in completely separate quarters of her property and the promotion

company provides security to all events. Defendant does not manage or supervise the events. This

is strictly done by GMT Promotion Entertainment.

uI.
Defendant's Pretrial Service Officer has been advised ofthe instant motion and is awaiting

a ruling from the Court.

IV.

Defendant submits that Defendant has complied with all the terms and conditions of the

aforementioned release order and further submits that if said order is modified, she will not
abscond nor violate any of the terms and conditions set out herein.

WHEREFORE, premises considered, Defendant Priscilla Chavez requests that Order be

modified, and for such other and further reliefto which she may show herselfjustly entitled.

Respectfi rlly submitted,

RAYYELARDE
srate Bar No. 20539950
1216 Montana Avenue
El Paso, Texas 79902
(9 r s) 532-6003/5 42-2341 F AX
Attorney for Defendant

CERTIFICATE OF SERVICE

I hereby certifr that on the I lrH day of Apfl,2022,1filed the foregoing elecronically through the
Texas E-filing system, which caused the following parties or counsel to be served by electronic means, as
more fully reflected on the Notice of Electronic Filing: Assistant Dishict Attomey, 500 E. San Antonio, 2
Floor, El Paso, Texas 79901.

RAYVELARDE
2
g8/05/2519 09: a7 191554581A3 DCRl PAGE OL/OI

TTII STATE OT TEXAS crs I - III: MoNEY LnUNDERING


icii JUL 3l 6[$B0E:
vs
PRISCILLA CHAVEZ
D
cAsE NO,20t60D023r3 ri:r 9LS-546-2285

PERSONAL BOND VIOLATION ATflDAVIT


My namc is Michacl Bcjarano am ofsound mind, capable of making thls rftidtvit, and
pcrsonally acquainted with thc facu hcrcin stEted,

I, Michacl Bejarano rm an Employcc with Crimiaal Justicc Coordin&tion Drpaltnent. ln 6st


capacity, I supcrvise compliancc of the pcrsonal rccogrrizancr bond tcrms and eonditions for thc
above named dcfcndant.

The abovc namcd dcfcndant sigrrd r, Peronel Bond Agecment on lSth dry ofJuly,20l6. &!
orleloel boad rmount 3159. !0 CS / $150.000 PR The dcfendant hEs violated thc personal
rccognizancc bond tcrms cnd conditions a! follows:

! rritcd to report ro the Prc-Trial Bond Ofiicc of thc Criminal Justicc Coordination Depanmcnt:
( )Daily( )Weekly( ) Bi-Wlskly( ) Monthly( ) by Pbone bchrccn the hourr of9:004m
rnd 5:0Opm.
Sincc thc following datc:
! Committcd an offcnsc rgainst the laws ofthc Statc ofTexas or any othcr stalc ofthc Unitcd
Statcs, nrmcly, lhc offenseof- on the dalc of

tr Friled to maintain pctmanent rcsidcncc withinwiihout


thc limits of El Paso County, Texas, oad/or
pcrmission of thc Prc- Trial scction and/or
movcd from the county or reponed rcsidence
thc Courr.
tr Failcd to pcrmit thc Prc-Trial Bond Sraff to visit the Dcfcndant !t homc or clscwhcrc, namcly:
tr work falthfully suitablc crlploymcnr rndor stend school.
Failcd to at
Failcd to provide proof of anempts to sci-urc suitable cmploymcnt or school anendancc.
orr
Failcd to naintain curfew by failing to bc at hisfrcr placc ofrcsidcncc bctween the hours of-
p.m. and r.m . cach and cvcry day unlcss working utd/or sttcnding school,
E frifca to submit to urinc auneillance as dirccted by thc Prc'Trial Bond StEff
E Frtl.d to-rbldc by othrr condlrion$ lnpored by thc Court rn or Spccirl Cooditionr _listcd
ar follors: Pcr ipfolmltloo Dmvldcd bv EPSO. dcfcodrnt holtcC nlultlDlc Dtllitl r!
rc.idcncc locmS irthlo the ll-itt of EtI"to couotv. TX. tnd

Supcwising Offi co's Signatuc: Datc: 25th day ofJuly,2019


Subscribcd and swom to bcforc n dat!.
N Y SIGNATLIREI

!A
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IN THE CRIMINAL DISTRICT COURT AT LAW NUMBER ONE
OF EL PASO COUNTY, TEXAS

STATE OF TEXAS $
s
$ CAUSE NOr 20160D02383
s
PRISCILLA CIJAVEZ $

ORDERTOMODIFY
CONDITIONS OF RELEASE

On this day came on to be considered the Motion to Modifr Conditions of Release filed by

Defendant, Priscilla Chavez, in which said Defendant is hereby requesting that the Court modify

the terms and conditions ofrelease so that Defendant can subcontract a portion ofher property to

an event planning company! GMT Promotions Entertainment, to host social events for income

purposes.

Having considered the Motion and the facts, the Court is of opinion that said Motion

should be granted.

It is therefore ORDERED that the terms of release of Defendant, shall be, and they are

hereby, AI4ENDED to allow Defendant to subcontract a portion of her property to host social

events for income purposes.

SIGMD AND ORDEREDflIs 18th d6y 6f Api1,2022.

34{,A
JUDGE PRESIDING

3
EXHIBIT 21
8/11/22, 12:45 PM https://casesearch.epcounty.com/PublicAccess/CaseDetail.aspx?CaseID=7558034

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Register of Actions
Case No. 20160D02383

State of Texas vs PRISCILLA CHAVEZ § Case Type: Adult Felony


§ Date Filed: 05/24/2016
§ Location: Criminal District Court 1
§
§

Related Case Information

Related Cases
20160D02382 (Co-Defendants)
20160D02384 (Co-Defendants)
20160D02385 (Co-Defendants)
20160D02386 (Co-Defendants)
20160D02387 (Co-Defendants)

Party Information

Lead Attorneys
Defendant CHAVEZ, PRISCILLA RAY VELARDE
  Retained
915-532-6003(W)
 
State State of Texas

Events & Orders of the Court

    OTHER EVENTS AND HEARINGS


05/24/2016  Indictment (OCA)
06/03/2016  Entry of Appearance       Index # 1
06/08/2016  Precept to Serve
06/08/2016  Motion Recalling Capias       Index # 2
06/10/2016  Waiver of Appointment of Counsel
06/11/2016  Certificate of Magistrate
06/11/2016  Waiver of Appointment of Counsel
06/13/2016  Precept Return
06/13/2016  Order
06/13/2016  Order of Court Setting
06/14/2016 CANCELED  
Bond Hearing 
(9:00 AM)
()
  
Court Coordinator Discretionary Cancellation
06/14/2016  Bond Hearing 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
06/14/2016  Discovery and Pre-Trial Order
06/16/2016  Bond Order
06/17/2016  Bond Hearing 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
06/17/2016  Order of Court Setting
06/17/2016  Motion Reducing Bond
06/21/2016  Order of Court Setting
06/22/2016  Motion Reducing Bond
06/23/2016  Notice       Index # 4
06/29/2016  Order of Court Setting
06/29/2016  Order of Court Setting
07/01/2016  Motion Hearing 
(9:00 AM)
(Judicial Officer Navarrete, Diane)
07/01/2016  Motion for Substitute Counsel       Index # 5
07/01/2016  Order
07/05/2016  Order of Court Setting
07/06/2016  Motion Reducing Bond
07/07/2016  Bond Hearing 
(2:30 PM)
(Judicial Officer Navarrete, Diane)
07/08/2016  P R Bond
08/30/2016  Motion to Modify Community Supervision
08/31/2016  Order to Modify       Index # 6
10/18/2016  28.01 Hearings 
(2:30 PM)
(Judicial Officer Navarrete, Diane)
10/20/2016  Order of Court Setting
10/21/2016  Motion       Index # 7
10/24/2016  Order
11/14/2016  Motion       Index # 8
11/29/2016 CANCELED  
Final Pre-Trial Hearing 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
  
Agreed
12/09/2016 CANCELED  
Jury Trial 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
  
Agreed
01/10/2017  28.01 Hearings 
(2:30 PM)
(Judicial Officer Navarrete, Diane)
01/10/2017  Order Setting Bond       Index # 9
02/21/2017  Final Pre-Trial Hearing 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
02/21/2017  Order of Court Setting
03/03/2017 CANCELED  
Jury Trial 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
  
Court Coordinator Discretionary Cancellation

https://casesearch.epcounty.com/PublicAccess/CaseDetail.aspx?CaseID=7558034 1/3
8/11/22, 12:45 PM https://casesearch.epcounty.com/PublicAccess/CaseDetail.aspx?CaseID=7558034
03/06/2017  Order of Court Setting
03/16/2017  Motion to Sever Hearing 
(10:00 AM)
(Judicial Officer Navarrete, Diane)
07/18/2017  Final Pre-Trial Hearing 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
07/20/2017  Order of Court Setting
07/28/2017 CANCELED  
Jury Trial 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
  
Agreed
10/23/2017  Status Conference 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
10/23/2017  Order of Court Setting
10/26/2017  Status Conference 
(2:30 PM)
(Judicial Officer Navarrete, Diane)
10/30/2017  Order of Court Setting
04/19/2018  Status Conference 
(11:00 AM)
(Judicial Officer Navarrete, Diane)
04/23/2018  Order of Court Setting
05/02/2018  Status Conference 
(11:00 AM)
(Judicial Officer Navarrete, Diane)
05/03/2018  Order of Court Setting
06/13/2018  Status Conference 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
06/20/2018  Order of Court Setting
07/11/2018  Status Conference 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
07/12/2018  Order of Court Setting
11/15/2018  Order of Court Setting
11/27/2018  Status Conference 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
02/12/2019  28.01 Hearings 
(2:30 PM)
(Judicial Officer Navarrete, Diane)
03/26/2019  Final Pre-Trial Hearing 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
04/04/2019  Status Conference 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
04/05/2019 CANCELED  
Jury Trial 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
  
Agreed
04/08/2019  Order of Court Setting
05/01/2019  Status Conference 
(9:30 AM)
(Judicial Officer Navarrete, Diane)
05/01/2019  Order of Court Setting
06/27/2019  Status Conference 
(9:30 AM)
(Judicial Officer Navarrete, Diane)
07/01/2019  Order of Court Setting
07/31/2019  Notice       Index # 10
07/31/2019  Affidavit       Index # 11
07/31/2019  DCLK Warrant Issued
07/31/2019  Receipt       Index # 13
08/05/2019  Application for Appointment of Counsel
08/05/2019  Certificate of Magistrate
08/06/2019  Order of Court Setting
08/07/2019 CANCELED  
Status Conference 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
  
Agreed
08/07/2019  Motion       Index # 14
08/08/2019  Status Conference 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
08/08/2019  P R Bond
08/08/2019  Order of Court Setting
08/21/2019  DC Filed by Warrant Return
08/29/2019  Motion       Index # 15
09/03/2019  Order
10/28/2019  Bond Order
10/31/2019  Receipt       Index # 16
12/17/2019  28.01 Hearings 
(2:30 PM)
(Judicial Officer Navarrete, Diane)
02/18/2020  Final Hearing/Plea Deadline 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
02/20/2020  Order of Court Setting
02/28/2020 CANCELED  
Jury Trial 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
  
Agreed
06/16/2020 CANCELED  
Final Hearing/Plea Deadline 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
  
Court Coordinator Discretionary Cancellation
06/26/2020 CANCELED  
Jury Trial 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
  
Court Coordinator Discretionary Cancellation
09/15/2020  Final Hearing/Plea Deadline 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
09/23/2020  Order of Court Setting
09/25/2020 CANCELED  
Jury Trial 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
  
Agreed
10/30/2020  Status Conference 
(9:00 AM)
(Judicial Officer Navarrete, Diane)
11/06/2020  Order of Court Setting
04/27/2021  Order of Court Setting
04/29/2021  Order of Court Setting
04/30/2021 CANCELED  
Status Conference 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
  
Agreed
10/19/2021 CANCELED  
Final Hearing/Plea Deadline 
(2:00 PM)
(Judicial Officer Navarrete, Diane)
  
Cancelled Pending Reset
10/19/2021  Order of Court Setting
10/22/2021 CANCELED  
Jury Trial 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
  
Cancelled Pending Reset
10/29/2021 CANCELED  
Jury Trial 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
  
Court Coordinator Discretionary Cancellation
03/22/2022  Final Hearing 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
03/22/2022  Order of Court Setting
04/05/2022 Status Conference 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
  
04/12/2022 Reset by Court to 04/05/2022
04/11/2022  Motion       Index # 18
04/11/2022  Order of Court Setting
04/19/2022  Order of Court Setting
04/26/2022  Motion to Reconsider Hearing 
(2:30 PM)
(Judicial Officer Navarrete, Diane)
04/27/2022  Order of Court Setting

https://casesearch.epcounty.com/PublicAccess/CaseDetail.aspx?CaseID=7558034 2/3
8/11/22, 12:45 PM https://casesearch.epcounty.com/PublicAccess/CaseDetail.aspx?CaseID=7558034
04/27/2022  Motion to Reconsider       Index # 19
04/28/2022  Motion to Reconsider Hearing 
(11:00 AM)
(Judicial Officer Navarrete, Diane)
05/02/2022  Order of Court Setting
05/03/2022 CANCELED  
Final Hearing/Plea Deadline 
(1:30 PM)
(Judicial Officer Navarrete, Diane)
  
Cancelled Pending Reset
05/13/2022 CANCELED  
Jury Trial 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
  
Cancelled Pending Reset
05/24/2022  Motion to Reconsider Hearing 
(9:00 AM)
(Judicial Officer Navarrete, Diane)
05/24/2022  Order of Court Setting
06/02/2022 CANCELED  
Motion to Reconsider Hearing 
(11:30 AM)
(Judicial Officer Navarrete, Diane)
  
Cancelled Pending Reset
07/21/2022  Status Conference 
(8:30 AM)
(Judicial Officer Navarrete, Diane)
08/11/2022  Order of Court Setting
08/25/2022 Bond Hearing 
(10:30 AM)
(Judicial Officer Navarrete, Diane)
  
10/27/2022 Reset by Court to 08/25/2022

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EXHIBIT 22
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