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NEW MEXICO LIVESTOCK BOARD JUSTIN GRAY SINALOA CARTEL DOMESTIC TERRORIST

BERNALILLO COUNTY

SECOND JUDICIAL DISTRICT COURT

CV-2023-09203

David Derringer,

Plaintiff,

V.

Sinaloa Cartel domestic terrorist private citizen Benjamin Benavidez Jr.,

Sinaloa Cartel domestic terrorist private citizen Justin Gray (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment),

Sinaloa Cartel domestic terrorist private citizen Manuel Monte (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment),

Defendants,


COMPLAINT FOR 11 COUNTS: COUNT 1-INJUNCTION; COUNT-2 REPLEVIN/REPARATIONS UNDER NMSA 42-8-1 and NMSA 29-1-2; COUNT-3 LOSS OF INCOME, UNJUST ENRICHMENT, CONVERSION OF PERSONAL PROPERTY/LARCENY; COUNT-4 FRAUD, CONSTRUCTIVE FRAUD, FRAUD ON THE COURT, FRAUD IN THE INDUCEMENT; COUNT 5-CIVIL RIGHTS DEPRIVATIONS OF THE 1ST, 4TH, 5TH, 8TH, 9TH, 10TH, 13TH, AND 14TH AMENDMENTS AND VIOATIONS OF THE BILL OF RIGHTS, AND PERSONAL PROPERTY RIGHTS UNDER 42 USC 1982; COUNT-6 HARASSMENT, OBSTRUCTION OF JUSTICE, INTIMIDATION; COUNT-7 DOMESTIC TERRORISM, HATE CRIMES AND RACIST HATE CRIMES; COUNT-8 CIVIL REDRESS FOR CRIMINAL ACTS; COUNT-9 CONSPIRACY, COLLUSION, FACILITATION OF CRIMINAL ACTS; COUNT-10 MENTAL ANGUISH AND EMOTIONAL DISTRESS; COUNT-11 PRIMA FACIE TORT


Plaintiff, David Derringer representing himself Pro-Se states his COMPLAINT as follows.

JURISDICTION AND VENUE

1) Plaintiff, David Derringer, (hereinafter “Derringer”) was violated multiple times in numerous torts and domestic terrorism involving RICO Racketeering and collusion of these invading Mexico National Sinaloa Cartel members Defendants Benjamin Benavidez Jr., private New Mexico citizen Justin Gray (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment) and private citizen Manuel Monte (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment), all working members of the Sinaloa Cartel doing criminal horse rustling criminal acts and skewing the laws and attempting to use any effect and influence they have using fraud on NM State and Federal agencies for the criminal conspiracy to continue violence and criminal acts and to protect the invading Mexico National Sinaloa Cartel.

2) All Defendants are working in criminal acts and civil rights violations targeting Derringer in concert with the alien US insurgent invaders of the Sinaloa and Juarez Mexican Cartels and MS-13, in collusion and conspiracy with bribed state personnel, and in collusion with other Sinaloa Cartel members as an illegal ring of horse rustlers working and some living on the Pajarito, that by personal experience of Derringer’s horses being stolen and persons caught in illegal possession, some other members are Hector Cabrera, Petra LLC, Dennis Chavez, Muir Pedro, Francisco “Cisco” Lovato, Isaas Compos, Manuel Monte, Justin Gray, Isidro Ruiz Saenz, Darron Shawn Davis, Sharon Davis, Ignacio Ricardo Sanchez, “Gypsy”, Daniel Valdez, Ramon Manquero, Patrick Calderon, A. B. Swanson, Andres Majalca, Christopher Sena., and many illegal aliens and citizen mules working for each; all of these known of and wherein all of the named Defendants are in conspiracy and collusion with each, or some of the named Defendants are intertwined so as all Defendants in conspiracy are also tied in liability and wherein all are protected and known and in CONSPIRACY with come corrupt state employees of the agencies of the BCSOO and NMLB..

3) All Defendants are traitors to the United States working against all law as subversive “domestic terrorists NM citizen personal actors”, as Sinaloa Cartel American employees as also known Cartel members, Cartel American Defendants noted above as “mules” and bribed “protector” for the Sinaloa Cartel. All Defendants seek to destroy America, protect, indemnify, and hold harmless all co-conspirator Defendants involved, so as to promote crimes against all Americans, specifically “targeted” against American Plaintiff David Derringer so as nationally and in New Mexico to provide unimpeded the trafficked cocaine, methylamphetamines, fentanyl, automatic firearms, human trafficking, and trafficking minors to the current administration, Judges, attorneys and elite cocaine addicts and pedophiles, with deliberate “open borders” facilitating the invasion and take-over of America by Democrat massive illegal voting illegal aliens.

4) The collusion and malicious conspiracy of these Defendants working with other criminals doing grand larceny (conversion), animal abuse, assault, burglaries, stealing over now 252+ head of Derringer’s horses, and more ongoing each day, as conversion of “personal property”, from the open range of private lands of the Pajarito Mesa in Bernalillo County NM to destroy the life and property of the Plaintiff.

5) This is occurring with orchestrated private individuals in terrorism, fraud to the courts, obstruction of justice, harassment, intimidation, threats of murder of Derringer, constantly trying to get Derringer illegally jailed, and other torts wherein the venue and jurisdiction is proper in Bernalillo County. As the terrorism and crimes are initiated in Bernalillo County, the venue is proper in Bernalillo County even though the stolen property is also moved across the county line to Valencia County, and some taken illegally across the US American border to the countries of Mexico and elsewhere, where the Defendants (plural) act illegally with likely provable state rogue employees, and where the illegal and US citizens live and operate as personal individuals involved in the torts

6) Plaintiff, David Derringer, lives in Bernalillo County at Box 7431, Albuquerque, New Mexico 87194.

7) Invading Mexican National Sinaloa Cartel member domestic terrorist NM private citizen Justin Gray (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment) can be found at location of 2105 Osuna Rd. Building South, Albuquerque, New Mexico 87113.

8) Invading Mexican National Sinaloa Cartel member domestic terrorist NM private citizen Manuel Monte (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment) can be found at location of 607 Brcker Avenue Belen, New Mexico 87002.

9) Invading Mexican National Sinaloa Cartel member domestic terrorist Benjamin Benavidez Jr. is located at 9701 Volcanes Rd. NW Albuquerque, New Mexico 87121.

10) Plaintiff’s cause of action arose with both Plaintiff Derringer and Defendants at all times in New Mexico, and all substantive matters involve happenings with all torts, conversion, killings of horses and mutilation and abuse, terrorism, intimidation, death threats and other matters that are performed by the Defendants, so venue is proper in the 2nd Judicial District Court wherein this both collectively in conspiracy and collusion wherein thus all Defendants are liable separately for all torts and all amounts even though one conspirator acted without others present but within the collective knowledge of all either before each act or after the overt act occurred. This 2nd Judicial District Court has full jurisdiction over both the parties and the subject matter.

11) Upon information and belief all of the Defendants above are in the State of New Mexico.

GENERAL ALLEGATIONS COMMON TO ALL COUNTS

12) Plaintiff adopts and incorporates by reference herein paragraphs 1-11 of the complaint as if set forth in full.

13) The East/West fence line dividing the Pajarito consists of open range wherein all lands are private lands, and dividing thus from the Santolina private lands is historically been in disrepair for 110 years, and non-compliant with NMSA 77-16-1, (not built or re-built in compliance with NMSA 77-16-4) well known to the Defendant private citizen Justin Gray and Defendant private citizen Manuel Monte as they collude with the Sinaloa Cartel private citizen Benjamin Benavidez Jr.’s where it was the Benavidez Jr.’x uncle Ivan Benavidez that set NM Case law of “FENCE THEM OUT” by NM Court of Appeals Case No. 12-8853; known to all courts that the Pajarito dilapidated fence precludes any Defendants trying to claim any “trespass” (also specifically prohibited in NMSA 77-14-3(A) of any livestock that might gain access to the “then open range” of the Santolina.

14) Defendants all know that the Santalina use by Benjamin Benavidez Jr. allegedly claiming a “grazing permit” is fraud, wherein the alleged contract for such with Garrett Corporation is breached and null and void due to the clause therein that the Pajarito fence line must be kept in statutory compliance with NMSA 77-16-1 which it is not and never has been. Therefore there can never be any fraudulent claim against any animals in trespass wandering onto the Santalina from the Pajarito or elsewhere, and there thus can never be any false claims for damages to the Santolina due to the Pajarito fence in total wrongful construction under statutory mandates and in total disrepair. Both the Santalina and the Pajarito are private lands and as the Pajarito is “open range” so thus is the Santolina without a legal, proper Pajarito dividing fence thatvis not compliant to NMSA 77-16-1.

15) No representing attorney in Answer to this Complaint, nor any assigned Judge to this case cannot contest or question that the Santolina is legally designated as any other then “open range” contiguous with the open range of the Pajarito since the Pajarito dividing fence is of no value of deterring or to be considered a barrier affording “livestock access from the Pajarito” since in total disrepair, the Pajarito fence does not FENCE THEM OUT, wherein no court can consider any premise that any state agency can get involved to claim any animals strays on either the Pajarito or the Santolina as both are private properties with both having no designation as a herd law district. Under NM Ct. App. No. 12-8853 case law was set regarding the Pajarito fence as mandatred FENCE THEM OUT.

16) Benjamin Benavidez Jr. does not own the Santolina lands, but has breached his alleged grazing contract by not re-building the Pajarito fence to statutory compliance and is thus trespassing as a squatter on the Santolina lands of Garrett Development Corporation with no legal means of allowing his castle to graze those premises, nor any means to attack, capture, or steal any horses coming into the Santalina. Benjamin Benavidez Jr. does not comply with the contract with Garrett Development Corporation, voiding the contract by negligent, malicious and deliberate refusal and failure to build a proper fence. Consequently, there is a legal contract breach and Benjamin Benavidez Jr. does not have a valid grazing contract, whereas with breach, the contract is mute and void. The Sinaloa Cartel persons

17) All Defendants are using the Pajarito fence line to open it to the Pajarito for horses owned by Plaintiff Derringer thus allowed to wander into the Santolina, whereas then all Defendants close the perimeter fence, trapping the horses on the Santolina without water and then illegally herd horses not owned by any Defendant to lock them in permanent pens to be able to then herd them into trailers for horse larceny. Defendants Manuel Monte and Justin Gray have no legal right to be on the Santolina at any time and are in trespass on such lands as Sinaloa Cartel mules for the RICO racketeering operation of horse rustling. There are never any horses on the Santolina that are legally owned by any Defendant.

18) All Defendants are in collusion and conspiracy to protect the Sinaloa Cartel horse rustling (larceny) and to protect one another in this RICO racketeering and other Sinaloa Cartel illegal activities of drug trafficking, human trafficking, sales of minor children to pedophiles, illegal sales of fully automatic firearms to the BCSO, and other debauchery and contraband.

19) The Defendants and all others have full knowledge that any horses that get onto the Santolina are not owned by the Defendants and lock up and then steal the horses as Sinaloa Cartel members for profits, kickbacks and perks of the Sinaloa Cartel whereas to this date of filing over 337 plaintiff Derringer horses have been stolen by the Defendants.

20) Defendants all work “in concert” of conspiracy with all other members of the invading Mexican National Sinaloa Cartel including but not limited to Sinaloa Cartel members Francisco “Cisco” Lovato, Kym M. Damazyn, Mier Pedro, Ramon Manquero, Isaas Compos, Isidro Ruis Saenz, Hector Cabrerra, Karla and Ernest Martinez, “Gypsy”, Patrick Calderon, Darron “Shawn” Davis, Sharron Davis, Dennis Chavez, Southwest Event Center LLC, D.C. Livestock Auction, Southwest Livestock Auction, Benjamin Benavidez Jr.,Benavidez Ranch, and many others in New Mexico, all of which are convicted felons or doing felonies not yet convicted; all doing treason against the United States of America as both foreign and domestic terrorists.

21) The Derringer horses are the private personal property of David Derringer with 12 years of breeding the 32 horses from the Derringer ranch South of Quemado, NM when Derringer was driven off his legal ranch by gunpoint of the same Sinaloa Cartel as the Defendants herein.

22) All Sinaloa Cartel Defendants know exactly where Derringer lives, just 200 yards South of the SW corner of the Santolina/Pajarito fence line; Derringer being on the Pajarito and all Defendants have been in conspiracy to burglarize, rob, assault, and steal in larceny horses, firearms, tools and more and also vandalize the personal property of Plaintiff Derringer.

23) All above Defendants are totally immersed in the employee, or collusion, and conspiracy of the invading Mexican National Sinaloa Cartel doing domestic terrorism against targeting Derringer in larceny, killing, mutilation, abuse, deprivation of water of all the now 337+ Derringer horses rustled by the above Defendants and the Cartel with cooperation by some rogue NM employees assisting in the protection, and taking the stolen horses to hidden places in New Mexico or to the known horse larceny felon Dennis Chavez on 24 Dalies Road Los Lunas, New Mexico

24) Benjamin Benavidez Jr.’s father, Benjamin Benavidez “the Elder” has former convictions of livestock larceny, and Benjamin Benavidez Jr. confessed of court record on January 21, 2015 Answer to Derringer v. Benavidez et. al. : D-202-CV-2014-07755, to stealing 2 Derringer horses and using his truck and horse trailer to transport the stolen livestock to horse rustler (also formerly convicted) Dennis Chavez 24 Dalies Rd. Los Lunas, NM, for over 40 years serving as the “fence” for stolen NM horses.

25) The Mexican National Sinaloa Cartel is an invading foreign body of subversives as enemies against of the United States, and all Defendants aiding, abetting, facilitating, protecting these invaders are traitors to the United States of America.

26) NM citizens are mandated to obey the laws under NMSA Title 30 and all federal law and Constitution..

27) Illegal insurgents are criminal enemies of the United States of America waging “war” upon the United States with the proven agenda of using weekly income of $32 million dollars to bribe NM officials for “protection”, immunity by the “law enforcement” agencies to protect, indemnify, and hold harmless all criminal acts of all involved against all rights, and all rule of law against “targeted” Derringer, and all Defendants are intertwined in conspiracy and embroiled in the attack against America.

28) David Derringer currently resides on the private property of the Pajarito Mesa wherein all property thereof is “private” and all within the boundaries of New Mexico State Political subdivision Bernalillo County, wherein Derringer horses are on the “open range” of the Pajarito where in NM no brands are mandated.

29) Pajarito Mesa and surrounding lands entering into the Rio Puerco are designated as “open range” under statutory law NMSA 77-16-1 “Fence Them Out” due to the private lands all with common borders with few private perimeter fences, with no county roads or thus no county jurisdiction, and wherein; thus, the NMLB has no jurisdiction to claim any “estray” horses which all horses are on only private lands and wherein there exist no stray horses, wild horses, un-owned horses in the 27 square miles (est) of the Pajarito Mesa.

30) Borders of the Pajarito are the Escarpment N/S road to the Ease, the Isleta Indian Reservation E/W fence to the South, the Rio Puerco, to the West and the Pajarito E/W fence line to the North.

31) The Pajarito fence line is in total disrepair and non-compliant with the mandates of NMSA 77-16-1, as dividing line between the Pajarito open range private properties and the Santolina private land development property, wherein as the Pajarito fence in proven disrepair for 110 years, legally makes the Santolina also open range as contiguous and congruent with the Pajarito, wherein any livestock that enter the Santolina can be retrieved by any livestock owner, by opening gates, opening the fence, or entering the Santolina and herding the owner’s livestock back onto the Pajarito congruent with ruling of the New Mexico Court of Appeals “FENCE THEM OUT” No. 12-8853.

32) All Defendants have knowledge well that any livestock owner can go onto the Santolina, or open the fence to recover horses or cattle under NM Ct. App. No. 12-8853, since the Pajarito fence line is not a legal barrier.

33) There are no “stray”, or “wild horses” ever on the Santolina or Pajarito lands.

34) All livestock horses on the Pajarito are owned by some person; and currently all the Derringer horses are either breeding stallions or breeding mares or young offspring of colts and fillies; none being gelded or spade.

35) Sinaloa Cartel are proven to steal Pajarito horses with the use of herding the horses to Benavidez’ permanent pens and whereas then Sinaloa Cartel Justin Grey and Manuel Monte admit to trailering such stolen livestock from these pens.

36) Plaintiff David Derringer has an extreme numbers of photographs of his horses locked in the Santolina perimeter fence and locked in the permanent pens of wood/steel inside the Santolina as proven “intent” of larceny on the Santolina without food or water, and has documents of confession by Sinaloa Cartel Justin Gray of trailering Derringer horses from the permanent pens on the Santolina. [multiple Exhibits 1].

37) Plaintiff Derringer is witness to Sinaloa Cartel Benavidez, Gray and Monte herding and loading and trailering such horses to Dennis Chavez in Los Lunas, NM several times and dates.

38) Livestock in New Mexico are not required to be branded as available option and the Derringer horses are not branded due to preference of selling some to show horse persons that do not want brands. However, as with all horse registries, all horses can be positively identified by color marking on bodies and face markings that never change in the life of the horse from birth and age by tooth inspection.

39) David Derringer is the lawful owner of over 362+ horses with about 32 new babies in 2023. Now the Sinaloa Cartel has stolen in larceny over 337+ horses.

40) Sinaloa Cartel Justin Gray has confessed in writing to stealing 28 horses, when in reality due to pregnant mares the number is actually 39.

41) Some of the horses stolen by admission of Sinaloa Cartel Justin Gray are as #1. Bay stallion; #2. Buckskin mare. #3. Buckskin filly. #4. Sorrel mare. #5. Sorrel colt. #6. Black filly. #7 Bay colt. #8. Sorrel colt. #9. Sorrel colt. #10. Sorrel mare. # 11. Sorrel colt. # 12. Bay mare. #13. Bay filly. #14. Sorel filly with a star strip #15. Chestnut stallion with a blaze, right hind cannon, and left hind pastern #16 Sorrel mare with a star #17. Sorrel colt with a blaze and lower lip #18. Bay mare with a star, right hind cornet and mother of # 19. Sorrel Colt with both hind cannons #20 Gruella mare with blaze, left hind cannon as right front pastern and had been stolen and illegally branded with a 12 on the left shoulder #21, Bay filly with a star and left hind pastern #22. Sorrel Stallion with a star snip and left front pastern #23. Chestnut mare mother to #24 Sorrel colt with a star snip and left front pastern #25 Chestnut mare with a star mother to # 26. Sorrel colt with a blaze #27. Palomino mare with a star previously stolen and illegally branded with a 12 on left shoulder #28. Sorrel filly with a star, strip, snip and a left hind cannon.

42) The admission of horse larceny of Sinaloa Cartel rustler Justin Gray occurred on or about August 23, 2023 and again on or about November 22, 2023, although it is known Gray was also involved with Monte “baiting” Derringer horses with remote hay and salt blocks to steal throughout 2020, 2021 and 2022, in domestic terrorism, retaliation, retribution, revenge and obstruction of justice of Derringer’s multiple Civil suits against both Gray and Monte.

43) All Derringer horses on the Pajarito Mesa on open range are all descendants of former original herd of 32 Derringer ranch and outfitting horses from Quemado, NM as well as current and descendant horses from additional horses purchased in the last 9 years from the Albuquerque area. Many Derringer horses are descended from registered Appaloosas and Quarter horses with ApHA and AQHA.

44) All Derringer “working herd” of 32 well trained horses Derringer are used for income from outfitting hunts, trail rides, pack trips and other training have all been now stolen, wherein all of the “working herd” could ride Western and Military, drive buggies and wagons, pack supplies to base camps and pack out hunt kills, and wherein 4 of that herd were also roping horses, 2 were also cutting cattle horses, and 1 trained for Medieval jousting, as well as 6 trained for shooting from their backs of guns and archery.

45) Derringer has to constantly haul water for his horses, and being unfenced, all other horses and cattle on the open range not owned by Derringer have constant access to the same water. At times, Derringer hauls up to 2,000 gallons of water per day to ensure his owned horses have water making 5 trips a day to Albuquerque, gone about 2 hours per trip, with much horse rustling taking place by Defendants with knowledge of Derringer’s absence and times available without detection.

46) Derringer owns several stallions and has new baby horses each year that ownership of same are Derringer’s personal property designated both by federal law Title 42 Section 1982 and many supporting case laws of SCOTUS.

47) Derringer can identify each horse owned by color markings, height, mannerisms and other identifying attitudes even at a distance, particularly with binocular magnification well knowing each horse personally as individuals. Derringer allows his foals to remain with the mother until rejection; thus, all foals are always with their mothers until about 10 months.

48) Sinaloa Cartel Benavidez admitted stealing 2 horses in 2014 and all Defendants and conspirators increased the horse larceny ongoing from there on.

49) All Defendants are using “bait” areas on the Pajarito and most of the horses are stolen by capture and containment by Sinaloa Cartel Benjamin Benavidez Jr.’s illegal use of the alleged grazing permit on the Santolina, wherein allow or chase Derringer horses from the Pajarito onto the Santolina and then lock them in without water on the Santolina, closing the perimeter fence. Then they entice or herd them to permanent pens in the middle of the Santolina wherein they permanently lock them in without food or water, and then easily back a stock trailer to a gate of the pen and herd them into the trailer for transport of stolen livestock to places unknown and concealed and sale to Dennis Chavez in Los Lunas, NM.

50) Owner Derringer has been interfering with the Benavidez horse rustling by seeing his horses locked up with Benavidez, and physically forced to release Derringer’s horses due to the total malicious discharge of all mandated duties of all law enforcement under NMSA 29-1-1 and 29-1-2 to save the horses’ lives deprived of water, enabled thus to get HOME.

51) All Defendants in conspiracy and collusion are benefiting from the RICO Racketeering of stealing the Derringer horses, as well have a need for retaliation, and revenge against Derringer in hate and racist crimes to destroy Derringer’s ability to expose the exponential public corruption in law suits.

52) Sinaloa Cartel Justin Gray and all Benavidez were involved or have knowledge of the Derringer one-week old filly butchered and thrown at the Derringer residence for intimidation. [Exhibit 2]

53) Plaintiff adopts and incorporates by reference herein paragraphs 1-52 of the complaint as if set forth in full.

54) Sinaloa Cartel Defendants all have all been caught and documented stealing Plaintiff’s personal property in grand larceny and proven with many photographs and witnesses of the RICO connections to the Sinaloa Mexican Cartel. Sinaloa Cartel Justin Grey has “confessed” to stealing 28 Derringer horses.

55) All Defendants have been in complicity and conspiracy to steal in grand larceny now over 337+ Derringer horses ongoing daily with clear intent to steal every horse Derringer owns and continue the burglaries to ruin Derringer’s life and drive Derringer from the State of New Mexico.

56) All Defendants have been involved in the murder of several Derringer horses in conspiracy and complicity with the Cartel, retaliation, revenge, and retribution against the Plaintiff seeking to run the Plaintiff from the State of NM for exposing the vast inclusive public corruption and now have done obstruction of justice, intimidation and instigated false reports as criminal acts under NMSA 30-39-1 and penal code 118- to gain false criminal complaints as a way to instigate false arrest, false imprisonment, abuse of process, and malicious prosecution to attempt to threaten and terrorize Derringer to stop the Derringer litigations.

57) All Defendants are complicit in the murder of the Derringer baby horse by torture of dismemberment of the right front leg by knife surgical removal, cutting its eyes out, ripping its heart out of the skinned rib cage, and then throwing the dead body at the Derringer residence as a death threat to stop all litigation or the Cartel will do this to the Plaintiff. Plaintiff has had 4 attempted assassination attempts against him.

58) Derringer seeks a permanent injunction against all Defendants to stop the larceny of Plaintiff’s personal property, death threats, killing horses and stop rounding up Derringer horses illegally claiming strays, and to return and recover all 337 + Derringer horses back to the Pajarito unharmed under mandates of replevin.

59) Order that Defendants cannot be within 100 yards from the Derringer horses or any other Derringer animal, friend, family member, and they cannot be in possession of any firearm within 1,200 yards of Derringer or his animals.

61) Defendants all know and are in conspiracy and collusion with all the Cartel horse rustlers on the Pajarito and all Defendants knows their names and knows the most are illegal aliens and knows the most, if not all are multiple time felons working all in conspiracy.

62) Defendants are personally perpetrators of the crimes against Derringer, having done the crimes themselves to Plaintiff Derringer; or in known collusion and conspiracy.

63) Defendants all know who has and the whereabouts of all Derringer horses or can find out for Replevin.

64) Derringer horses are worth a 30 year lifetime value of $100,000.00 each animal that have to be instantly and immediately returned to Derringer while Derringer is there to inspect that all horses are unharmed and that no babies are kept by the rustling perpetrators.

65) All 337 + Derringer horses are demanded to be returned immediately. Since now, all Derringer “working horses” described above are stolen, each needs to be replaced with expertly exactly trained registered horses in trained disciplines, of breeds Quarter Horses, Appaloosas, Paints, and Palominos, Gruella were stolen horses, in restoration at Derringer discretion.

66) Defendants all know exactly where Derringer’s stolen horses are, who has them and if they were killed and if they are locked in pens at DC Chavez “horse-killers” in Los Lunas or taken to Mexico or elsewhere.

67) Defendants all have tenable ways to get Derringer horses returned and the Sinala Cartel Defendants know the disposition of each horse.

WHEREFORE Derringer DEMANDS under NMSA 42-8-1 that every stolen horse be returned immediately unharmed. Derringer also claims the following values to be paid by EACH of all Defendants named in the heading assessed to each Defendant separately and distinctly.

1. A value of $100,000.00 per horse stolen and an amount of additional punitive damages of $100,000.00 per horse for the larceny itself with a $100,000.00 extra punishment if the horse as a Derringer pet is killed and butchered for meat or any stallion that has been gelded unable to breed.

2. Derringer claims a value of $200.000.00 for horse “Crescent” stolen three times and his balls cut off in mutilation.

3. All horses stolen by false claims of strays stolen by the Sinaloa Cartel Defendants from either the Pajarito or Santolna are mandated to be returned to the Pajarito from whence they came.

4. All Derringer horses are to be instantly returned directly to the Derringer residence on the Pajarito, in good health.

5. All Defendants EACH will pay Derringer $25,000.00 per horse returned in punishment and exemplary damages for the larceny/conversion and deprivation of use of the animal.

6. All Derringer horses will be returned to Derringer in proper health or each Defendant will pay any vet bills required and $25,000.00 punitive damages for animal abuse.

7. Derringer claims the amount in addition of $10,000,000.00 from each Defendant in an extreme amount to stop the instant larceny, and to be exemplary in a severe amount necessary to both deter, the instant Sinaloa Cartel Defendants RICO Racketeering and public corruption in concert with private parties and Cartels to punish not to perform horse rustling against others, and to also deter by case law others similarly situated not to perform horse rustling against others. Derringer also claims court costs and any other more severe damages and sanctions that the court deems just and proper under the circumstances.

8. These amounts will increase if the Sinaloa Cartel Defendants touch or steals any remaining horses.

68) Plaintiff adopts and incorporates by reference herein paragraphs 1-67 of the complaint as if set forth in full.

69) Sinaloa Cartel Defendants have now stolen “ongoing” over 337 + Derringer horses including now all trained “working horses” detailed above, stopping all horse related outfitting, hunts, pack trips, trail rides and other related use, as well as stopping all income of horse sales with constant burglary stealing all saddles, horse tack and training equipment. All stolen horses, horse tack and other burglary larceny has enabled unjust enrichment of all Defendants by collusion conversion of personal property /larceny, with then sale of stolen property, bribes and kickbacks, perks, and personal financial gain of Sinaloa Cartel Defendants.

WHEREFORE Derringer demands punishment, replevin, and severe exemplary damages of $10,000.000.00 ($ Ten Million Dollars) from each Sinaloa Cartel Defendant separately and distinctly from each Defendants private citizen Benjamin Benavidez Jr., private citizen Justin Gray, private citizen Manuel Monte and an additional $50,000,000.00 ($ Fifty Million Dollars) from Sinaloa Cartel Justin Gray as he admitted to stealing 28 Derringer horses, Court costs and any and further punishment from the Court for Sinaloa Cartel Defendants being TRAITORS AGAINST AMERICA IN COLLUSION WITH THE INVADING MEXICAN NATIONAL SINALOA CARTEL, as deemed just and appropriate by the Court.

COUNT-4 FRAUD, CONSTRUCTIVE FRAUD, FRAUD ON THE COURT, FRAUD IN THE INDUCEMENT

70) Plaintiff adopts and incorporates by reference herein paragraphs 1-69 of the complaint as if set forth in full.

71) All Sinaloa Cartel Defendants have met with a meeting of the minds to take collective criminal action against Derringer for the motive of protection and facilitation of the invading Mexican National Sinaloa Cartel as traitors to America, and to destroy Derringer’s life and his continued ability to have liberty, freedom, life of himself and his animals, happiness of use, companionship and “pet” bonds with his horses in an exponential domestic terrorism by the Sinaloa Cartel Defendants, with Defendants agreements to attack Derringer’s homeland America with terrorism. expose the vast NM public and judicial corruption. in which government officials act “in concert” with agreement with the Sinaloa Cartel.

72) All Defendants acted in tandem with each other as horse thieves, filing a false police report, in fraud, then goading officials to file false criminal charges in criminal violations of NMSA 30-39-1 and penal code 118.1 falsifying complaints in attempts to imprison Derringer; all FRAUD ON THE COURT.

73) All the above Defendants, had full knowledge of the essential objectives of the larceny, horse rustling and conspiracy. All Defendants above were knowing and voluntary complicit involvement, and interdependence among these Defendant co-conspirators.

74) All Defendants had an agreement as the gist of all these crimes of conspiracy and united in an understanding way to accomplish the fraudulent scheme.

75) All Defendants were acting in concert where even some attended the act of one or more of the conspirators to affect the object of the conspiracy totally complicit in it all.

WHEREFORE Since the conspiracy is well established, all Defendants are connected with evidence as co-conspirators in all acts and each Defendant is attributable to any member of the conspiracy that is attributable to all members. Derringer therefore demands punishment, replevin, and severe exemplary damages of $10,000.000.00 ($ Ten Million Dollars) from each Defendant separately and distinctly from each Defendant, Court costs and any and further punishment for being TRAITORS AGAINST AMERICA IN COLLUSION WITH THE INVADING MEXICAN NATIONAL SINALOA CARTEL, as deemed just and appropriate by the Court.

COUNT 5- CIVIL RIGHTS DEPRIVATIONS OF THE 1ST, 4TH, 5TH, 8TH, 9TH, 10TH, 13TH, AND 14TH AMENDMENTS AND VIOATIONS OF THE BILL OF RIGHTS, AND PERSONAL PROPERTY RIGHTS UNDER 42 USC 1982

76) Plaintiff adopts and incorporates by reference herein paragraphs 1-75 of the complaint as if set forth in full.

77) The invasion of the Sinaloa Cartel and Sinaloa Cartel domestic terrorist Defendants have no right to demand and steal Derringer’s personal property of horses used as “trade tools” for income, loved pets, breeding for income and increase in assets, for unjust enrichment, revenge, retaliation, interests, real or alleged, of non-owners as the Sinaloa Cartel horse rustlers of the Defendants.

78) Plaintiff Derringer has a Constitutional and Statutory right to own and control his personal property including owned horses.

79) Derringer has a Constitutional right to own, protect, and control it-even if that conflicts with the esthetic tastes or priorities of non-owners. Derringer has the right to acquire property and, once acquired, to use it without interference from others

80) All Sinaloa Cartel Defendants as co-conspirators dupe the courts in fraud, dupe all law enforcement, and file false and fraudulent police reports and criminal complaints that “trespass” can be charged against persons as a ruse to steal animals in larceny.

81) Plaintiff has a Civil right to “quiet enjoyment” of his animals and life style without domestic terrorism and larceny and fear of the Sinaloa Cartel Defendants’ ongoing RICO racketeering Sinaloa Cartel rustling industry of larceny of horses.

82) The Civil Rights Act of 1866 gave Plaintiff Derringer an unalienable right that all persons in the United States should be free as practical freedom from fear and oppression by the Sinaloa Cartel Defendants.

83) Derringer has a right to just compensation for force enslavement and oppression generated by the domestic terrorism by the Sinaloa Cartel Defendants defeat of Derringer’s Civil Rights in tort actions and Derringer is entitled to compensatory damages for humiliation, emotional distress, and deprivation of Civil Rights.

84) The conspiracy against Derringer by the ongoing Sinaloa Cartel domestic terrorist Defendants is a conspiracy aimed specifically for a deprivation against Derringer of the equal enjoyment of rights secured by the law to all other citizens.

85) Derringer has every right to inherit, purchase, lease, sell, hold, and convey real and personal property including his horses without any larceny or interference, and Sinaloa Cartel Defendants willfully trap and capture the horses without their ownership and without means to use NMSA 77-14-3 or any other law as any legal means of claim.

86) Derringer’s Civil Rights are those which have no relation to the establishment, management or support of the government and consists in the power of enjoying and acquiring property.”

WHEREFORE Since the conspiracy is well established, all Sinaloa Cartel Defendants are engaged maliciously in depriving Plaintiff’s Civil Rights by use of domestic terrorism, all connected with evidence as co-conspirators in all acts and each Defendant is attributable to any member of the conspiracy that is attributable to all members. Derringer therefore requests $1.2 billion Dollars from each Defendant, Court costs and any and further punishment for being TRAITORS AGAINST AMERICA IN COLLUSION WITH THE INVADING MEXICAN NATIONAL SINALOA CARTEL, as deemed just and appropriate by the Court.

COUNT-6 HARASSMENT, OBSTRUCTION OF JUSTICE, INTIMIDATION

87) Plaintiff adopts and incorporates by reference herein paragraphs 1-86 of the complaint as if set forth in full.

88) As detailed in other counts above, the well-orchestrated fraud posing and ploy to deliberately steal horses with INTENT is domestic terrorism to gain unjust enrichment, intimidation, obstruction of justice and retaliation, retribution and revenge having nothing to do with lawful activities.

89) Simply put, all actions of the Sinaloa Cartel domestic terrorists Defendants are based in crimes against Derringer and treason crimes against the United States of America.

COUNT-7 DOMESTIC TERRORISM, HATE CRIMES AND RACIST HATE CRIMES

90) Plaintiff adopts and incorporates by reference herein paragraphs 1-89 of the complaint as if set forth in full.

91) All Defendants were involved in the latest ongoing conspiracy of Sinaloa Cartel Justin Gray to deliberately steal additional Derringer horses.

92) The plan was to steal more horses knowing they are Derringer’s, then get $ thousands’ of dollars in ransom/extortion or then attack Derringer in falsely claiming Derringer horses, were again in trespass to entrap Derringer in more false accusation of a new criminal Complaint.

93) The INTENT is to dupe the Courts into false additional criminal complaints by entrapment when Derringer claims his own personal property in violation of a known false criminal complaint in fraud on the court to take away Derringer’s 4th, 5th, and 14th Amendment rights in denial of due process and equal protection, do cruel and unusual punishment under the 8th Amendment and extreme deprivation of freedom, liberty and threatened life of both Derringer and his animals, still illegally kept somewhere in possession of stolen property, maybe even being deprived of food and water.

WHEREFORE Derringer therefore demands punishment of $1.6 Billion ($1,600,000,000.00) from the instigator of this particular criminal plan by Sinaloa Cartel domestic terrorist Justin Gray, and $25,000,000.00 ($25 Million) each from those participating eagerly of from each individual complicit of other Sinaloa Cartel Defendants, Court costs and any and further punishment for being TRAITORS AGAINST AMERICA IN COLLUSION WITH THE INVADING MEXICAN NATIONAL SINALOA CARTEL, as deemed just and appropriate by the Court.

COUNT-8 CIVIL REDRESS FOR CRIMINAL ACTS

Plaintiff adopts and incorporates by reference herein paragraphs 1-93 of the complaint as if set forth in full.

94) All Sinaloa Cartel Defendants have worked in tandem, in fraud, in conspiracy, in complicity, and in treason against the United States of America, using motives of political, bribery, paid invader protection, perks of use of minor children, cartel whores, paybacks, kickbacks, and various other means of enrichment provided by the invading National Mexican Sinaloa Cartel only limited by their imagination and concurrence with the Carbal.

95) Defendants and the Sinaloa Cartel have stolen over now 337 + Derringer horses butchered a 1-week baby, stolen another baby foal abandoned by Benavidez Jr. stealing her mother mare and then a woman from the Benavidez Ranch license plate # 300SXC, attacked Derringer (with witnesses Sharon Davis and Ignacio Sanchez) three different times with noted aggravated assault with a deadly weapon handgun in order to then achieve stealing the baby filly horse to go back to the stolen mare stolen by Benavidez Jr. The alleged Cartel whore Sharon Davis, likely related to Darron Shawn Davis was not only a witness to the firearm robbery aggravated assault with a handgun, but is definitely a witness and likely participant to the earlier butchering of the 1-week filly [Exhibit 2] dismembered to threaten and intimidate Derringer with mutilated body thrown at the Derringer residence.

96) Sinaloa Cartel Defendants have violated every Constitutional right Derringer has in America against all rule of law, while harassing, intimidating and doing criminal acts of willfully depriving water to innocent animals in abuse retaliation against the Derringer owner, and assisting a plethora of crimes of burglaries, larceny of items and animals, neglect to prevent and deliberate abuse of animals, reckless endangerment of both Derringer and all Derringer animals, killing animals without justification. Sinaloa Cartel Justin Gray admits stealing now 28 of the 337 Derringer horses, many of which are Derringer babies as a coward scum Cartel person attacking Derringer by attacking innocent, and vulnerable baby horses in an attempt to violate Derringer owner by attempting ransom/extortion to gain additional money, but really to show the domestic terrorism he can inflict on another by choosing baby horses to abuse and violate.

97) The worst crime of all Defendants is the Sinaloa Cartel conspiracy and collusion these domestic terrorism Defendants; have against not only Derringer, but all the Americans dying of fentanyl, forced slavery and prostitution, murders, beatings, beheadings, larceny and robbery and many crimes against not only New Mexican civilian US Citizens, but nationwide due directly of all named Defendants being traitors assisting the invading Mexican National Sinaloa Cartel, in violation of the 14th Amendment Section 3 aiding and abetting, facilitating, providing protection and comfort to all the Sinaloa Cartel, MS-13 and multinational criminals invading to destroy America.

WHEREFORE Derringer therefore demands punishment of $25,000,000.00 ($25 Million) each from Sinaloa Cartel domestic terrorists Justin Gray, Manuel Monte, Benjamin Benavidez Jr. of $10,000.000,000.00 ($ Ten Million Dollars) from each individual complicit as private citizens and Court costs and any and further punishment for being TRAITORS AGAINST AMERICA IN COLLUSION WITH THE INVADING MEXICAN NATIONAL SINALOA CARTEL, as deemed just and appropriate by the Court.

COUNT-9 CONSPIRACY, COLLUSION, FACILITATION OF CRIMINAL ACTS;

98) Plaintiff adopts and incorporates by reference herein paragraphs 1-97 of the complaint as if set forth in full.

99) Each Sinaloa Cartel Defendant solely and separately has entered into the conspiracy with collusion of all acts of the whole operation also all acts participated willingly of all Defendants for power, money, racist crimes, hate crimes, targeting Derringer, exuberance in ruining the life of another to kill, act without morality, without ethics, do evil to both persons and animals in violence, hatred, and horrendous crimes against humanity itself for personal gain in esteem, power and ego.

100) Each horse represents tens of thousands of dollars by breeding fees of a stallion, live foals of a mare, hourly income if used for trail rides, hunts, events, or horse lessons and more. Thus each horse represents from $60,000.00 to over $200,000.00 income in their lifetime of 30 years stolen by each Sinaloa Cartel Defendant in treason, hate crimes and persecution against Derringer as a “targeted” individual whistleblowing on the extreme long term corruption in the State of New Mexico now owned by the Sinaloa Casrtel.

WHEREFORE Derringer therefore demands punishment of $25,000,000.00 ($25 Million) each from each Sinaloa Cartel Defendant separately and distinctly from each as private personal citizens as individuals complicit in each crime herein described and Court costs and any and further punishment for being TRAITORS AGAINST AMERICA IN COLLUSION WITH THE INVADING MEXICAN NATIONAL SINALOA CARTEL, as deemed just and appropriate by the Court.

COUNT-10 MENTAL ANGUISH AND EMOTIONAL DISTRESS

101) Plaintiff adopts and incorporates by reference herein paragraphs 1-100 of the complaint as if set forth in full.

102) The Sinaloa Cartel Defendants have been rustling Derringer horses over a period of the last 9 years. In the last 7 years, Derringer has caught some “red handed” with Derringer horses locked up or recovered stolen horses trailered to horse killer DC Livestock in Los Lunas. Derringer has known of horse killer Chavez for 40 years and despised his horse slaughter as do others; where most of his horses are stolen illegally by some alleged authorities falsely claiming “strays” or come from the horse rustling Sinaloa Cartel ring named Defendants above and others with the blessing and deliberate failure of the NM law enforcement community.

103) Derringer has inherent rights, immunities and privileges in the United States under the US Constitution.

104) Derringer has inherent God given rights to own and have full control of his personal property, which also entails the right to keep safe and protect his living animals as family and pets. Emotional extortion, sadistic, vile, and satanic torture to endeared Derringer pets, bonded souls and personalities being stolen by Defendants are to be sent to Mexico butchered for “meat”.

105) All Defendants have converted personal property and tangible assets of Plaintiff Derringer to unjust enrichment for Sinaloa Cartel scum by rustling.

106) All Defendants have converted personal property and tangible assets of Derringer to extinction by a conspiracy and collusion with others to kill, dismember, torture, and butcher Derringer animals of then no use to anyone, done in hate crimes, racist crimes, death threats and vicious enjoyment of murder.

107) All Defendants have taken and deprived Derringer the enjoyment and love of his animals as pets and destroyed the use as trade tools, use as income, use as assets, use of companionship and love of them as “pets”.

108) Derringer has had horses as part of his life since 7 years old.

109) Derringer’s horses comprise working animals for income as “trade tools”, companions for personal enjoyment and recreation, income in sales, breeding and selling select animals, use of domestic chores of farming, hunting, game retrieving, packing camps, teaching riding and horse care, and are considered “family” and each animal is also a cherished PET.

110) Derringer selects, trains and keeps his own herd of animals considered special and never for sale that are intermixed at this time with other animals on the Pajarito.

111) All Defendants in conspiracy and collusion with others have stolen Derringer horses, killed several, abused many, and may be selling to horse killers whereas treasured Derringer horses will be wantonly slaughtered for meat.

112) Extreme emotional trauma exists with the fears that the stolen Derringer animals will possibly be killed, abused and harmed as has already been done by the all and select Defendants in cahoots with others.

WHEREFORE Derringer therefore demands punishment of $25,000,000.00 ($25 Million) each from each Sinaloa Cartel Defendant separately and distinctly from each as private personal citizens as individuals complicit in each crime herein described and Court costs and any and further punishment for being TRAITORS AGAINST AMERICA IN COLLUSION WITH THE INVADING MEXICAN NATIONAL SINALOA CARTEL, as deemed just and appropriate by the Court.

113) Plaintiff adopts and incorporates by reference herein paragraphs 1-112 of the complaint as if set forth in full.

114) If the acts of all the Defendants have been lawful, those acts also have been intentional acts.

115) Each of these acts was intended to injure the Plaintiff, and the Plaintiff has been injured by each act of all of the Defendants and their facilitation of co-conspirators, and Plaintiff Derringer has been damaged thereby financially, emotionally, and physically with medical problems traced to the stress caused by all of the Defendants.

116) Each of these acts was intended to injure the Plaintiff, and the Plaintiff has been injured by each act of all of the Defendants, and has thus been damaged thereby.

117) All of the Defendants had no justification or insufficient justification for taking these acts.

118) The conduct of all of the Defendants was done with malicious intent, reckless endangerment, and in willful and in reckless disregard of the rights of the Plaintiff.

119) All attempts to resolve these issues have been met with violence, criminal acts, and deprivations without conscience and despite exhaustive reporting this to every New Mexico agency, NMAG and Governor Grisham with no resolution whatsoever.

WHEREFORE the Plaintiff requests that this Court enter judgment against all the Defendants of all counts for damages claimed in amounts secured by both facts and law to be proved at trial, sanctions and damages and exemplary damages for deterrence that are indicated, and such other and further relief as the Court deems just and proper. There can be no quarter, sympathy, relief, leniency, for Sinaloa Cartel thugs that prey on United States citizens whether they be the actual Cartel invaders or the scum of the citizen domestic terrorists Defendants herein supporting the protecting the invading Mexican National Sinaloa Cartel in treason against America to assist and facilitate a world-wide mafioso crime syndicate invasion of foreign Mexican Nationals, MS_13, and 140 other country criminals that are insurgents against America to attack and facilitate the invasion against the United States of America.

Respectfully submitted by ___________________________________________

David Derringer Pro-Se Box 7431, Albuquerque, New Mexico 87194


VERIFICATION


STATE OF NEW MEXICO )

) ss.

COUNTY OF BERNALILLO )


I, David Derringer, being first duly sworn, upon my oath state that I have knowledge and have read the foregoing Complaint and know the contents thereof, and that the statements contained therein are true to my knowledge, except for those statements made on affirmation and belief, which I believe are true.


_____________________________________________David Derringer


SUBSCRIBED AND SWORN to before me on ________________, ______, 2023 by David Derringer.




(Seal)




My Commission Expires: __________________



__________________________________________________

NOTARY PUBLIC



BERNALILLO COUNTY

SECOND JUDICIAL DISTRICT COURT

CV-2023-09203

David Derringer,

Plaintiff,

V.

Sinaloa Cartel domestic terrorist private citizen Benjamin Benavidez Jr.,

Sinaloa Cartel domestic terrorist private citizen Justin Gray (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment),

Sinaloa Cartel domestic terrorist private citizen Manuel Monte (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment),

Defendants,


COMPLAINT FOR 11 COUNTS: COUNT 1-INJUNCTION; COUNT-2 REPLEVIN/REPARATIONS UNDER NMSA 42-8-1 and NMSA 29-1-2; COUNT-3 LOSS OF INCOME, UNJUST ENRICHMENT, CONVERSION OF PERSONAL PROPERTY/LARCENY; COUNT-4 FRAUD, CONSTRUCTIVE FRAUD, FRAUD ON THE COURT, FRAUD IN THE INDUCEMENT; COUNT 5-CIVIL RIGHTS DEPRIVATIONS OF THE 1ST, 4TH, 5TH, 8TH, 9TH, 10TH, 13TH, AND 14TH AMENDMENTS AND VIOATIONS OF THE BILL OF RIGHTS, AND PERSONAL PROPERTY RIGHTS UNDER 42 USC 1982; COUNT-6 HARASSMENT, OBSTRUCTION OF JUSTICE, INTIMIDATION; COUNT-7 DOMESTIC TERRORISM, HATE CRIMES AND RACIST HATE CRIMES; COUNT-8 CIVIL REDRESS FOR CRIMINAL ACTS; COUNT-9 CONSPIRACY, COLLUSION, FACILITATION OF CRIMINAL ACTS; COUNT-10 MENTAL ANGUISH AND EMOTIONAL DISTRESS; COUNT-11 PRIMA FACIE TORT


ADDENDUM EXHIBITS

To date Defendants’ Justin Gray, Manuel Monte and Benjamin Benavidez Jr. have stolen 337 + Derringer owned horses lifetime value $100,000.00 each wherein each horse stolen/converted is criminal felony larceny under NMSA 30-16-1.

EXHIBITS 1

















EXHIBIT 2


Respectfully submitted by ____________________________________

David Derringer Pro-Se Box 7431 Albuquerque, New Mexico 87194

 
 
 

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