TREASON AND DOMESTIC TERRORISM OF NEW MEXICO LIVESTOCK BOARD; LARCENY AND FALSE CRIMINAL COMPLAINTS

STATE OF NEW MEXICO

BERNALILLO COUNTY

SECOND JUDICIAL DISTRICT COURT

CV-2023-07042

David Derringer,

Plaintiff,

V.

Benjamin Benavidez Jr., Benavidez Ranch, Benavidez Ranch Employee John Doe [Exhibit 1] [1], private New Mexico citizen Justin Gray (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-MANDATED COMPLIANCE TO NMSA 77-16-1 AND NMSA 77-16-4; 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., Benavidez Ranch, Benavidez Ranch Employee John Doe [Exhibit 1], private New Mexico citizen Justin Gray (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment) all working with the Sinaloa Cartel doing 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 Benjamin Benavidez Jr. is located at 9701 Volcanes Rd. NW Albuquerque, New Mexico 87121.

9) Invading Mexican National Sinaloa Cartel member employees domestic terrorists on Benavidez Ranch are located at 9701 Volcanes Rd. NW Albuquerque, New Mexico 87121.

10) Invading Mexican National Sinaloa Cartel member domestic terrorist Benavidez Ranch Employee John Doe [Exhibit 1], is located at 9701 Volcanes Rd. NW Albuquerque, New Mexico 87121.

11) 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.

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

GENERAL ALLEGATIONS COMMON TO ALL COUNTS

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

14) 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 77-16-7) well known to the Defendants private citizen Justin Gray and wherein it was Benjamin Benavidez Jr.’s 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 Benjamin Benavidez Jr., Benavidez Ranch, Benavidez Ranch Employee John Doe [Exhibit 1], trying to claim any “trespass” of any livestock that might gain access to the “then open range” of the Santolina re; NMSA 77-16-3. or (NMSA 77-14-1THAT WAS REPEALED)

15) Defendants all know that NMSA 77-16-3 trespass or damages does not apply to the Santolina due to the Pajarito fence in total wrongful construction under statutory mandate and in total disrepair, so the Pajarito fence is not compliant to NMSA 77-16-1 (“but not otherwise”) damages do not apply for the occupants or lessee of the Santolina, nor does any fraudulent claim of “trespass” under NMSA 77-14-1 AS IT WAS REPEALED.

16) 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 Derringer had no legal right to retrieve horses stolen by Defendants Benjamin Benavidez Jr and employees of Defendant Benavidez Ranch since this matter assuring Santolina as “open range” has already been decided by a superior court to this one, the New Mexico Court of Appeals No. 12-8853.

17) Benjamin Benavidez Jr. does not own the Santolina lands, but is leasing the land (Santolina) wherein the lease of Benjamin Benavidez Jr. and the private entity of Benavidez Ranch with the Garrett Development Corporation developing the Santolina has a very specific clause that Benjamin Benavidez Jr. and the private entity of Benavidez Ranch is mandated to maintain the 4+ miles of Pajarito fence line East/West dividing the Santolina from the Pajarito in full compliance with New Mexico State law NMSA 77-16-1; that being construction as specified by NMSA 77-16-7, whereas, since Benjamin Benavidez Jr. and the private entity of Benavidez Ranch does not comply with the contract, 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. and the private entity of Benavidez Ranch does not have a valid grazing contract, whereas with breach, the contract is mute and void. The Sinaloa Cartel persons and Defendant private citizen traitor Justin Gray assist Benjamin Benavidez Jr. and the private entity of Benavidez Ranch criminally steal Derringer horses in larceny and lock horses up not belonging to Defendants Benjamin Benavidez Jr. and the private entity of Benavidez Ranch depriving those horses of water is criminal animal abuse, both acts felonies “per horse”.

18) To protect the Sinaloa Cartel horse rustling (larceny) and Sinaloa Cartel members Defendants Benjamin Benavidez Jr. and the private entity of Benavidez Ranch, Sinaloa Cartel member Justin Gray, employee John Doe and others allow deceit to allege that the horses Defendants Benjamin Benavidez Jr. and the private entity of Benavidez Ranch lock up and then steal and trailer to horse thief Dennis Chavez in Los Lunas are “wild horses” and “estrays” (stray horses). Defendant Sinaloa Cartel NM citizen Justin Gray has lied under Oath the horses accessing the Santolina alleged grazing permit of Defendants Benjamin Benavidez Jr. and the private entity of Benavidez Ranch, are “estray” stray horses where all above Defendants already know the horses having easy access to the Santolina are Derringer’s horses they are stealing belonging on the Pajarito open range wherein is the Derringer residence and the water for these horses.

19) The Defendants and all others have full knowledge that any horses that get onto the Santolina are not owned by the Defendants Benjamin Benavidez Jr. and the private entity of Benavidez Ranch lock up and then steal the horses as Sinaloa Cartel member Justin Gray also knows the Derringer horses unbranded and others that are branded are not “estray” horses, but Cartel Justin Gray helps the Defendants Benavidez and others steal them in larceny anyway.

20) 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 in cahoots with the entire corruption of the State of New Mexico and NM Judiciary.

21) Sinaloa Cartel domestic scum of Defendant Justin Gray knows exactly where Derringer lives, just 250 yards South of the SW corner of the Santolina/Pajarito fence line; Derringer on the Pajarito.

22) Defendant private party citizen Justin Gray cannot mis-use any “connections” to embezzle New Mexico tax dollars to allow any New Mexico state tax paid attorney or other such non-private attorney representation to also be an attorney or represent the individual citizen of Justin Gray or Benjamin Benavidez Jr. nor the private entity of Benavidez Ranch or the John Doe employee of Benavidez Ranch in violation of NMRA 16-107 “conflict of interest”. No presiding Judge in this case is enabled to manipulate the Rules to allow any of this to happen under Canon 3 (B)(2): A judge shall be faithful to the law and maintain professional competence in it. Canon: “Law” “denotes court rules as well as statutes, constitutional provisions, and decisional law.”

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 252+ Derringer horses rustled by the above Defendants and the Cartel with cooperation by some rogue NM employees assisting in the protection or allowing use of state vehicles and trailers to those doing the horse larceny and transport of 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. Any state employees assisting this proven larceny rustling of Derringer horses is by willful facilitation and protection of the Sinaloa Cartel by the deliberate and malicious discharge of duties of the employees working in “moonlighting” as bribed Sinaloa Cartel protection.

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 15, 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) and Benavidez Ranch illegal alien non-citizen employees, Defendant John Doe, and other known Sinaloa Cartel members as the compound of Hector Cabrera, Mier Pedro, Manuel Monte, Justin Gray, Karla and Ernest Martinez, Isidro Ruis Saenz, Isaas Compos, and others that have right now several Derringer horses locked on their Pajarito property. Statutory mandates of NMSA 77-9-22(F) are to arrest, prosecute and recover the stolen horses under NMSA 29-1-2, but all NM law enforcement is bribed by the Sinaloa Carte to discharge duties to protect the Cartel instead. Since the invading Mexican National Sinaloa Cartel is an invading foreign body of subversives as enemies against of the United States, all Defendants aiding, abetting, facilitating, protecting these invaders are traitors to the United States of America.

25) Defendants above are great friends with Dennis Chavez, Southwest Event Center LLC, D.C. Livestock Auction, Southwest Livestock Auction, located at 24 Dalies Rd. Los Lunas, New Mexico 87031, for over 40 years serving as the “fence” for stolen NM horses

26) NM citizens are mandated to obey the laws under NMSA Title 30.

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.

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 legal 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 has been totally in disrepair and non-compliant with NMSA 77-16-1 for 110 years, as the dividing line between the Pajarito open range, and the Santolina development area wherein Benjamin Benavidez Jr. and Benavidez Ranch have the “grazing permit” controlled by contract with the owners of the Santolina Development LLC. Benavidez Ranch is mandated legally under their grazing contract to maintain the Pajarito fence to NMSA 77-16-1 Statutory compliance, which they never have.

32) 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.

33) All Defendants Benavidez Jr. and ranch, know 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 case was Bernalillo County Commissioners v. Ivan Benavidez (the Uncle of Benjamin Benavidez Jr..)

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

35) All livestock horses on the Pajarito are owned by some person; there are no wild horses no “estrays” or Mustangs on the Pajarito 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.

36) Sinaloa Cartel citizen Justin Gray is proven to steal Pajarito horses with the Benavidez’ by collusion to get the horses on the Santolina and them lock them up and trailer them away. Justin Gray get the Sinaloa Cartel bribe drug and human trafficking money, use of Cartel prostitutes, use of drugs, and many other kickback sales of stolen horses and other perks, all for paid protection for the invading Mexican National Sinaloa Cartel, against all rule of law in New Mexico and as a traitor to the United States.

37) The invading Mexican National Sinaloa Cartel members Benavidez (plural), Cartel citizen Justin Gray and the direct witnessed Sinaloa Cartel connections of Justin Gray has been personally witnessed by Plaintiff David Derringer.

38) Derringer has an extreme numbers of photographs of Benavidez Jr. and employees of Benavidez Ranch locking up Derringer horses deliberately inside the Santolina fence line and in permanent pens of wood/steel inside the Santolina as proven “intent” of larceny, wherein also Derringer is witness to Benavidez, and Sinaloa Cartel loading and trailering such horses to Dennis Chavez in Los Lunas, NM.

39) In defining action, Benavidez Ranch employee John Doe [Exhibit 1] was deliberately locking in Derringer horses, when Derringer was going by the SW corner of the Santolina. Benavidez Ranch employee John Doe had Derringer horses behind him, while closing the barbed wire to prevent their escape to capture them. Derringer yelled at the man to immediate release Derringer’s horses to their home on the Pajarito. The man replied “they are not your horses, they belong to county” and would not open the fence to release them in witnessed larceny. Point of fact is that Benjamin Ranch thus knowingly admitted (although a false statement wherein “county” owns no horses on either the Santolina or Pajarito) that the horses just locked up by John Doe and thus both stolen (NMSA 30-16-1) and deprived as captured to deny access to water (NMSA 30-18-1) (2 felonies for each horse) were knowingly NOT HORSES OWNED BY BENAVIDEZ RANCH under NMSA 77-9-22(F)..

40) 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.

41) David Derringer is the lawful owner of over 300+ horses with about 42 new babies in 2023. Now the Sinaloa Cartel has stolen in larceny over 252+ horsesl

42) In July, 2023 Benjamin Benavidez Jr. and Justin Gray stole another 9 horses last seen locked in larceny at the SW corner of the Santalina, which included a small herd of 5 of Derringer’s 2 Paint horses. [Exhibit 2]

43) On or about August 23 Sinaloa Cartel Justin Gray admitted to stealing a herd of 13 Derringer horses, deliberately stealing in that herd 8 Derringer baby horses less than 1 year old, most babies of that herd being less than 6 months old. Justin Gray knows the 13 horses belong to only Derringer as the Cartel scum citizen posted a ransom/extortion note demanding thousands of dollars to be able to get the horses back, by Justin Gray trespassing to Derringer’s front door, identifying the horses 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. These Derringer horses were not further identified by the horse thief Justin Gray with markings or photos because Justin Gray knows that David Derringer would know exactly which herd they are and that they’re his and demand for extortion/ransom of $thousands to get them back.

44) The horse larceny of Justin Gray on or about August 23, 2023 was domestic terrorism, retaliation, retribution, revenge in a well-executed plan of John Doe locking the 13 horses in the perimeter Santolina fence, then herding to them to the permanent pens in the middle of the Santolina, then criminal Sinaloa Cartel Justin Gray trailering the Derringer stolen horses to a place unknown by victim Derringer so as to effect the ransom/extortion demand of $thousands of dollars to get them back, also demanding the money at a deadline. Sinaloa Cartel Justin Gray only posted the ransom/extortion note on the Derringer front door, falsely claiming the 13 horses as “strays” wherein Gray did not post the ransom note to any other as he knows the 13 horses are owned by Derringer.

45) All Derringer horses on the Pajarito Mesa on open range as both descendants of former 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.

46) All Derringer “working herd” of 32 well trained horses Derringer used for income from outfitting hunts, trail rides, pack trips and other training have all been now stolen, wherein all of the “wording herd” can 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.

47) 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.

48) 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.

49) 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.

50) As of date July 27, 2021, the Cartel started rustling Derringer horses, killing, abusing and mutilating in cahoots with Defendant Justin Gray for “protection”.

51) Sinaloa Cartel Benjamin Benavidez Jr. and Benavidez Ranch are and have been stealing Derringer horses since 2014 (documented and confessed) wherein they allow or chase them 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 and sale to Dennis Chavez in Los Lunas, NM.

52) Owner Derringer has been interfering with the Benavidez horse rustling by seeing his horses locked up with Benavidez, and physically releasing and rescuing Derringer’s personal property deprived of water, enabled thus to get HOME.

53) 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.

54Sinaloa 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 3]

COUNT 1-INJUNCTION

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

55) Defendants of Benavidez, Justin Gray and all Sinaloa Cartel 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 “confessed” to stealing 13 Derringer horses fraudulently claiming them strays, yet posted a note of ransom/extortion by trespass to the front door of the Derringer residence, proving without doubt that he obviously knows the horses belong to the victim of the larceny Derringer, as he posted the extortion note to none other.

56) Sinaloa Cartel Justin Gray posted the extortion/ransom note on Derringer’s front door with posted no trespassing/do not enter signs and doing harassment, stalking and larceny, abuse of animals, killing and torturing and death threats against Plaintiff David Derringer.

57) All Defendants have been in complicity and conspiracy to steal in grand larceny now over 252+ 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.

58) All Defendants has 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 over the last 20 years and now have done obstruction of justice, intimidation and instigated false reports as criminal acts under NMSA 30-39-1 so as to gain false criminal complaints of those filing in criminal acts under penal code 118.1l, 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.

59) 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.

60) 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 Derringer horses back to the Pajarito unharmed under mandates of replevin.

61) 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.

COUNT-2 REPLEVIN/REPARATIONS UNDER NMSA 42-8-1 and NMSA 29-1-2

62) Plaintiff adopts and incorporates by reference herein paragraphs 1-61 of the complaint as if set forth in full.

63) 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, yet protect the rustlers from arrest, and prosecution by fraud and bribery schemes.

64) Defendants are personally material witnesses to the crimes against Derringer or having done the crimes themselves to Plaintiff Derringer; whereas in several instances the Plaintiff was a witness to the Defendants doing crimes or that criminal Cartel Justin Gray noted he stole the latest 13 horses by claiming they were strays and posting a ransom/extortion note on the front door of the known owner David Derringer.

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

66) The 13 horses identified by the Sinaloa Cartel rustler Justin Gray ransom/extortion note posted on Derringer’s front door have to be instantly and immediately returned to Derringer while Derringer is there to inspect that all 13 horses are unharmed as 8 of the 13 are Derringer’s baby horses of recent 2023 birth. Rustler Justin Gray will pay owner Derringer $100,000.00 for each of the 13 identified horses noted in his extortion/ransom note posted on Derringer’s door for any of those horses missing.

67) All 252+ 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, as were stolen horses, in restoration.

68) 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.

69) Defendants all have tenable ways to get Derringer horses returned and the state has a mandatory statutory duty to recover and return the Derringer horses immediately unharmed under NMSA 29-1-2 as notified.

70) Now, there have been stolen over 252 + and more each day of Derringer horses, by baiting and trailering plus (+) 2 shot and killed, 3 babies killed, “Crescent” stolen three times, Derringer buckskin stolen twice, and at least one horse mutilated and gelded, one baby severely mutilated, tortured, and dismembered and used as a death threat against David Derringer. [Exhibit 3]

WHEREFORE Derringer DEMANDS under NMSA 42-8-1 that every stolen horse be returned immediately unharmed by statutory mandates of NMSA 29-1-2. 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 $60,000.00 per horse stolen and an amount of additional punitive damages of $100,000.00 per horse for the larceny itself with a $25,000.00 extra punishment if the horse as a Derringer pet is killed and butchered for meat.

2. Derringer claims a value of $200,000.00 for every horse killed and wherein any horse not returned assumed dead for this amount from each Defendant.

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

4. All horses stolen by the NMLB as strays and all horses stolen by the Cartel are mandated to be returned to the Pajarito from whence they came.

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

6. 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.

7. 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.

8. Derringer claims the amount in addition of $100,000,000.00 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 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.

9. These amounts will increase if the Defendants touches or steals any remaining horses.

COUNT-3 LOSS OF INCOME, UNJUST ENRICHMENT, CONVERSION OF PERSONAL PROPERTY/LARCENY;

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

72) Defendants have now stolen “ongoing” over 252 + 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 Defendant Citizens Justin Gray by his latest attempt of unjust enrichment by extortion/ransom with a note posted on Derringer’s front door demanding $thousands of dollars before a specific date or Derringer won’t get his horses back, killing them or falsely selling them claiming “strays”.

WHEREFORE Derringer demands punishment, replevin, and severe exemplary damages of $10,000.000.00 ($ Ten Million Dollars) from each Defendant separately and distinctly from each Defendants Benjamin Benavidez Jr., Benavidez Ranch, Benavidez Ranch employee John Doe [Exhibit 1] and $50,000,000.00 ($ Fifty Million Dollars) from Sinaloa Cartel Justin Gray as he admitted to stealing 13 Derringer horses falsely claiming strays, yet posted a demand for extortion/ransom of known owner David Derringer’s front door (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment) 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-4 FRAUD, CONSTRUCTIVE FRAUD, FRAUD ON THE COURT, FRAUD IN THE INDUCEMENT

73) Plaintiff adopts and incorporates by reference herein paragraphs 1-72 of the complaint as if set forth in full.

74) All 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 expose the vast NM public and judicial corruption. in which government officials act “in concert” with agreement with the Sinaloa Cartel.

75) 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.

76) 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.

77) 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.

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

WHEREFORE Since the conspiracy is well established, 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 Defendants Benjamin Benavidez Jr., Benavidez Ranch, Benavidez Ranch employee John Doe, Sinaloa Cartel citizen Justin Gray (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment) 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-MANDATED COMPLIANCE TO NMSA 77-16-1 AND NMSA 77-16-4

79) Plaintiff adopts and incorporates by reference herein paragraphs 1-78 of the complaint as if set forth in full.

80) All Defendants as 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 and animals having access to the Santolina by false and fraudulent attempted use of NMSA 77-14-3 whereas that statute makes it very clear that without total compliance with NMSA 77-16-1 AND 77-16-4, which 4+ miles of the Pajarito fence line, dividing the open range private lands of the Southern Pajarito from the Northern Santolina have been dilapidated for 110 years and never were and are in no way now compliant with NMSA 77-16-1 AND 77-16-4.

81) Defendants willfully and deliberately use the dilapidated Pajarito fence line for the ongoing RICO racketeering Sinaloa Cartel rustling industry of larceny of horses and cattle.

82) Defendants use the Pajarito fence line as a tool and vehicle to knowingly allow horses access to the Santolina by deliberate and malicious non-compliance with NMSA 77-16-1 AND 77-16-4 even though the Benavidez Jr. grazing contract with Garret Development of the Santolina mandates compliance with NMSA 77-16-1 and 77-16-4.

83) Defendants knowingly allow and physically watch horses not owned by any Defendants enter the Santalina through, under, or over places of low wires, places with no wires, places with few wires or only one wire to duck under, and then when horses are inside the Santolina perimeter fence, Defendant John Doe and others place more wire where horses enter so as to willfully trap and capture the horses without their ownership and without means to use NMSA 77-14-3 as any legal means of claim.

84) The latest larceny was Defendant Justin Gray working with the other Defendants wanting deliberately to capture, steal, known Derringer herd of 13 horses, mainly babies, to then post a ransom/extortion note on Derringer’s door falsely and in fraud claiming vast amounts of money to return Derringer’s horses, lying that they were “strays” that he took from the Santolina falsely claiming trespass under NMSA 77-14-3.

85) Justin Gray maliciously performed multiple felonies PER HORSE of illegal capture, illegal herding of not owned horses, illegal forced detainment of larceny, containment in locked pens without food or water in animal abuse4, illegal transport of stolen horses to an unknown place, concealment of stolen horses, possession of stolen property, extortion/ransom note to known owner falsely claiming possession in fraud claiming “trespass” under false pretenses of NMSA 77-14-3, as domestic terrorism, collusion, conspiracy, and treason against the United States whereas this is done to facilitate, protect and do RICO racketeering livestock rustling with the invading Mexican National Sinaloa Cartel.

86) Defendants and the Cartel make vast amounts of $hundreds of thousands of dollars illegally rustling Derringer horses, transporting stolen horses to Mexico to be slaughtered for meat of each horse 1,200# selling for $12.00 per pound with bribes, kickbacks and perks going to Defendants for their participation and “protection” of the Sinaloa Cartel.

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 requests Court Order demanding relief mandating all Defendants within 20 days of such Order to construct the Pajarito fence line starting at the SW corner of the Santolina going East 4+ miles to the statutory mandated specifications of NMSA 77-16-1 and NMSA 77-16-4, wherein if not finished in 20days Order sanctions against each Defendant separately and distinctly from each Defendants Benjamin Benavidez Jr., Benavidez Ranch, Benavidez Ranch employee John Doe, Justin Gray (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment) in an attempt to mitigate the ability of these Defendants to keep stealing Derringer horses with the former selective use of a non-compliant fence as a tool for horse rustling and 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 manufacturing INTENT to gain false arrest, false imprison goes well beyond the obvious ploy to enable physical larceny of horses, but in racist crimes, RICO, obstruction of justice, harassment and intimidation to stop the Derringer Pro-Se court actions.

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 Defendants Benjamin Benavidez Jr., Benavidez Ranch, Benavidez Ranch employee John Doe, Justin Gray (as an individual NM citizen precluded attorney representation by use of NM tax dollar fee payment) 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-7 DOMESTIC TERRORISM, HATE CRIMES AND RACIST HATE CRIMES

89) Plaintiff adopts and incorporates by reference herein paragraphs 1-88 of the complaint as if set forth in full.

90) All Defendants were involved in the latest conspiracy of Sinaloa Cartel Justin Gray to deliberately steal an additional 13 Derringer horses by gaining the false report of Benavidez to then have created a false criminal Complaint against Derringer in attempt to get Derringer in jail to then be able to take all the horses.

91) The plan was to steal 13 horses knowing they are Derringer’s, then get $ thousands’ of dollars in ransom/extortion falsely claiming stray horses, yet posting the ransom note on the front door of Derringer, knowing Derringer is the owner and then attempting to make a knowingly false Complaint to try to jail Derringer.

92) The false report turned into a known false criminal complaint in fraud on the court took away Derringer’s 5th, and 14th Amendment rights in denial of due process and equal protection, did 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 Justin Gray, and $25,000,000.00 ($25 Million) each from those participating eagerly of from each individual complicit of Benjamin Benavidez Jr. and each of Benavidez Ranch, Benavidez Ranch employee John Doe, 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 1-92 of the complaint as if set forth in full.

93) All 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.

94) Defendants and the Sinaloa Cartel have stolen over now 252 + 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 Ranch. 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 3] dismembered to threaten and intimidate Derringer with mutilated body thrown at the Derringer residence.

95) 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 steals 13 Derringer horses, 8 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.

96) The worst crime of all Defendants is the domestic terrorism 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 terrorist Justin Gray; $10,000.000,000.00 ($ Ten Million Dollars) from each individual complicit citizen of Benjamin Benavidez Jr. and each of Benavidez Ranch, Benavidez Ranch employee John Doe, 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;

97) Plaintiff adopts and incorporates by reference herein paragraphs 1-96 of the complaint as if set forth in full.

98) Each 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.

99) 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 Defendant in treason, hate crimes and persecution against Derringer as a “targeted” individual whistleblowing on the extreme long term corruption of the NMLB..

WHEREFORE Derringer therefore demands punishment of $25,000,000.00 ($25 Million) each from Sinaloa Cartel domestic terrorist Justin Gray; $10,000.000,000.00 ($ Ten Million Dollars) from each individual complicit citizen of Benjamin Benavidez Jr. and each of Benavidez Ranch, Benavidez Ranch employee John Doe, 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

100) Plaintiff adopts and incorporates by reference herein paragraphs 1-99 of the complaint as if set forth in full.

101) The Cartel and 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 ring named Defendants above and others with the blessing and deliberate failure of the NM law enforcement community.

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

103) 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”.

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

105) 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.

106) 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”.

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

108) 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.

109) 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.

110) 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.

111) 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 Sinaloa Cartel domestic terrorist Justin Gray; $10,000.000,000.00 ($ Ten Million Dollars) from each individual complicit citizen of Benjamin Benavidez Jr. and each of Benavidez Ranch, Benavidez Ranch employee John Doe, 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-11 PRIMA FACIE TORT

112) Plaintiff adopts and incorporates by reference herein paragraphs 1-111 of the complaint as if set forth in full.

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

114) 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.

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 has thus been damaged thereby.

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

117) 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.

118) All attempts to resolve these issues have been met with violence, criminal acts, and deprivations without conscience and despite reporting this to the very agency NMLB designed to stop it, and criminal reports to BCSO, VCSO, NMSP, Governor Grisham and to the NM AG no action to stop any of this is happening due to the very people a citizen has in state agencies to stop these criminal acts are the very people as public employees doing all the crimes and conspiracy with the known criminals.

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 Santolina Cartel thugs that prey on United States citizens whether they be the actual Cartel invaders or the scum of the citizen domestic terrorists 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

[1] Benavidez Ranch Employee John Doe [Exhibit 1] name unknown will be found in Court Discovery