FILE_________.
DEFENDANT: JESÚS RAMON BERNAL
WARRIOR
CRIME: EXTORTION
C. FIFTH JUDGE OF FIRST INSTANCE
FROM THE PENAL BRANCH.
PRESENT
JESUS RAMON BERNAL GUERRERO, in my
character of processing and other general details duly accredited in
the criminal case recorded in the section, before you C. Judge respectfully
I appear and state:
That by means of this writing in accordance
with the provisions of article 20 of the political constitution of the
Mexican United States, enciso A, fraction IX, I come before you with the
I designate C. Lic. RODOLFO as my private defender.
SANCHEZ GOMEZ, with an address to hear and receive all kinds of
notifications at the house marked with the number 217 located at
stroller unit of the Fraccionamiento Puesta del Sol in this city, to
who requested to be informed of the appointment made in his favor for
effect of the acceptance and protest of the conferred position
Hereby revoking any appointment.
made in advance
Likewise, I should be considered present.
offering in my favor the following evidence:
EXPANSION OF DECLARATION TO ME
CARGO.-( JESÚS RAMON BERNAL GUERRERO) consisting of the
statement that I will issue personally and directly according to the
interrogation that my lawyer formulated on the day and time that this
the tribunal shall designate for that purpose
,
Based on the above and founded A
YOU C. JUDGE, I RESPECTFULLY REQUEST
FIRST.- Let it be considered present
designating as my private defender the professional referred to in the
body of this course revoking any appointment made with
precedence:
SECOND.-Thus I am also to be considered as
present offering within I determine the evidence to which it refers
mention in the present petition
.
I protest the necessary.
Mazatlán Sinaloa, May 3rd of the year
2007
EXP.73/08
Processed.- RAMONA
IBARRA TIRADO
OFFENSE.- INJURIES
C. SECOND JUDGE OF FIRST INSTANCE
FROM THE CRIMINAL BRANCH.
PRESENT.
RODOLFO SÁNCHEZ GOMEZ, in my
character of private defender of the accused
RAMONA IBARRA TIRADO, in the noted criminal process to
matter. Before you, Honorable Judge, with due respect
I appear to present
That through this written document of
compliance with the provisions of article 330 of the code
criminal procedures in force, I turn to you by virtue of this in time
in order to offer the following evidence in favor of my defendant.
TESTS
1.- TESTIMONIALS OF GOOD
CONDUCT.- consisting of the statements that IDELFONSO will issue
PRADO CAMACHO and MARIA ANTONIA LOPEZ HERNANDEZ, who
they have their addresses at Angel Flores Street No. 1012 in the center and private street
from lighthouse No 913 in the Juárez colony, both in this city and that they declare in
verbal and direct form in relation to the conduct of my defended, according to the
interrogation that the defense formulates on the day and time that this court serves
set for that effect.
2.- PRIVATE DOCUMENT.- Consistent
in the letters of recommendation and good conduct issued by the CC.
GILBERTO GARCIA GALINDO AND SERGIO CORONADO TAGLE.
Same as I request to be added to the cars of this process so that in their
opportunity produce the legal effects that may apply.
3.- PRIVATE DOCUMENT.
Consistent with the certificate issued by Mr. ISAAC PRADO RUIZ, the
which I request to be added in vehicles so that they may have effects at the appropriate time
legal actions as may be appropriate.
A T T E N T I O N
MAZATLÁN SINALOA A 14 DE JULIO DEL AÑO 2008
LIC. RODOLFO SÁNCHEZ GOMEZ
AMPARO330 /2005
Complaining. Benjamin
AGUIRRE SOURCES
C. NINTH DISTRICT JUDGE
IN THE STATE
PRESENT
RODOLFO SANCHEZ GOMEZ, in my
character of judicially authorized of the complainant
BENJAMIN FUENTES AGUIRRE in the amparo trial
noted to the category, before you C JUDGE with due
I appear to present.
That through this writing in accordance
in accordance with the provisions OF ARTICLE 8 of the political constitution of the
United Mexican States, I come before you with the purpose of requesting that
send me at my expense certified copies of everything that has been done in the
present trial, including the documents attached in their reports
previously justified the C. Second agent of the public ministry of the jurisdiction
common, RESPONSIBLE AUTHORITY INDICATED AS
EXECUTOR IN THE PRESENT GUARANTEES DEMAND, by
I need them for the defense of my client.
For the aforementioned, to you Mr. Judge
I respectfully request.
U N I C O- Please remember to comply with
here requested.
Atentamente
Mazatlán Sinaloa May 19th
year 2005
FILE No 135/1998
Qualified Homicide Crime
PROCESSED.-RICARDO ANGUIANO
Valenzuela
C. FOURTH DISTRICT COURT
CRIMINAL BRANCH INSTANCE
PRESENT
RODOLFO SANCHEZ GOMEZ, in my
character of private defender of the accused
RICARDO ANGUIANO VALENZUELA, in the criminal case
noted to the field before you C. Judge with the due
I respectfully appear to present.
That through this writing I request to set a new date so that
verification of the expansion of the statement that was the responsibility of Mr. ANGEL
ESTEBAN CABRAL ESTRADA (A) EL CABRALILLO who will declare in accordance with
interrogation that I conducted verbally and directly for the defense on the day and time that this
I declare that for this purpose, and under oath to tell the truth, I state that
by virtue of the fact that it is known that said co-defendant is currently in the
municipality of Los Cabos belonging to the state of Baja California Sur, having its
private residence at the house located at the corner of Second Street and Juan Andrés number
2760 from the El Arenal colony. I request in accordance with the provisions of article 46 of the
current code of criminal procedure in the state of Sinaloa is hereby respectfully forwarded to
First-instance judge of the criminal branch on duty in that city for assistance
from this court notify the co-defendant ANGEL ESTEBAN CABRAL ESTRADA IN THE
LEGAL TERMS FOR THE PURPOSE OF PRESENTING BEFORE THIS
COURT ON THE DAY AND TIME SET FOR THE HEARING OF THE
DILIGENCE IN QUESTION.
According to the above mentioned, I respectfully request you, Mr. Judge.
U N I C O.- I ask to be considered PRESENT OFFERING the evidence to which
it is referred to in the body of this writing
Atentamente
Mazatlán Sinaloa a 29 de mayo del año 2006
FILE No 39/2004
PROCESSED JORGE IVAN
TIZNADO SÁNCHEZ
THEFT IN PLACE
INHABITED AND FOR TWO
PERSONAS
C. FIFTH COURT OF FIRST INSTANCE
FROM THE CRIMINAL BRANCH.
PRESENT.
RODOLFO SÁNCHEZ GOMEZ, in my
character of private defender of the accused JORGE
IVAN TIZNADO SÁNCHEZ, in the criminal process recorded at
item. Before you, Judge, with due respect
I appear to present
That by means of this and in virtue of the fact that there is no evidence
pending for resolution, I request that you, Mr. Judge, kindly close the instruction.
in the present process, the files must be made available to the parties for
the legal effects referred to in article 341 of the code of procedures
penalties in effect.
For the reasons previously stated and based, to you, Judge, respectfully
I ask.
UNICO.- Please act in accordance with what is requested here.
A T T E N T I V E L Y
MAZATLÁN SINALOA JUNE 7, 2004
CRIMINAL CASE
39/2004
JORGE IVAN
TIZNADO
SÁNCHEZ AND ANOTHER
ROBO PLACE
INHABITED
C. FIFTH JUDGE OF FIRST INSTANCE
CRIMINAL BRANCH INSTANCE
PRESENT.
RODOLFO SÁNCHEZ GOMEZ, in my
character of private defender of the defendant JORGE IVAN
TIZNADO SANCHEZ in the criminal case in the indicated category, before
You, Mr. Judge, I respectfully appear to present:
Through this means in accordance with
the provisions of article 341 of the code of procedures
penal laws in force in the state of Sinaloa I come to present to
please for my represented the following:
CONCLUSIONS:
That the defense differs from the
accusatory conclusions made against my defense
JORGE IVAN TIZNADO SÁNCHEZ ALIAS THE CHUKY for the
prosecutor who considers him criminally liable
responsible for the commission of the crime of qualified theft
(place inhabited by two or more people), nevertheless that in
ruling on the complaint filed with the public prosecutor's office
by the offended MARLEN GARCIA ZAMUDIO according to page 11 of
the present proceedings, and the affidavits issued by the witnesses
ERICK GABRIEL CERVANTES, DAVID LIZARRAGA LIZARRAGA E
ISABEL NAVA MENDOZA visible on pages 12 to 14.
By virtue of the analysis of the
the mentioned ministerial statements are only suitable
GABRIEL CERVANTES for the defense stated that not
they are personally aware that my client has
participated in the robbery of which they were the object, in addition to that
a contradiction arises between Erick's testimony and
the statement made by DAVID LIZARRAGA LIZARRAGA, already
that the first of those mentioned before this court said
that David showed up at his home to offer him for sale the
watch belonging to him that had just been stolen moments ago
from inside his home and at that moment he did it to him from
knowledge, and it was then that David told him that my
the defendant and his co-defendant had offered it for sale
alluding that the stereo was in his private residence,
while the latter presented themselves to testify upon being
questioned by the defense, he assured that he went to the home
from Erick to deliver the objects (WATCH AND VCR)
since he had previously informed him of the robbery
Now, while it is true that said
the witness continued to assert that the watch and the video cassette recorder
were offered for sale by my client and his co-defendant ISAAC
MONTES CRUZ at his private residence is also true
that this statement is not corroborated with any other
evidentiary medium since when they were examined by the
defense the offended MARLEN GARCIA ZAMUDIO, ERICK
CERVANTES AND ISABEL NAVA MENDOZA in this regard
they stated that they do not personally know since they know
because DAVID LIZARRAGA said so.
Likewise, when the witness ISABEL
NAVA MENDOZA appeared before this court being
the questioned stated that she did not know my defendant JORGE
IVAN TIZNADO SÁNCHEZ nor to the person known
like Chucky since I had never seen it adding
Moreover, when the events occurred, she did not live in the
Francisco Villa neighborhood where the address is located.
offended MARLEN GARCIA ZAMUDIO BUT IN THE COLONY
Mazatlán and if he appeared to testify it is because the offended party
that's how he/she asked for it.
Reasons why this judge to
to enter into assessing this evidence for the purpose of issuing
I did not take the sentence into consideration due to not
meet the demands required by Article 322 of
criminal procedure code being unclear and imprecise
by virtue of leaving doubts about criminal liability
from my client, as stated by the witness ERIKC
Instance: First Chamber
Source: Judicial Weekly of the Federation
Book: CXXIV
Page: 1040
WITNESSES IN CRIMINAL MATTERS. According to logic
legal, the non-contradiction of the testimony determines
its evidentiary efficiency, but if such exists
contradiction, she determines a procedural vice that
nullifies the evidential value of the testimony and
determines the insufficiency of the evidence.
Direct criminal protection 973/54. By agreement of the
First Chamber, dated June 8, 1953, does not
mention the name of the promoter. June 18
1955. Unanimity of four votes. Absent: Genaro
Ruiz de Chávez. Speaker: Rodolfo Chávez Sánchez.
Eighth Era
Instance: Circuit Collegiate Courts
Source: Judicial Weekly of the Federation
Tomo: IV, Segunda Parte-1, Julio a Diciembre de 1989
Page: 548
PREPARED TESTIMONIALS, IF THEY USE TERMS
ALMOST IDENTICAL AND CONTRADICTED BY OTHERS
TESTIMONIES. The statements of those who testify in
A criminal process must be assessed by the body.
jurisdictional attending to the rules contained in the
adjective code of the matter, therefore, if it
they find themselves in contradiction with other means of
evidence gathered during the instruction and also the
witnesses used almost identical terms, that is
sufficient to consider as prepared their
testimonies; consequently they cannot have
no probative value.
THIRD COLLEGIATE COURT OF THE SECOND
CIRCUIT.
Direct protection 395/89. José Ramírez Garatechea. 12
July 1989. Unanimity of votes. Rapporteur: José
Ángel Mandujano Gordillo. Secretaria: Julieta María
Elena Anguas Carrasco.
It is not an impediment to support the
no criminal responsibility of my client JORGE IVAN
corroborated with other means of evidence, which in the case of
concrete does not happen besides not being the only type of test
what exists to demonstrate my criminal responsibility
client, applies the following jurisprudential theses.
Fifth Era
Instance: First Chamber
Source: Federal Judicial Weekly
Volume: LXXXI
Page: 3506
CO-DEFENDANT, VALUE OF THE DECLARATION OF. It is
it is true that the Court has established jurisprudence in the
the sense that the accusation should not be dismissed
what an accused does against another, when not
tries to evade his own responsibility; but it is
it is evident that that sole accusation cannot
to assign full trial value, as they would be stopped from
observe the regulating principles of that test
established in all Procedural Codes
Criminal laws that govern the Republic. The charge arising from
of the co-defendant, it produces evidence, but it is necessary
associate it with others so that together they constitute
complete trial, and if the conviction is based only on the
The imputation of the co-defendant is a violation of guarantees.
Direct criminal protection 3156/44. Bejarano Mendívil
Jesus. August 16, 1944. Unanimity of five
votes. The publication does not mention the name of the
speaker.
Sixth Era
Instance: First Chamber
Source: Federal Judicial Weekly
Volume: Second Part, XXII
Page: 36
CO-DEFENDANT, VALUE OF HIS STATEMENT. The imputation
made by a co-defendant, in general terms it is
ineffective by itself to substantiate a judgment
condemnatory.
Direct Amparo 5691/58. Antonio Cedillo Ramos. June 6
abril de 1959. Cinco votos. Ponente: Rodolfo Chávez
Sánchez.
Seventh Era
Criminal Procedures of the State of Jalisco, the
accusatory statement of a co-defendant, which for the
the accused is equivalent to that of a prosecution witness, deserves
only indicative value and therefore not obstante for
to support a convicting sentence on its own. It is
it is true that this Chamber has assigned value at some point
full evidence to the statement of the co-defendant who does not evade
his responsibility, makes accusations against another; but the
the application of this criterion is specified in cases where
that the applicable legislation does not specify a value
determined by the singular testimony, but not by the case of
the procedural law of Jalisco, which expressly it
consider a presumption. So that if no
evidentiary element confirms the initial statement of the
co-defendant, it is concluded that there is not enough evidence
to condemn.
Direct Amparo 7036/81. Santiago Rodríguez Medrano
and another. June 7, 1982. Unanimity of four votes.
Speaker: Raúl Cuevas Mantecón.
See:
Judicial Weekly of the Federation, Sixth Era,
Second Part:
Volume XXX, page 39, thesis under the heading 'CO-DEFENDANT,'
VALUE OF YOUR SAY.
Volume L, page 13, thesis of the heading 'CO-DEFENDANT,'
APPRECIATION OF HIS/HER IMPUTATION.
Appendix to the Judicial Weekly of the Federation 1917-
1975, Second Part, First Chamber, thesis 55, page
129, under the heading 'CO-DEFENDANT. VALUE OF THEIR STATEMENT.'
Regardless of what has already been stated, your honor should not exceed
although according to the records, the only one found with the objects in his possession
that were stolen from the home of the victim MARLEN GARCIA
ZAMUDIO went to witness DAVID LZARRAGA and when he realized he was discovered since
offered for sale to the husband of the offended, that was when he said that they had been
offered for sale by the co-defendant ISAAC MONTES CRUZ AND MY DEFENSE, for not
There are indications that support this, but if we take into account that JORGE IVAN
TIZNADO SÁNCHEZ, when declaring before the investigative public ministry, did not accept his...
participation in the criminal acts attributed to him despite having declared earlier
for my client and his co-defendant before this court are in the same terms it would seem that
they were written at the same time or that when declaring both had written their
statements, which creates doubt regarding the participation of my defended
in the criminal acts that are the subject of study.
Now then, if your lordship considers
that the elements of evidence that exist in the process are
sufficient to support the criminal charge of robbery with the
qualifiers of a place inhabited by two or more people, thus
As the criminal responsibility of my represented client, I request
that when passing sentence, the minimum penalties be applied to him and he
grants the legal benefits (SUSPENSION BENEFIT)
CONDITIONAL EXECUTION OF THE SENTENCE - SUBSTITUTE
FROM THE PEN) by virtue of the fact that in the records it is found
the good conduct of my defense JORGE IVAN is accredited
TIZNADO SÁNCHEZ since no background was found
penal in the reports required by you to the other
criminal courts of the locality,
Not taking into consideration in the
in my defense, I request that the prosecutor assigned to this
court in its written conclusions on page 11 reverse
final part, as your request aims to surprise this
judge because of the criminal record that was found
the co-defendant ISAAC MONTES CRUZ before the third criminal judge
From this locality, I request that the benefit be denied to my client.
defended for acts not committed by my client
arguing that it poses a danger to society
when in the reports my defense was not found
any proceedings followed before a judicial authority.
For the reasons stated above, it is
I ask your honor that when passing sentence in this process
absolve the client of the charges by the public prosecutor
he is attributed or otherwise the penalties should be applied
minimums that the law provides for these cases granting the
benefits of the law.
For the above reasons and foundations
I kindly request.
U N I C O. - Please serve to confirm
to what is requested here
MAZATLÁN SINALOA AUGUST 5
YEAR 2004
FILE No 29/2006
QUALIFIED HOMICIDE CRIME
PROCESSED. EDGAR GUILLERMO
Sarmiento Castañeda
C. FIFTH JUDGE OF FIRST
CRIMINAL BRANCH INSTANCE
PRESENT
RODOLFO SANCHEZ GOMEZ in me
character of private defender of the accused EDGAR
GUILLERMO SARMIENTO CASTAÑEDA, in the criminal case
noted to the section before you C. Judge with the due
I appear to present.
That through this course based on the provisions of Article 8 of
the political constitution of the United Mexican States I come before you for the purpose of
resign from the position of defender that was granted to me in the current process as it suits me
to my interests
For the above-mentioned reasons, I respectfully request you, Honorable Judge.
U N I C O.- please wake up in accordance with what is requested here
Atentamente
Mazatlán Sinaloa, March 15, 2006
RODOLFO SANCHEZ GOMEZ
FILE No 29/2006
QUALIFIED HOMICIDE OFFENSE
PROCESSED. EDGAR GUILLERMO
Sarmiento Castañeda
C. FIFTH JUDGE OF THE FIRST
Instance of the Criminal Branch
PRESENT
EDGAR GUILLERMO SARMIENTO CASTAÑEDA
in my capacity as an accused and other general information
accredited, in the criminal case noted under the header before
you, Mr. Judge, with due respect, I appear to
expose.
That through this course based on the provisions of the articles
378, 380, 381 fraction II, 382 fraction II and other related provisions of the code of procedures
penalties in force I come before you Mr. Judge with the intention of filing the appeal
appeal against the formal imprisonment order issued against me by this court in
virtue of causing me grievances for considering me as a probable responsible for the crime
of qualified homicide
For the above reasons, I respectfully request you, Honorable Judge.
U N I C O.- Se me tenga por presente interponiendo en recurso de
appeal for the reason already stated in this document
Atentamente
Mazatlán Sinaloa, February 21, 2006
PRELIMINARY INVESTIGATION _________
ALBINO RODRIGUEZ RIVERA
Culpable damages.
The Mixed Agent of the Public Ministry
OF THE COMMON JURISDICTION ATTACHED TO THE MUNICIPALITY
FROM ESCUINAPA IN THE STATE OF SINALOA.
PRESENT
C. ALBINO RODRIGUEZ RIVERA, in my capacity as the offended party and
recognized personality, whose number is mentioned in the section, before you C. Agent with the due
I respectfully appear to present:
Que por medio de este escrito, y con fundamento en el articulo 8 y 20
fraction section B fraction II of the General Constitution of the Republic, 9 of the Code of
Criminal Procedures, 9 and 14 of the Victim Protection Law, both of
State of Sinaloa, we appear to appoint as collaborators of this representation
social alC. LIC. RODOLFO SANCHEZ GOMEZ, and/or P.D. IRIANA ALEJANDRA
MORENO LOPEZ AND MIZRAIN RODRIGUEZ AGUILAR, whom I ask to be given
to know the appointment made in your favor, indicating as your address to hear and receive
notifications located at 127 South Melchor Ocampo Street, Ampliación neighborhood
Benito Juárez, C.P. 82470, of this municipality
For the above mentioned before you, Honorable Social Representative, respectfully
P I D O:
UNICO.- Please provide as requested.
Mazatlán, Sinaloa, October 2, 2009.
____________________________________
ALBINO RODRIGUEZ RIVERA.
EXPEDIENTE: 284/2008
TRIAL: CRIMINAL PROCESS JURISDICTION
COMMON
OFFENSE: QUALIFIED ROBBERY
PROCESSED: LUIS ALBERTO
RUBIO FLORES AND JOSE RAMON
RUBIO FLORES
SUBJECT: THE ONE INDICATED.
C. FIRST JUDGE OF FIRST INSTANCE
OF COMMON JURISDICTION
PRESENT.
C. MARIA DEL SOCORRO FLORES LUGO, Mexican,
of legal age, in a common-law marriage, originally from
Navojoa Sonora and neighbor of this city, residing at
7th of April Street number 128 Rubén Jaramillo neighborhood
city indicating as the address to hear and receive all kinds of
of notifications in the university law firm
autonomous of Sinaloa located in benemérito de las Américas without
old airport number of this city and authorizing for
to Mr. Lic. RODOLFO SANCHEZ GOMEZ, before you Mr.
Judge, with due respect, I appear to present:
Through this writing and in my character of
third party unrelated to the trial, based on article 8.
from our Magna Carta, 472, 473, 475 and other relevant articles of the
Current Code of Criminal Procedure in our Entity
I appear to promote UNSPECIFIED INCIDENT OF
RETURN OF THE VEHICLE that will be specified later,
basing my claim on the following narration of:
EVENTS
1. I, the undersigned, am the owner of a
vehicle of the brand Mitsubishi with serial number
JA7FL24D1JP104948 type pickup model 1988 red color
with license plates TX-91218 from Sinaloa, which
I believe with the original import declaration that
on the attached sheet, the endorsement made in my favor is noted and
that for such purpose
2. I acquired that unit from [Link]
ANGEL SANDOVAL GARATE, as can be inferred from the request of
import that is originally attached to the present
attached sheet shows the endorsement made in my favor with
September 13, 2008
3. under protest of telling the truth
4. However, I have learned that
currently the unit of my property is located at
disposition of Your Honor, by virtue of being in
process some criminal acts of a robbery committed against a
house dwelling, in which my car was secured.
5. But it is necessary to clarify to Your Honor
that the undersigned never lent the unit of my property with
the purpose of committing any crime and I did not have
nothing to do with the facts being investigated, which
I do not know if they happened as they told me or if it is
another truth, but what is certain is that I am foreign to
they, reason for which I request to be given my
unity, accrediting the property with the documents that
attached to this document.
6. As the undersigned, I am a stranger to the
criminal acts that are being processed in this case, it is because of the
that I ask your Honor to order the return of the
vehicle of my property, which must be ordered, because
not doing so would violate my individual rights;
supports the above is the jurisprudence that, to
I continue to transcribe:
No. Registro: 205.282
Jurisprudence
Materia(s):Penal
Ninth Era
Instance: Circuit Collegiate Courts
Source: Judicial Weekly of the Federation and its Gazette
I, April 1995
Thesis: XV.1o. J/2
Página: 89
PUBLIC PROSECUTOR'S OFFICE. ASSET SECURING
PROPERTIES BY HIM, IN THE PREVIOUS INVESTIGATION. a when the
Article 40 of the Federal Penal Code authorizes during the preliminary investigation or
the process, the seizure of the instruments of the crime and the things that are its object
and, furthermore, indicates that the competent authorities will immediately ensure
the goods that could be subject to confiscation; however, for this to
it is necessary for such goods to be included in the
assumptions of said numeral, but when from the records of the case it
note that the owner of the insured property is unrelated to the
preliminary investigation to be conducted against third parties and
No objects related to the crime have been found in the property, even though they exist.
search warrant, the seizure is illegal if the complaining party has no relation
with the offenses attributed to those being investigated, and so it is
it is appropriate to grant the protection against said measure.
Amparo in revision 259/94. Federal Public Prosecutor's Office agent assigned to
Fifth District Court in the State and others. October 14, 1994.
Unanimity of votes. Speaker: Pedro Fernando Reyes Colín. Secretary:
María Elizabeth Acevedo Gaxiola.
Review appeal 285/94. Federal Public Prosecutor's Agent assigned to
Fourth District Court in the State and another. October 27, 1994.
Unanimity of votes. Speaker: Pedro Fernando Reyes Colín. Secretary:
Maria Elizabeth Acevedo Gaxiola.
Amparo in review 308/94. Agent of the Federal Public Ministry assigned to
Sixth District Court in the State and another. November 3, 1994.
Unanimity of votes. Speaker: Raúl Molina Torres. Secretary: José de Jesús
Bernal Juárez.
Amparo for review 95/95. Director General of Control of Secured Assets
from the Attorney General's Office and others. March 24, 1995.
Unanimity of votes. Speaker: Pedro Fernando Reyes Colín. Secretary:
Rubén David Aguilar Santibáñez.
For the reasons stated above to Your Honor
I respectfully request:
FIRST.- The present incident is admitted.
SECOND.- The present matter is resolved outright.
incident in the terms of article 473 of the Code of
Current Criminal Procedures in our Entity and I was
deliver materials from the automotive unit of my property
whose characteristics are specified in the first point of
facts of the present incident.
PROTEST IS NECESSARY
MAZATLAN, SINALOA September 8, 2011
______________________________
MARIA DEL SOCORRO FLORES LUGO
FILE No284/2008
PROCESSED: LUIS ALBERTO
RUBIO FLORES AND JOSE RA
MY BLONDE FLOWERS
THEFT IN PLACE
CLOSED.
C. FIRST JUDGE OF FIRST INSTANCE
INSTANCE OF THE CRIMINAL BRANCH.
PRESENT.
LUIS ALBERTO RUBIO FLORES AND JOSE
RAMON RUBIO FLORES, in our capacity as
sentenced, in the criminal process recorded in the heading.
Before you, Your Honor, with due respect
we are here to present.
We hereby come before you with this writing regarding the
object of complying with the sentence handed down in our
against, welcoming the benefit of the conditional suspension of the execution
from the penalty through the presentations to sign under the established terms
in that resolution.
For the purposes mentioned above and under protest of telling the truth
we state that the address we commit to reside will be in the house
from our mother MARIA DEL SOCORRO LUGO FLORES, located in
7 de Abril Street NO. 128 in the Rubén Jaramillo neighborhood, between Insurgentes Street and
International of this city, which I demonstrate with the receipt issued by
the Federal Electricity Commission that I present in this document, therefore
Once this request is accepted, please issue an order through an official letter to whom it may concern.
our immediate freedom.
For the reasons stated above, to you, Judge, respectfully
I ask.
UNICO.- Please proceed to agree in accordance with the request made here and in your
opportunity serves to forward the letter to the relevant party so that I may be put
in immediate freedom.
A T T E N T I V E L Y
MAZATLAN SINALOA ON NOVEMBER 11 OF THE YEAR 2009
LUIS ALBERTO RUBIO FLORES JOSE RAMON RUBIO FLORES
FILE No 284/08
PROCESSED LUIS ALBERTO
RUBIO FLORES AND ANOTHER.
THEFT CRIME IN PLACE
INHABITED.
C. FIRST JUDGE OF FIRST INSTANCE
FROM THE CRIMINAL BRANCH.
PRESENT.
RODOLFO SÁNCHEZ GOMEZ, in my
character of private defender of the processed
LUIS ALBERTO RUBIO FLORES AND JOSE RAMON RUBIO FLORES
in the criminal process noted in the heading. Before you C.
Judge, with due respect, I appear to present
That through this present writing of
conformidad con lo dispuesto por el artículo 339 del Código de
Pending Criminal Procedures, I come before you in virtue of this in time
in order to provide the following evidence on behalf of my defendants.
TESTS
1.-PRIVATE DOCUMENTARIES.-
Consistent in the letters of recommendation and good conduct issued
by CC. MARCOS MASCOTE ANGELES AND CARLOS HERNANDEZ
OSUNA, in his capacity as the owner of Technical Manufacturing of the Pacific and
Sole administrator of Pesquera Doreen s.a de c.v respectively, in favor of
of my defendants JOSE RAMON RUBIO FLORES AND LUIS ALBERTO
RUBIO FLORES. The same ones that I request to be added to the files of this process.
so that they may take legal effect when appropriate
Due to the above and based on
You, Judge, I respectfully request.
UNICO.- Please serve to agree in accordance with
here is what you requested.
A T T E N T I O N
MAZATLÁN SINALOA, MARCH 5, 2009.
EXPEDIENTE No 284/08
PROCESSED LUIS ALBERTO RU
BIO FLOWERS AND JOSE RAMON
RUBIO FLORES
CRIME.- THEFT IN PLACE
HABITATED
[Link] FIRST OF FIRST INSTANCE
FROM THE CRIMINAL BRANCH.
PRESENT.
RODOLFO SANCHEZ GOMEZ, in my
character of private defender of the accused
LUIS ALBERTO RUBIO FLORES Y JOSE RAMON RUBIO FLORES
in the criminal case recorded under the heading. Before you C.
Judge, with due respect, I appear to present
That through this writing I come before you
Your Honor, in order to request the following:
a). as it may be in the interest of the defense
I appear before you, Honorable Judge, with the intention of withdrawing the evidence of
supplementary statement provided by CC ALBERTO SAINZ
BARRON AND JOSE LUIS BOROBOA CEYSA experts attached to the direction
of criminal investigation and expert services that is scheduled for its
relief for today, requesting that my representatives be given notice and in
your opportunity, please decree the closure of the instruction.
For the above reasons to you, judge
I kindly request.
You, n i c o. - Please serve to agree according to what is here.
requested
A T T E N T I O N
MAZATLÁN SINALOA JUNE 18, 2009
EXP. No. 143/010
ACCUMULATION INCIDENT
OF PROCESSES
PROCESSED. FABRICIO ARIEL
C. FOURTH JUDGE OF FIRST INSTANCE
FROM THE CRIMINAL BRANCH
PRESENT.
RODOLFO SANCHEZ GOMEZ in my capacity as
judicial prosecutor of the accused FABRICIO ARIEL ALATORRE
BARRIER. From widely accredited generals in the cited criminal case
top right corner, before you C. JUDGE with due respect
I appear to expose:
That through this written document and by my own
law and based on article 446 section I, of the code of
current criminal procedures in the state of Sinaloa, in relation to the
Article 24 of the Penal Code, I present myself before this court of knowledge.
to request the accumulation of proceedings be granted to me so that
accumulate the criminal process number 158/010 filed before the second judge of
first instance of the criminal branch against my client FABRICIO
ARIEL ALATORRE BARRERA FOR THE COMMISSION OF THE CRIME OF
ROBBERY ______________________ committed to the detriment of the assets
economic of__________________ to the criminal case that is being followed against me
represented before this court whose case number is located
noted in the heading of this writing.
This petition is made by virtue of the ongoing trial.
before this court against the accused FABRICIO ARIEL ALATORRE
BARRIER FOR THE CRIME OF INJURIES TO THE DETRIMENT OF
_________- ACCORDING TO FILE NUMBER 143/10, in which it was issued
the formal imprisonment order dated ________ is older than the one given to you
follow my defendant before THE SECOND JUDGE OF FIRST INSTANCE
FROM THE CRIMINAL BRANCH IN FILE 158/010 IN WHICH HE
DICTO AUTO OF FORMAL PRISON ON THE DAY ________ BY THE
CRIME OF THEFT _________
I base and justify this request for the consolidation of processes. In the
Next presentation of facts and legal provisions.
FACTS
On April 20, 2010, the agent
The third of the public ministry of the common jurisdiction initiated the preliminary investigation
number 343/010 for the crime of injuries committed against integrity
2.- that 30 thirty days after having started the
preliminary investigation by the third party agent of the public ministry of
common jurisdiction began on May 20 of the same year another investigation
previous against my defendant now with number 530/2010 for the crime of
qualified robbery committed to the detriment of economic heritage of
__________, this is sent before the second judge of first instance.
case number 158/010, in which are recorded as
likely responsible my today sponsored
3.-That the second judge of first instance of
prior penal branch the disclosure of the legal proceedings dated
_____________________ resolved the legal situation of my client.
FABRICIO ARIEL ALATORRE BARRERA dictating formal order
prison with date ___________ for considering him likely responsible for the
qualified theft committed to the detriment of economic patrimony
______________.
4.- That the incident of is appropriate
accumulation of processes requested in the terms provided by the articles
446 fraction I, and 452 of the current criminal procedure code in force in
relationship with article 24 of the current penal code because my client
FABRICIO ARIEL ALATORRE BARRERA is undergoing two processes for
crimes committed on different dates as established in the article
24 of the aforementioned legal provision, this fourth court being competent
penal for being the court that hears the oldest criminal proceedings already
that began on April 20, 2010, while the criminal case that is
he follows my defendant before the second judge of first instance of the branch
penal began on May 20 of the same year and according to article 152 of
code of criminal procedure in force this court is competent for all
since this trial, whether it is 143/010, is still in the instruction period
That's why I come before Your Honor to
request the accumulation of processes as it meets the requirements of it
contemplated in Article 446, section I of the Code of Procedures
penal laws in effect in the state, in relation to article 24 of the penal law
in force
RIGHTS
1.- Regarding the substance, Article 24 of the
Criminal code and regarding the procedure, articles 446 are applicable.
fraction I, 449, 452, of the Code of Criminal Procedure.
For the reasons stated above, I address you, Mr.
SECOND.- Notice is given to the Honorable JUDGE
SECOND OF FIRST INSTANCE OF THE CRIMINAL BRANCH
I remit to you all the actions taken in the criminal proceedings number 158/2010 before you.
tribunal.
RESPECTFULLY
Mazatlan Sinaloa, a August 2010
__________________________
LIC. RODOLFO SANCHEZ GOMEZ
INTERROGATION WHAT SHOULD ANSWER THE
CC______________Y_______________ IN VERBAL AND DIRECT FORM IN THE
DRAINING OF THE TESTIMONIAL EVIDENCE OF GOOD CONDUCT
SCHEDULED FOR SEPTEMBER 8, 2009 IN THE
CRIMINAL PROCESS NUMBER 348/08.
1.- LET THE WITNESS SAY IF SHE KNOWS MY REPRESENTED
NAYELY GUADALUPE RAMOS MELCHOR AND IF AFFIRMATIVE THAT
MENTION THE TIME YOU HAVE KNOWN HER.
2.- LET THE WITNESS SAY WHAT CONDUCT HAS BEEN
OBSERVED THE PROCESSED NAYELY GUADALUPE RAMOS MELCHOR IN THE
TIME THAT YOU HAVE KNOWN HER
3.- TELL THE WITNESS WHAT HAS BEEN THE WORK ACTIVITY THAT
MY REPRESENTATIVE NAYELY GUADALUPE RAMOS HAS PERFORMED
MELCHOR IN THE TIME HE HAS KNOWN HIM
4.- SAY THE WITNESS IF HE/SHE HAS KNOWLEDGE THAT MY
HAS THE REPRESENTED PARTY HAD ANY OTHER JUDICIAL PROBLEM
DIFFERENT FROM THE ONE FOLLOWED BEFORE THIS COURT
5.- LET THE WITNESS STATE THE REASON FOR THEIR STATEMENT
EXPEDIENTE: 348/08
Processed Nayely Guadalupe
RAMOS MELCHOR
Culpable Damage Offense
C. FOURTH FIRST JUDGE
INSTANCE OF THE CRIMINAL BRANCH
PRESENT
RODOLFO SANCHEZ GOMEZ, in my capacity as defender
particular of the processed NAYELY GUADALUPE RAMOS MELCHOR, in the
Criminal case recorded under the heading, before you, Honorable JUDGE, I appear to
expose
That through this written document I come before you with the purpose
to contest the expert report prepared dated ________ of
present year by the experts ALMA ROSA SOSA VELARDE and CARMEN
CELIA RIVERA RAMIREZ, the same who acted on page _____ of the records,
well, said opinion does not meet the requirements set forth by the article
237 of the current code of criminal procedures, since in the aforementioned
the report does not establish the operations or experiments that
they carried out to issue it and even less to indicate the facts and circumstances
on what does its ruling base itself.
Well, in the ruling that is being challenged today, it refers to the method
direct observation of the valued object was used and using the
the sense of touch was how I valued the vehicle belonging to the victim,
by virtue of the fact that when the expert ALMA ROSA SOSA was questioned,
in the expansion of the statement made before this tribunal about
What else did he do to issue his opinion? He replied that nothing more than what was already done.
quote in the ruling.
Aiming that such valuation was made based on the commercial value.
obtained from the specialized negotiations in the field to which it is
there was a percentage that included VAT, shipping, commission of the
sellers, however when the expert was interrogated in the
relief from the expansion of the statement about what the percentage was
which exceeded the commercial value of the negotiations granted to the
damaged parts of the vehicle valued responded that he could specify it.
The same happened when he was asked what the brand was.
painting that was taken into account.
Resulting then that the opinion was made observing and
asking, and for these operations no specialization is required and
Any staff can carry it out and not as required by article 224.
of the current criminal procedure code, as well as in the
The mentioned ruling appears as a note at the end of the back.
It remains to evaluate the mechanical-electrical part, suspension,
alignment, etc., however it would not match the ministerial faith of damage
what work in the files.
For the above reasons, I respectfully REQUEST: Mr. JUDGE
UNIQUE.- Let it be noted that I am challenging the
expert opinion that appears on page 29 of the case, which was issued
by CC. ALMA ROSA SOSA VELARDE and CARMEN CELIA RIVERA
RAMIREZ, for the reasons set forth in the body of this
written.
D I LI G E N T LY
Mazatlán, Sinaloa, 31 de Agosto del 2009
LIC. RODOLFO SANCHEZ GOMEZ
ORGANIZATION
Deliberate harmful acts
C. FOURTH COURT OF FIRST INSTANCE
FROM THE CRIMINAL BRANCH.
PRESENT
RODOLFO SÁNCHEZ GOMEZ, in my
character of private defender of the processed
JAIME CABRERA ORTEGA in the criminal process noted to
item. Before you, Honorable Judge, with due respect
I appear to present.
That through this present course
in accordance with the provisions of article 332
of the current code of criminal procedure, I refer to
before you with the aim of requesting the following:
a).-That due to the fact that there are no pending evidence for
to relieve, I request you, Honorable Judge, to kindly close the instruction in the present case.
process, having the records made available to the parties for the effects
legal matters referred to in article 341 of the criminal procedure code in
vigor.
Given the above and founded on this, I respectfully address you, Mr. Judge.
I ask.
UNICO.- Please agree in accordance with the request made here.
T E N T A M E N T E
MAZATLÁN SINALOA August 4, 2009
LIC. RODOLFO SÁNCHEZ GOMEZ
PROCESSED JAIME CABRERA
ORANGE
WILLFUL DAMAGE OFFENSE
[Link] Fourth Court of First Instance
FROM THE CRIMINAL BRANCH.
PRESENT.
RODOLFO SANCHEZ GOMEZ, in my
role of private defender of the accused JAIME
CABRERA ORTEGA in the criminal case recorded under the heading.
Before you, Honorable Judge, I appear with due respect.
to expose.
That through this written document
I am addressing you with the aim of requesting it.
next:
A).- That by virtue of the result
from the relief of the expansion of the declaration in charge
from the CC. ROBERTO GASTELUM LOPEZ AND LADISLAO
GRACIANO GAMBOA experts attached to the directorate of
criminalistics research and expert services
conducted before this tribunal on the date of the 20th of
February of this year. I attend before you with the
object of challenging the expert report prepared by
date May 17, 2008, which is on page 21 of
the cars where the damages caused are assessed
two palapas made of palm materials with structure
of wood and tubular of metal in the quantity of
60,000 pesos currency [Link] which I do in the
following terms.
1.- That the present is challenged
expert opinion on damage assessment by virtue
that does not meet the provisions established by the article
237 del code of procedimientos penal in vigor
that establishes that the experts must carry out all
the operations and experiments what's up science and
art the suggest expressing the facts y
circumstances that serve as the basis for your opinion
which of course does not happen since the content of the
multicitado opinion it observe what the unique
operations what they carried out for emit it were
observe and play, besides what in the release of the
The REPAIR DE LÑA PALAPA WHAT ACCOUNT CON THIRTEEN
METROS DE DIAMETER RESPONDED... what us possible
determine the number of palm trees based on that
The specified in the ruling was done based on
a research per square meter with people
what himself dedicate a to carry out this types of work
giving the amount stated in the report, WHILE
WHEN THE EXPERT NAMED LADISLAO WAS QUESTIONED
GRACIANO GAMBOA IN THE SAME SENSE AS THE QUESTION
NOVENA DEL INTERROGATION WHAT WHICH It was THE QUANTITY
DE PALM TREE WHAT Tomo EN CONSIDERATION FOR LA
REPAIR DEL DAMAGE TO PALM TREE WHAT MIDE FOUR
SUBWAY DE DIAMETER RESPONDED... approximately 16
square meters.
Thus, the expert contradicts himself.
when questioned about the commercial value of
the amount of palm used for the repair of
the palapa well expert ROBERTO GASTELUM TO THE QUESTION
NOVENA RESPONDED what no the could to specify with
accuracy since in this present expert report there
I take in bill the material y hand of work sine
detail the quantity and cost of the palm tree, WHILE
WHAT THE EXPERT LADISLAO GRACIONO Gamboa WHEN Was
QUESTIONED EN THIS SAME SENSE EN The QUESTION
ELEVENTH RESPONDED… 400.00 four hundred pesos
per square meter...
Likewise, when he was questioned in
relationship a the operations y experiments what
practical for the preparation del opinion expert
what today it object of challenge being this one
requirement imposed by article 237 of the code of
procedures penal in vigor THE EXPERT ROBERTO
Gastelum EN The QUESTION TENTH FIRST DEL
INTERROGATION BY THE DEFENSE HE DID RESPOND... that
some arithmetic operations were performed and that
At the moment I don't have them on hand without remembering.
exactly which ones were.
FURTHERMORE what both experts refer for
issue your opinion if they took into account a format
from some other already prepared ruling and that had the
necessity of to ask a third parties people what he
dedicate a the sale of material y construction of
this type of work (construction of palm thatch roofs).
to the emit the opinion lo do in base of su
experience professional but what must to do use of
the means scientists what this is you scope for
that it generates conviction in the judge and not as
in this case the experts they made to the question a
third parties people what it they dedicate a the sale of
material y construction of palapas. Having
application of the following jurisprudential thesis
Based on the aforementioned, I respectfully request you, Judge.
U n i c o.- Let me be considered present and formally contesting the
expert report referred to in the body of this writing by the
reasons already stated requesting this court to rule at the time of issuing
the ruling in this process did not take into account the cited expert opinion
and acquit my defendant from the payment of damages
A T T E N T I O N
MAZATLÁN SINALOA June 30, 2009
LIC. RODOLFO SÁNCHEZ GOMEZ
PROCESSED: ANDRÉS CARBALLO
RIVER
SUBJECT: THE ONE INDICATED.
C. FIRST JUDGE OF FIRST INSTANCE
FROM THE CRIMINAL BRANCH.
PRESENT
C. ANDRES CARBALLO RIVERA, of personality
recognized in the documents of the criminal trial whose file is
I cite the item, before you Mr. Judge with due respect.
I appear to present:
Through this writing, based on
Article 8 and 20 section A fraction V of our Charter
Magna, 1, 3, fractions II and III, 214, 215, 245, 246 and others
provisions of the current Code of Criminal Procedure in
our Entity, I appear to offer in favor of the undersigned
the following:
P R U E B A S
TESTIMONIAL REGARDING FACTS.-
Consistente en la declaración que haga con base a las
questions that the parties will ask on the day and time that
Please be so kind as to point out Dr. Ulises Orozco Beltrán,
to which I request to be cited through legal channels with the
legal warnings, since, under the oath to tell the truth
manifest cannot present, who can be duly
cited through the Institution of the Public Ministry,
as a qualified forensic physician, as stated in the case files.
EXPANSION OF STATEMENT.- Consisting of the
extension of the statement based on those that you make
the parties will formulate on the day and time that they deem appropriate
Your Honor to ARMANDO HERRERA JACOBO, whom I request to be summoned.
through legal channels with the legal warnings, already
that, under the protest of telling the truth, I state I am unable to
to present, who can be duly cited with an address
known in the treasure, Municipality of Isla, Veracruz; For the
To the satisfaction of this evidence, I request that the knife presented
at the disposal of this H. Authority as an instrument of the
crime, that it is located in the facilities where
the test will be carried out to relieve it, with the purpose of
put it in view of the witness for the purposes of the
fraction IX of article 251 of the Adjective Law in question.
DOCUMENTARY OF REPORTS.- Consisting of the
written information, prior official document issued by this H.
Judged the Director or Person in Charge of the Regional Hospital of
Isla, Veracruz in order to state the name of the one or ones
doctors who attended to the deceased Roberto Cobos Jacobo on the day
May 27 of the current year; likewise, if they formed any
medical or clinical record of said patient and in case
UNIQUE.- Please provide accordingly.
requested.
I PROTEST for what is necessary
San Andrés Tuxtla, Veracruz on September 8, 2011
______________________________
C. ANDRÉS CARBALLO RIVERA
INTERROGATION FOR ISRAEL LÒPEZ LUQUE
1.- The witness says he knows Martín Enriquez
Herrera
2.- Tell the witness where you met the person
mentioned above
3.- Tell the witness if he was interviewed by
Police officers from the Federal Agency
Investigations that were conducting the research
of a female person who
they found drugs in a bag that contained
fish and coal.
4.– Tell the witness what you told them.
mentioned agents;
5.– Tell the witness if you sent Martín
Enrique Herrera the amount of $1,900.00 with a
internal name Juan Antonio García Ávalos;
6. – Ask the witness if the day he sent the ...
money to Martín Enrique Herrera, this (Martín
Enriquez was waiting outside.
money
7.– * If the answer to the above is yes, ask *
Say the witness how C. Martín Enriquez knew.
that you were going to send him the money;
8.– *In case of a negative response, ask* If I didn’t know that
Mr. Martín Enriquez was waiting for the
money, because he sent it.
9. – Tell the witness for what concept did he send it
usted dinero a la persona mencionada;
10. – Does the witness say if Martín Enrique Herrera
he waited for the money you were sending him;
11. - *In case of a negative, ask* Say the
witness why the person did not wait for the money
mentioned;
12. – Diga el testigo la razón de su dicho;
INTERROGATION FOR MR. JUAN ANTONIO GARCÍA AVALOS
1.– Tell the witness if you received from
ISRAEL LÒPEZ LUQUE the amount of $1,900.00
4.– The witness states the reason why he was summoned.
removed by the guardians the mentioned money,
5.- The witness recounts everything that happened since
the money was delivered to him until it was
secured by the guards,
6.– Tell the witness if he was informed of the reason for the
Why did Israel López Luque send money to
Martin Enriquez Herrera
7.– Let the witness state the reason for their statement.
INTERROGATION FOR ARNULFO ANGULO MEDINA
1. – Tell the witness if he has knowledge of the
reason why C. is detained.
Candelaria Medina Acosta;
2.– The witness narrates what he knows about what happened to him.
accuse the mentioned person;
3.– Ask the witness if the mentioned person
previously (Candelaria Medina Acosta) has
drug brought to you inside the
detention center
4. - Let the witness state the reason for their statement.
CRIME: COUNTERFEITING OF CURRENCY AND
USE OF COUNTERFEIT CURRENCY
PROCESSED: RODRIGO INZUNZA
CAMACHO AND ANOTHER
SUBJECT: CONCLUSIONS
[Link]ÉPTIMODE DISTRICT IN THE STATE
PRESENTED.
LIC. GABINO ACEVEDO GARCÍA, in my capacity as
private defender of the defendants in the criminal case whose
the file is cited to the section; before you, Honorable JUDGE, with the
I respectfully appear to present:
Through this document, based on
what is provided in article 307 of the Federal Code of
Criminal Procedures by virtue of the Agent of the Ministry
The public prosecutor filed against my clients.
accusatory conclusions, I appear in order to formulate to
please them the following:
CONCLUSIONS OF NON-CULPABILITY
My clients have always acted with truth, with the
purpose that your lordship has a greater and better illustration
about how the events occurred in this criminal case.
I inform Your Honor that at the moment of pronouncing
final sentence in this criminal case, I take very in
count the circumstances of manner, time, and place in which
the events that concern us took place; also the degree of
instruction that my client has which is practically
zero; as well as, the salary, honest way of living and others
particular situations of the case, especially the one anticipated
in articles 51 and 52 of the Federal Penal Code, so that
a proper assessment is made and a judgment is reached
justa.
The elements that are in the records, even when they were
sufficient to dictate the Formal Prison Order, they are not
to pass a conviction sentence, for which your honor
at the time of resolving, you should issue a ruling of acquittal for not
to be fully aware that my defended has committed the crime for
the one accused by the Social Representation.
My defendants are not criminally responsible for the offense.
of Use of Counterfeit Money, for which they are accused by the representation
social, as there is not enough evidence to issue a
convicting sentence; indeed, in this case, we have
The existence of counterfeit currency, specifically, hundred peso bills.
2. That someone makes use of those fake bills.
3. That the use of those bills be made knowingly, that is, with knowledge that the
they are false.
At first, it is to make oneself known to this H.
A tribunal cannot hold a person if there is
only as a test your confession; In this regard, the article
Article 287 of the Federal Code of Criminal Procedure establishes that
next
ARTICLE 287.- The confession before the Public Prosecutor and before the judge must meet the
following requirements:
I.- It must be made by a person not less than eighteen years old, against them, with full
knowledge, and without coercion, or physical or moral violence;
II.- That it be made before the Public Ministry or the court of the case, with the assistance of
his defender or a person he trusts, and that the accused is duly informed of the
procedure and process;
III.- That it is of its own fact; and
IV.- That there are no data that, in the opinion of the judge or court, make it implausible.
No one can be charged if the only evidence is the confession.
Judicial Police may provide reports but not obtain confessions; if they do, these
they will lack any evidentiary value.
The actions carried out by agents of the Federal or local Judicial Police will have value.
of testimonies that must be complemented with other evidence proceedings that are carried out
the Public Ministry, to be attended at the time of the consignment, but in no case will it
they may take as confession what is stated in those.
Entonces, si no puede consignarse a una
a person only exists against them as evidence the
confession, the less one can be sentenced, hence they are
I must acquit for this offense; it supports the above.
the theses that I transcribe below:
Sixth Era
Instance: First Chamber
Source: Judicial Weekly of the Federation
Volume: Second Part, CXIV
Thesis:
Página: 47
Volume LXXVII, page 30. Direct amparo 3241/63. Juan Navarro. 27 of
November 1963. Five votes. Rapporteur: Ángel González de la Vega.
Volumen LXXVII, página 30. Amparo directo 3399/63. Manuel Olmos
Hernández. 27 de noviembre de 1963. Cinco votos. Ponente: Ángel González
from the Vega.
Volume CXI, page 38. Direct protection 4200/65. Jaime Tabares Barajas. 8
September 1966. Five votes. Speaker: José Luís Gutiérrez Gutiérrez.
Volume CXII, page 45. Direct amparo 8313/65. Leopoldo Ruiz Zenil. 5
October 1966. Five votes. Speaker: Agustín Mercado Alarcón.
Volume CXII, page 45. Direct amparo 8145/65. Rolando C. Lozano. 27
October 1966. Five votes. Speaker: Abel Huitrón and Aguado.
Note: In the Judicial Weekly of the Federation, the case 4200/65 appears.
as corresponding to 'Volume CXI, Second Part, page 47' which
correct as seen in this record, with support from this last one
publication.
In addition to the above, we must not lose sight of
seeing that every person enjoys the benefit of the presumption
of innocence, a principle that must be disproved by the
Social Representation for a person to be
condemned, as it is stated in articles 14, 16, 19,
21, 102 section A constitutional and 170 of the Code of
Current Criminal Procedures in our State, for it is at
Public Ministry to whom the burden of the
test, therefore, in this case, as it has not been discredited.
that principle must prevail and therefore absolve from the
accusation for all legal effects that may arise,
sirve de apoyo a lo anterior la tesis de jurisprudencia
supported by the Full Court of the Supreme Court of
Justice of the Nation that I will transcribe below:
Plenary Instance
Source: Judicial Week of the Federation and its Gazette
Volume: XVI, August 2002
Thesis: P. XXXV/2002
Page: 14
PRESUMPTION OF INNOCENCE. THE RELATIVE PRINCIPLE IS
IMPLICITLY CONTAINED IN THE CONSTITUTION
FEDERAL. From the harmonious and systematic interpretation of articles 14,
second paragraph, 16, first paragraph, 19, first paragraph, 21, paragraph
guarantees of hearing and the right to present evidence to refute the accusation
corresponding, the Judge shall issue a final ruling declaring him guilty;
and on the other hand, the accusatory principle, through which it corresponds to the Ministry
The public function of prosecuting crimes and the obligation (burden) to seek.
and present the evidence that demonstrates the existence of these, as it is
it derives from the provisions of article 19, first paragraph, particularly
when it warns that the formal prison car must express 'the data that
throwed the preliminary investigation, those that must be enough to prove the
body of the crime and make the responsibility of the accused probable; in the
Article 21, stipulating that "the investigation and prosecution of crimes
it is the responsibility of the Public Ministry"; as well as in article 102, when stating that
It is the responsibility of the Federal Public Ministry to prosecute all
federal offenses, corresponding to 'searching for and presenting the evidence'
that certify the responsibility of these ones." In that sense, it should be considered that
the constitutional principles of due process and the accusatory system
implicitly safeguard the diverse principle of presumption of innocence,
allowing the governed not to be obliged to prove the lawfulness of their
conduct when accused of committing a crime, as long as the accused
it does not have the burden of proving its innocence, since the system provided by the
The Political Constitution of the United Mexican States recognizes, a priori,
that state, by expressly providing that it is the Public Ministry to whom
it is the responsibility to prove the essential elements of the crime and of culpability
accused.
Amparo for review 1293/2000. August 15, 2002. Eleven votes. Speaker:
Sergio Salvador Aguirre Anguiano. Secretaries: Eduardo Ferrer Mac Gregor
Poisot and Arnulfo Moreno Flores.
The Full Court, in its public session held on August fifteenth this year,
approved, with number XXXV/2002, the isolated thesis that precedes; and determined
that voting is suitable for integrating jurisprudential thesis. Mexico, District
Federal, on August sixteenth, two thousand two.
Now then, regarding the statement of the Agents
of Municipal Police that could at any given moment be a
the accusation against my defendants, it should be said that to them
the facts are not known to them, as per the informative report
It is clear that they arrived when the events had already
occurred, therefore, since they have not been appreciated for their
senses become witnesses by hearsay and not being
reinforced with other tests, then, no value
they do not meet the legal requirements; it serves as support
to the above, the theses that I will transcribe below:
FIRST COLLEGIATE COURT OF THE FOURTEENTH CIRCUIT.
(XIV.1o. 3P).
Direct Amparo 437/95. César Ernesto Vázquez Castillo. February 1, 1996.
Unanimity of votes. Rapporteur: Mariano Hernández Torres. Secretary: Silvia
Beatriz Alcocer Enriquez.
JUDICIAL WEEKLY. NINTH EPOCH. VOLUME III. APRIL 1996.
COLLEGIATE COURTS. PAGE 403.
Eighth Era
Instance: FIRST COLLEGIATE COURT OF THE SEVENTH
CIRCUIT.
Source: Judicial Weekly of the Federation
Volume: VIII, October 1991
Thesis: VII.1o. J/14
Page: 119
HEARSAY WITNESSES. VALUE OF THE. The statement of
the hearsay witnesses, who do not have personal knowledge of the facts.
FIRST COLLEGIATE COURT OF THE SEVENTH CIRCUIT.
Review Amparo 537/88. Hugo Hermoso Mendizabal. May 31
1989. Unanimidad de votos. Ponente: Eliel E. Fitta García. Secretario:
Antonio Zúñiga Luna.
Direct Amparo 1365/89. Hermilo Guzmán Velázquez. February 14
1990. Unanimidad de votos. Ponente: Eliel E. Fitta García. Secretario:
Pedro Pablo Hernández Lobato.
Direct Amparo 1971/89. Pedro Rodríguez Reyes. February 21, 1990.
Unanimity of votes. Speaker: Eliel E. Fitta García. Secretary: Nilvia
Josefina Flota Ocampo.
Direct appeal 1875/89. María Elena Rodríguez Trujillo. October 24
1990. Unanimidad de votos. Ponente: Eliel E. Fitta García. Secretario:
Pedro Pablo Hernández Lobato.
Appeal for review 189/89. Honorio López Carmona. August 28
1991. Unanimidad de votos. Ponente: Eliel E. Fitta García. Secretario:
Pedro Pablo Hernández Lobato.
NOTE: This thesis also appears published in the Weekly Newspaper Gazette
Indeed, article 286 of the Federal Code
The Criminal Procedure Code states the following:
Article 286. The courts, depending on the nature of the facts and the
logical and natural link, more or less necessary to exist between truth
known and the one being sought, they will appreciate in conscience the value of the
indications until they can be considered as full proof.” (The underlining is
of this Tribunal)
The analysis of the transcribed regulatory provision allows
to conclude that for the integration of the circumstantial evidence
it is necessary that the clues to start from are
properly proven, because only in that way does one reach the
certainty of the truth that is sought.
This is the mechanism for fact-checking
through the circumstantial test it must meet two
requirements:
That the basic facts about are proven
those from which the presumptions derive.
2. That there is a logical and natural link, more or less
necessary between the known truth and the one being sought.
The above implies that one should not force the
concatenation of the existing evidence to demonstrate the
truth that is sought, but rather the fact or hypothesis to
check arises or emerges naturally from the
meeting and logical concatenation of facts or evidence
tested in cars.
The above consideration is supported by the
thesis of jurisprudence number two hundred sixty-eight, which
can be consulted on page one hundred fifty, volume II,
from the Appendix to the Judicial Weekly of the Federation 1917-
1995, supported by the First Chamber of the Supreme Court of
National Justice, with the following title and text:
CIRCUMSTANTIAL EVIDENCE, VALUATION OF. The evidence
circumstantial is based on the incriminating value of the evidence and has,
as a starting point, facts and circumstances that are proven and of
which aims to detach their relationship from the inquired fact, this
yes, already a data to complement, already an unknown to determine, already a
hypothesis to be verified, the same regarding the materiality of the crime as about
the identification of the culprit and about the circumstances of the act
incriminated." (The underlining is of this Court)
The diverse thesis of this also applies
jurisprudence I.3rd.P. J/3, visible on page six hundred
eighty-one, volume III, corresponding to the month of June of
nineteen ninety-six, from the Judicial Weekly of the
Federation and its Gazette, supported by the Third Court
Court of Appeals in Criminal Matters of the First Circuit, which is
shares, with the following literal tenor:
CIRCUMSTANTIAL TEST. INTEGRATION OF THE.
integration of the circumstantial evidence, it is necessary that they are found
proven the basic facts from which the presumptions arise, thus
like the logical, natural harmony and legal concatenation that exists between
the known truth and the one that is sought, appreciating as a whole the
evidentiary elements that appear in the process, which should not
undoubtedly, certain, known and manifest in
cars, whenever it comes to data whose certainty
allows starting from them to verify other data not
known.
It is also timely to mention that in order to assess the strength
probation of an indication, it is necessary to find out what it is
strength of the specific relationship that links in him, it
known with the unknown, in order to establish it that way
its effectiveness in the unambiguous and unequivocal verification of the fact
to demonstrate, in this case, the verification of the second
element of the crime of using counterfeit currency.
Under that line of considerations, the accreditation of a
made through circumstantial evidence requires that the
indicative circumstances lead to confidently affirm the
truthfulness of an unknown fact, beyond the simple
possibility or probability, for there must be good reasons
and a manifest plausibility, based on sufficient reason
to reach the conviction that the conclusion reached
It is sustainable and that is only fulfilled when an indication is
I have effectively corroborated with another who is also
determinant and convergent.
Now, from the examination of the documents that comprise
the original file notes that the only data that
work in relation to the assets making use of the
fake bills when purchasing some soft drinks and a record
its Ministerial declaration is concise.
In the aforementioned statement given on the 18th of
October 2005 my client HÉCTOR ENRIQUE ANGULO ARAUJO
among other things he said:
... That yesterday, Monday, October seventeenth, when it was past ten o'clock.
tomorrow, we arrive with the voice and my friend RODRIGO to this city, passing through to a
grocery store called "DOÑA MATY", which is located on that side of the center, a little further
beyond the EMAUS Funeral Home, a place where we ordered some soft drinks and my friend RODRIGO
I paid with a fake hundred peso bill, and after this, we headed to the center.
from this city, arriving at the market where the one with the voice bought a record, paying for it with
another counterfeit hundred peso bill, and then we went to a stationery store to buy glue, sheets
whites, a knife, as well as the adhesive pencil Resistol TOP, and then we separated,
since my friend RODRIGO went to buy other things, and I headed to a store of the
I went to the market to buy ten pesos worth of cheese, which I paid for with the other fake hundred peso bill.
the pesos I had left, and since the lady who sold me the cheese didn't have change, she left with
the ticket to look for the fair and shortly returned with a police officer, who told me that the ticket with the
what I had paid was fake and if where I had gotten it from, then I told him to give it to me.
they had given, but then I told him that I had done it...
On its part my defended RODRIGO INZUNZA
CAMACHO in his ministerial statement given therein
date said:
Yesterday, then the lady who served us gave me the change of one hundred pesos.
amount of $83.00 pesos, and we immediately left heading towards the center of this.
city, and then my friend HECTOR ENRIQUE bought a compact disc which he paid for
with another fake hundred peso bill, who apparently had thirty pesos left over, and already
From there we parted ways, so I headed towards my home located in the community.
from El Salitre, and when I was going through the old market of this city, some police officers caught up with me.
municipal elections by bicycle ...
However, nonetheless the recognition of
the assets regarding the use of the bills, the defense
estimates that this data is insufficient to demonstrate the
element under study as long as there is no means in the case
test someone who confirms it and consequently allows to reach
the certainty that the processed have, indeed,
used counterfeit bills; requirementsnone what not for
to estimate the proven crime of using counterfeit currency provided
and sanctioned by the last paragraph of article 234 of
Federal Penal Code.
It is so because the confession of the defendants,
in accordance with Article 285 of the Federal Code of
Criminal procedures have value as evidence and only
when it is not distorted, nor implausible and also is
corroborated by other means of evidence may reach the
full testing range, otherwise it is not suitable for collection
certainty regarding the facts mentioned therein.
Regarding the subject being discussed, it is applicable to the
thesis of jurisprudence VI.1o. J/100, which can be consulted
on page forty-seven of the Weekly Gazette
Federal Judicial number eighty-two
corresponding to the month of October nineteen ninety-four,
supported by the First Collegiate Court of the Sixth
Circuit that is shared, with the following item and text:
CONFESSION SU VALUE PROBATIONARY.
(FEDERAL CRIMINAL LEGISLATION). According to the
technique that governs the assessment of evidence in the
criminal procedure, the confession of the accused as
recognition of one's own guilt derives from
own facts, has the value of a hint, and reaches
the range of full trial when it is not distorted
it is implausible and has been corroborated by other elements
of conviction.
Now then, as already mentioned in the case
only the confession of the accused exists in the
use of counterfeit currency anticipated and sanctioned by the last one
Paragraph of Article 234 of the Federal Penal Code.
Confirms the criterion adopted by the thesis
VI.2o.107 P, visible on page six hundred nineteen,
Volume IV, corresponding to the month of September of one thousand
nine hundred ninety-six of the Judicial Weekly of the
Federation and its Gazette, supported by the Second Court
Collegiate of the Sixth Circuit, with the following literal wording:
CONFESSION OF THE ACCUSED. BY ITSELF IT IS
INSUFFICIENT FOR TO BELIEVE SU
CRIMINAL RESPONSIBILITY. The judicial confession of
processed, for having evidentiary value as an indicator in the
criminal case is in itself insufficient to have
for fully established criminal responsibility in the
illicit act that is attributed to him; therefore, that confession for
acquire full evidential value must be linked with
other means of conviction that strengthen it and
make it believable.
It is stated that the confession is not
corroborated by other means of evidence because neither in the
preliminary investigation was not received before or during the trial
testimonials that would serve to substantiate such
circumstance and the arresting officers have no knowledge of it
the facts and although in its informative part they mention that
my defendants acknowledged the facts that were brought to them
the imputations made against them, this cannot serve as a basis
to issue a condemnation sentence, given that the
municipal police lack the authority to receive
statements, therefore, have no value.
Under those conditions, your honor must issue
sentence where the element is deemed not proven
reference, as a consequence of the above I declare that in
the case has operated the exclusion of the crime provided by the
article 15, section II, of the invoked legal provision and
dictate a judgment of acquittal in favor of RODRIGO INZUNZA
CAMACHO AND HÉCTOR ENRIQUE ANGULO ARAUJO, for the crime of use
of counterfeiting as provided and sanctioned by article 234 of
the federal substantive criminal law.
Likewise, regarding the crime of Counterfeiting of currency,
It can be said that there is also not enough evidence to
to issue a condemnatory sentence, given that although it is true
my defendants admitted to having photocopied the bills
that by ruling turned out to be false, it is also
it is true that they retracted what they said and offered proof
offer evidence to demonstrate it, which causes it to
I was left in a state of helplessness.
In this regard, Your Honor must take into account
it states that there are no elements to certify the use of the
fake currency for the reasons mentioned above, then
then there is no data to suggest that the bills that
they were seized with the aim of deceiving the public to
thus harming the protected legal interest which is public faith and the
national economy, for the same reasons that
they exposed that studying the crime of using counterfeit currency does not
this crime is under investigation, meaning there is no evidence
sufficient for that, which is why it is not updated
illicit; now, while a behavior is updated
criminal by bringing with them my defendants some bills that
they turned out to be false, as their use was not accredited then
the behavior must be reclassified due to the diversity of the article
235 of the Federal Penal Code, without being an obstacle to the
before the fact that the process has been followed by a
different crime because the facts remain unchanged and the
The Public Ministry institution exercises criminal action for
the facts, corresponding to the judicial authority the
resolve what the crime that is proven is, I support my
consideration in the theses that I transcribe below:
Ninth Era
Instance: First Chamber
Source: Judicial Weekly of the Federation and its Gazette Volume: XXII, November 2005
Thesis: 1a. CXXXIII/2005 Page: 40
Subject: Criminal Isolated Thesis
Category
FORGERY. ARTICLES 234, THIRD PARAGRAPH AND 235, FRACTION I,
THE FEDERAL PENAL CODE DOES NOT SANCTION THE SAME CONDUCT.
Text
These precepts do not sanction equal conduct with diverse penalties inasmuch as, in
essence, they do not have the same direct object. In article 234, third paragraph, it is observed that
a typically fraudulent behavior is sanctioned, aimed at deceiving the public with
objects likely to be confused with money or banknotes, given their
characteristics of imitation of the images and other elements used in coins
circulating. Indeed, according to its ordinary meaning, to falsify is to fabricate a false thing
or lack of law, and by false should be understood as something deceptive, feigned, simulated, lacking law, of
reality or truthfulness, and concerning the coin, it will be false the 'one with intent
delictual is made by imitating the legitimate one." It is also required that the result of the action
a criminal object that, due to its physical characteristics, is suitable for public use
he is deceived regarding whether he is in front of authentic or counterfeit currency. In contrast, the article
235, fraction I, of the referred code does not establish the purpose of deceiving the
public, but only that the pieces of paper look like bills because of their size
(similar to or equal to that of the real ones) and for containing elements or images of the banknotes
legally issued, without the possibility of being confused with paper currency of
legal course, that is to say, the object of this last numeral is limited to sanctioning reproduction
Record No.192764
Location:
Ninth Era
Instance: Full
Source: Judicial Weekly of the Federation and its Gazette
X, December 1999
Page: 15
Thesis: P. LXXXV/99
Isolated Thesis
Materia(s): Constitucional, Penal
OFFENSE. THE SECOND PARAGRAPH OF ARTICLE 385 OF THE CODE
FEDERAL CRIMINAL PROCEDURES, WHICH AUTHORIZES ITS
RECLASSIFICATION IN THE APPEAL FILED IN
AGAINST THE ORDER OF FORMAL PRISON OR THE SUBJECTING TO PROCESS,
DO NOT TRANSGRESS ARTICLE 19 OF THE CONSTITUTION.
Article 385, second paragraph, of the Federal Code of Criminal Procedure refers to
the appeal filed against the order of formal imprisonment or the order of detention
process, in which the appellate court is granted powers to reclassify the offense,
as long as it is in accordance with the reported and accredited facts that motivated the
consideration that the elements of an offense were demonstrated and the presumed
responsibility of the appellant; thus, the cited criminal procedural rule aims at
comply with public order and social interest requirements, which consist of seeking that the
the process follows for the crime or crimes exactly determined by the facts
denounced, in such a way that the reclassification made by the higher court is
precisely to comply with Article 19 of the Federal Constitution, in order to
that the process continues for the crimes that characterize the reported facts and not for others.
Moreover, the above does not mean that the appellant is left in a state of defenselessness,
because at that procedural stage they have access to the entire aftermath of the trial, starting from the
instruction, in which you can express arguments and provide evidence that aim to
demonstrate their innocence, or that the criminal type, according to the facts accredited by
his defense corresponds to another of lesser gravity.
Appeal for review 3226/97. January 18, 1999. Unanimity of ten votes. Absent:
José Vicente Aguinaco Alemán. Ponente: Humberto Román Palacios. Secretario:
Guillermo Campos Osorio.
The Full Court, in its private session held on the sixteenth of November this year,
approved, with the number LXXXV/1999, the isolated thesis that precedes; and determined that the
voting is suitable for integrating jurisprudential thesis. Mexico, Federal District, on the sixteenth
of November nineteen ninety-nine.
Record No. 184032
Location:
Ninth Era
Instance: First Chamber
RECLASSIFICATION OF THE CRIME. WHEN THE JUDGE OF THE CASE ISSUES
SENTENCE FOR ONE DIFFERENT FROM THE CONTENT IN THE FORMAL ORDER
PRISON, BASED ON THE SAME FACTS, DOES NOT VIOLATE THE
GUARANTEES OF LEGALITY AND LEGAL SECURITY (INTERPRETATION
FROM ARTICLE 19 OF THE FEDERAL CONSTITUTION.
The aforementioned constitutional provision requires, as one of the prerequisites for issuing the order of
formal imprisonment, which states the crime attributed to the accused and the data that emerges
preliminary investigation, which must be sufficient to establish the elements of the crime and
make probable the responsibility of the accused; likewise, it establishes that every process is
will necessarily proceed for the crime or crimes indicated in the formal imprisonment order or of
subject to process. Now, the word crime used in the mentioned provision
Constitutional should not be understood in the literal sense of the name by which it is called.
the criminal act (in its legal classification), but rather as the set of facts that are subject to
the deposit, and those for whom formal imprisonment is decreed. In these
conditions, if a formal imprisonment order is issued for a crime (understood as the
legal classification contained in the Penal Codes) and, subsequently, in consideration that
The Public Ministry specified its intention and formulated its accusatory conclusions for one
different, based on the same facts, and that the defendant had the opportunity to
formulate your defense against such accusation, the Judge of the case issues the sentence
corresponding and classifies the facts differently from what is contained in the formal order
prison, it is concluded that such action is in accordance with what is established in the provision
reference constitutional, and that such reclassification does not violate the guarantees of legality and
legal certainty.
Direct amparo review 263/2003. March 12, 2003. Five votes. Speaker: Juan N.
Silva Meza. Secretary: Jaime Flores Cruz.
For the reasons previously stated and founded before
You, Honorable Judge, request carefully:
PRIMERO.- Tenerme por presentado en tiempo y
this present document, formulating conclusions of
innocence in favor of my defendants.
SECOND.- At the appropriate time, I will pronounce
ACQUITTAL ruling, and in the hypothetical case not granted of
pass a CONDEMNATORY sentence, be lenient and grant him
some of the benefits that exist in the law.
I PROTEST THE NECESSARY
Los Mochis, Sinaloa 08 de septiembre de 2011
________________________________
LIC. GABINO ACEVEDO GARCÍA
OFFENSE.- INTRAFAMILY VIOLENCE
MILIAR
C. THIRD JUDGE OF FIRST INSTANCE
FROM THE CRIMINAL BRANCH.
PRESENT.
RODOLFO SÁNCHEZ GOMEZ, in my capacity as
private defender of the defendant JESUA ERNESTO ACUÑA HERRERA, in the
penal process noted in the heading. Before you, Honorable Judge, with due respect
I appear to present
That through this written document in accordance
with the provisions of article 330 of the code of criminal procedure in
vigor, I appeal to you in due time with the purpose of offering in favor
of my defended the following evidence.
TESTS
1.- LETTERS OF GOOD CONDUCT.-
consistent in the statements that OLGA LIDIA RENTERIA will issue
CAMACHO AND RAMONA HERNANDEZ LUNA, who have their addresses at
GIRASOL street No 4910 in the Flores Magon neighborhood and Jorge Abel street No 566 in
the Labastida Ochoa neighborhood respectively, both in this city and that
they will declare verbally and directly regarding the conduct of my client
JESUS ERNESTO ACUÑA HERRERA, according to the interrogation I conducted
the defense the day and time that this court serves to set for that purpose.
2.- PRIVATE DOCUMENT.- Consisting of the
letters of recommendation and good conduct issued by the CC. C.P.
CARLOS IRIBE IBARRA AND LIC JORGE LUIS APODACA MUÑOZ. The same as
I request that they be added to the cars of this process so that at the appropriate time.
the legal effects that may apply arise.
3.- CONSTITUTIONAL HEARING that results
between my represented JESUS ERNESTO ACUÑA HERRERA and the offended party
ALMA ROSA VELAZQUEZ AGUILAR, requesting to be summoned by the means
accustomed legal
Based on the above and founded on
I respectfully ask you, Judge.
UNICO.- Please proceed to agree in accordance with what is requested here.
A T T E N T I V E L Y
MAZATLÁN SINALOA ON JULY 14, 2008