Ernesto Zedillo Complaint

Case 3:11-cv-01433-AWT Document 1 Filed 09/16/11 Page 1 of 28

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\ UNITE�f�T� t'\STRICT COURT DIStR.ltT-dF�ECTICUT

"Jane Doe 1, an alien; I Jane Doe 2, an alien; )Jane Doe 3 , an alien; -Jane Doe 4, an alien; John Doe 1, an alien; John Doe 2, an alien; John Doe 3, an alien; John Doe 4, an alien; John Doe 5, an alien; and John Doe 6, an alien,

Plaintiffs,

vs.

Ernesto Zedillo Ponce de Leon, an alien resident of Connecticut,

Defendant.

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JURY TRIAL DEMANDED

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COMPLAINT

Plaintiffs, Jane Doe I, Jane Doe 2, Jane Doe 3, Jane Doe 4, John Doe 1, John Doe 2, John

Doe 3, John Doe 4, John Doe 5, and John Doe 6, through undersigned counsel, sue Defendant,

Ernesto Zedillo Ponce de Leon ("Defendant Zedillo"), and allege:

INTRODUCTION

1. This is a civil action for compensatory and punitive damages, for declaratory

judgment, and for torts in violation of international and domestic law. Plaintiffs institute this

action against Defendant Zedillo for his responsibility in: (a) the extrajudicial killings of

decedents Richard Roe 1 and Mary Roe 1 (parents of Plaintiffs Jane Doe I, Jane Doe 2, Jane Doe

3), and of decedent Mary Roe 2 (wife of Plaintiff John Doe 1 and mother of John Doe 2, John

Doe 3 and John Doe 6) (collectively, the "Decedents"); (b) injuries caused during the attempted


extrajudicial killings of Plaintiffs Jane Doe 2, John Doe 2, and John Doe 3; and (c) the attempted

extrajudicial killing of Jane Doe I, Jane Doe 3, Jane Doe 4, John Doe I, John Doe 4, John Doe 5,

and John Doe 6.

2. Plaintiffs also bring claims against Defendant Zedillo for: (a) war crimes; (b)

crimes against humanity; (c) cruel, inhuman and degrading punishment; (d) terror and violence

to violate freedom of association; and (e) terror and violence to violate freedom of thought,

political opinion and freedom to exercise the political franchise.

3 . At all times material hereto, while he was the President of the United States of

Mexico ("Mexico"), Defendant Zedillo exercised command responsibility over, ordered,

conspired with, acted in concert with, engaged in a joint criminal enterprise with, and/or aided

and abetted, directly and/or indirectly, various members and/or agents of one or more

subdivisions, instrumentalities and/or agencies of the Federal Government of Mexico (the

"Mexican Government"), including, inter alia, paramilitary groups trained, armed or protected

by members and/or personnel of the Mexican Army, or persons or groups acting in coordination

with the Mexican Army or under its control and protection, to commit acts of extrajudicial

killing, attempted extrajudicial killing, torture, crimes against humanity, war crimes, cruel,

inhuman, or degrading treatment or punishment, terror and violence to violate freedom of

association, freedom of thought, political opinion and freedom to exercise the political franchise,

all for political purposes, and to cover up said acts. As such, Defendant Zedillo is liable under

domestic and international law for Plaintiffs' injuries, pain and suffering.

PARTIES

PlaintifJ, Jane Doe 1

4. Plaintiff, Jane Doe I, an individual, sui juris, is a Tzotzil-speaking indigenous

resident of the village of Acteal, municipality of Chenalh6, State of Chiapas, Mexico ("Acteal").

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Jane Doe I brings this action in her individual capacity, as well as in her capacity as next-of-kin

for the extrajudicial killing of Richard Roe I (her father) and Mary Roe I (her mother) during a

mass execution carried out against Acteal villagers by groups armed, sponsored and trained by

members and/or personnel of the Mexican Army, or persons or groups acting in coordination

with the Mexican Army or under its control and protection, on December 22, 1997 ("the Acteal

Massacre"). She brings claims of attempted extrajudicial killing, war crimes, crimes against

humanity, cruel, inhuman and degrading punishment, terror and violence to violate freedom of

association, and terror and violence to violate freedom of thought, political opinion and freedom

to exercise the political franchise for her own mental pain and suffering in living through and

witnessing the Acteal Massacre. She also brings, in her capacity as next-of-kin of her deceased

relatives, claims for war crimes, crimes against humanity, cruel, inhuman and degrading

punishment, terror and violence to violate freedom of association, and terror and violence to

violate freedom of thought, political opinion and freedom to exercise the political franchise.

Jane Doe I seeks to proceed under a pseudonym because she fears reprisals against herself or her

family as a result of her participation in this lawsuit.

Plaintiff. Jane Doe 2

5. Plaintiff, Jane Doe 2, an individual, sui juris, is a Tzotzil-speaking indigenous

resident of the village of Acteal. Jane Doe 2 brings this action in her individual capacity, as well

as in her capacity as next-of-kin for the extrajudicial killing of Richard Roe I (her father) and

Mary Roe I (her mother) during the Acteal Massacre. She brings claims of attempted

extrajudicial killing causing injuries, war crimes, crimes against humanity, cruel, inhuman and

degrading punishment, terror and violence to violate freedom of association, and terror and

violence to violate freedom of thought, political opinion and freedom to exercise the political

3


franchise for her own physical and mental pain and suffering in living through, witnessing, and

being injured during the Acteal Massacre. She also brings, in her capacity as next-of-kin of her

deceased relatives, claims of war crimes, crimes against humanity, cruel, inhuman and degrading



Jane Doe 2 seeks to proceed under a pseudonym because she fears reprisals against herself or her

family as a result of her participation in this lawsuit.

Plaintiff, Jane Doe 3


resident of the village of Acteal. Jane Doe 3 brings this action in her individual capacity, as well

as in her capacity as next-of-kin for the extrajudicial killing of Richard Roe I (her father) and

Mary Roe 1 (her mother) during the Acteal Massacre. She brings claims of attempted

extrajudicial killing, war crimes, crimes against humanity, cruel, inhuman and degrading


violate freedom of thought, political opinion and freedom to exercise the political franchise for

her own mental pain and suffering in living through and witnessing the Acteal Massacre. She

also brings, in her capacity as next-of-kin of her deceased relatives, claims of war crimes, crimes

against humanity, cruel, inhuman and degrading punishment, terror and violence to violate

freedom of association, and terror and violence to violate freedom of thought, political opinion

and freedom to exercise the political franchise. Jane Doe 3 seeks to proceed under a pseudonym

because she fears reprisals against herself or her family as a result of her participation in this

lawsuit.

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Plaintiff, Jane Doe 4


resident of the village of Acteal. Jane Doe 4 brings this action in her individual capacity, for

attempted extrajudicial killing, war crimes, crimes against humanity, cruel, inhuman and



franchise for her own mental pain and suffering in living through and witnessing the Acteal

Massacre. Jane Doe 4 seeks to proceed under a pseudonym because she fears reprisals against

herself or her family as a result of her participation in this lawsuit.

Plaintiff, John Doe 1

8. Plaintiff, John Doe I, an individual, sui juris, is a Tzotzil-speaking indigenous

resident of the village of Acteal. John Doe 1 brings this action in his individual capacity, as well

as in his capacity as next-of-kin for the extrajudicial killing of Mary Roe 2 (his wife) during the

Acteal Massacre. He brings claims of attempted extrajudicial killing, war crimes, crimes against

humanity, cruel, inhuman and degrading punishment, terror and violence to violate freedom of

association and terror and violence to violate freedom of thought, political opinion and freedom

to exercise the political franchise for his own mental pain and suffering in living through and

witnessing the Acteal Massacre. He also brings, in his capacity as next-of-kin of his deceased

relatives, claims of war crimes, crimes against humanity, cruel, inhuman and degrading


violate freedom of thought, political opinion and freedom to exercise the political franchise. John

Doe 1 seeks to proceed under a pseudonym because he fears reprisals against himself or his

family as a result of his participation in this lawsuit.

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9. Plaintiff, John Doe 2, an individual, sui juris, is a Tzotzil-speaking indigenous

resident of the village of Acteal. John Doe 2 brings this action in his individual capacity as well

as in his capacity as next-of-kin for the extrajudicial killing of Mary Roe 2 (his mother), for

attempted extrajudicial killing causing injuries, war crimes, crimes against humanity, cruel,

inhuman and degrading punishment, terror and violence to violate freedom of association, and

terror and violence to violate freedom of thought, political opinion and freedom to exercise the

political franchise for his own physical and mental pain and suffering in living through,

witnessing, and being injured during the Acteal Massacre. John Doe 2 seeks to proceed under a

pseudonym because he fears reprisals against himself or his family as a result of his participation

in this lawsuit.


1 0. Plaintiff, John Doe 3, an individual, sui juris, is a Tzotzil-speaking indigenous



attempted extrajudicial killing causing injuries, war crimes, crimes against humanity, cruel,

inhuman and degrading punishment, terror and violence to violate freedom of association, and

terror and violence to violate freedom of thought, political opinion and freedom to exercise the

political franchise, for his own physical and mental pain and suffering in living through,

witnessing, and being injured during the Acteal Massacre. John Doe 3 seeks to proceed under a

pseudonym because he fears reprisals against himself or his family as a result of his participation

in this lawsuit.

6



II. Plaintiff, John Doe 4, an individual, sui juris, is a Tzotzil-speaking indigenous

resident of the village of Acteal. John Doe 4 brings this action in his individual capacity, for




franchise for his own mental pain and suffering in living through and witnessing the Acteal

Massacre. John Doe 4 seeks to proceed under a pseudonym because he fears reprisals against

himself or his family as a result of his participation in this lawsuit.


12. Plaintiff, John Doe 5, an individual, sui juris, is a Tzotzil-speaking indigenous

resident of the village of Acteal. John Doe 5 brings this action in his individual capacity, for




franchise for his own mental pain and suffering in living through and witnessing the Acteal

Massacre. John Doe 5 seeks to proceed under a pseudonym because he fears reprisals against

himself or his family as a result of his participation in this lawsuit.


1 3. Plaintiff, John Doe 6, an individual, sui juris, is a Tzotzil-speaking indigenous




7




franchise, for his own mental pain and suffering in living through, witnessing, and being injured

during the Acteal Massacre. John Doe 6 seeks to proceed under a pseudonym because he fears

reprisals against himself or his family as a result of his participation in this lawsuit.

Defendant Ernesto Zedillo Ponce de Leon

14. Defendant Zedillo, an individual, sui juris, is a native and citizen of Mexico.

Defendant Zedillo currently resides in Connecticut, and has resided in the u.s. for the last 1 1

years. From December 1, 1994 to November 30, 2000, Defendant Zedillo served as the

President of Mexico.

JURISDICTION AND VENUE

15. This Court has jurisdiction over this action based on 28 U.S.C. § 1350 (the Alien

Tort Claims Act as well as the Torture Victim Protection Act codified in the note of said code),

28 U.S.C. § 1331, and 28 U.S.C. §§ 2201 and 2202.

16. On information and belief, Defendant Zedillo resides in Connecticut. Therefore

venue is proper in the United States District Court for the District of Connecticut pursuant to 28

U.S.C. § 1391 (b) and/or (d).

17. Defendant Zedillo' s actions set forth herein violate, and Plaintiffs' causes of

action arise from, the law of nations and/or laws or treaties of the United States, including, inter

alia, the following laws, agreements, conventions, resolutions, and treaties, which constitute

specific examples of the applicable law of nations or customary intemational law:

a. Alien Tort Claims Act, 28 U.S.C. § 1350;

b. Torture Victim Protection Act, 28 U.S.C. § 1350;

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c. Common law of the United States of America;

d. United Nations Charter, 59 Stat. 1031,3 Bevans 1 1 53 (1 945);

e. Universal Declaration of Human Rights, G.A. Res. 21 7A(iii), U.N. Doc. Al810

(1 948);

f. International Covenant on Civil and Political Rights, G.A. Res. 2220(A)(xxi), 21

U.N. Doc., GAOR Supp. (No. 1 6) at 52, U.N. Doc. Al63 1 6 (1966);

g. International Covenant Against Torture and Other Crue!, Inhuman or Degrading

Treatment or Punishment, G.A. Res. 39/46, 39 U.N. Doc., GAOR Supp. (No. 5 1 )

at 197, U.N. Doc. Al39/51 ( 1 984) (ratified 1 0/28/1998);

h. Declaration on the Protection of All Persons From being Subjected to Torture and

other Cruel, Inhuman or Degrading Treatment or Punishment, G.A. Res. 3452, 30

U.N. Doc., GAOR Supp. (No. 34) at 91, U.N. Doc. Al1 0034 ( 1 976);

1. Vienna Declaration and Programme of Action (World Conference on Human

Rights, 1 993);

J. Article 3 of the Geneva Conventions (Convention for the Amelioration of the

Condition of the Wounded and Sick in Armed Forces in the Field, entered into

force Oct. 2 1 , 1 950,for the United States Feb. 2, 1 956, 6 U.S.T. 31 14, T.l.A.s.

3362, 75 U.N.T.S. 31 ; Convention for the Amelioration of the Condition of the

Wounded, Sick, and Shipwrecked Members of Armed Forces at Sea, entered into

force Oct. 2 1 , 1950,for the United States Feb. 2, 1 956,6 U.S.T. 3217, T.l.A.S.

3363,75 U.N.T.S. 85; Convention Relative to the Treatment of Prisoners of War,

entered into force Oct. 2 1 , 1950, for the United States Feb. 2, 1956, 6 U.S.T.

3316, T.I.A.S. 3364, 75 U.N.T.S. 135; Convention Relative to the Protection of

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Civilian Persons in Time of War, entered int% rce Oct. 21, 1950, /or the United

States Feb. 2, 1956, 6 U.S.T. 3516, T.I.A.S. 3365, 75 U.N.T.S. 287.) (the "Four

Geneva Conventions"); and

k. Statutes and common law of Mexico.

STATEMENT OF FACTS

Background

18. The State of Chiapas, Mexico ("Chiapas") is a mountainous region located in the

south-central area of Mexico, bordering Guatemala. Historically, the economic advances and

modernity of other regions of Mexico, including Mexico City, have not benefitted the residents

of Chiapas. Chiapas has been among the most underdeveloped states in the country. Most of the

residents of Chiapas live in extreme poverty and have had little access to the most basic services,

including electricity, sanitation, medical care, education, and dependable transportation. Prior to

1994, Chiapas was fairly isolated from the government power center in Mexico City, and there

was little investment in the region. Roads to many of the villages and towns were nonexistent or

in precarious condition, resulting in their isolation.

19. This situation was exacerbated by persistent racist attitudes toward many of the

inhabitants of Chiapas. Most people in those areas are of indigenous descent, unlike the white or

mestizo popUlations of the developed areas of Mexico, including Mexico City. Many speak a

variety of languages, including Tzotzil, as their first language, rather than Spanish. These ethnic

and cultural differences played significant roles in the mistreatment endured by Chiapas residents

from Mexican governmental entities and the wealthy landowners of the region.

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20. On January 1, 1994, the Ejercito Zapatista de Liberaci6n Nacional, or Zapatista

Army of National Liberation ("EZLN"), an indigenous, separatist movement in Chiapas,

announced its existence and promptly declared war against the Mexican Govermnent.

2 1. The EZLN advocates a socialist ideology that demands social and economIC

justice for indigenous populations. The EZLN attempted to promote its social policies by means

of armed conflict against the Mexican Govermnent.

22. Several organizations, known as civil societies, which were not associated with

any federal or state govermnent, were formed in Chiapas at that time, including, inter alia, the

civil society known as "Las Abejas" ("The Bees").

23. Las Abejas was, and remained at all relevant times, a pacifist organization not

affiliated with the Mexican Govermnent. Due to its pacifist nature, Las Abejas was also opposed

to the EZLN, which advocated violence as a means to its ends.

24. A large majority of the residents of Acteal, including the Decedents and the

Plaintiffs, were members of Las Abejas and fully ascribed to its non-violent, pacifist practices.

25. On or about January 2, 1994, regular Mexican Army units moved into Chiapas

and engaged in armed confrontation with EZLN forces.

26. Shortly thereafter, the Mexican Govermnent under then-President Carlos Salinas

de Gortari ("Salinas") entered into peace negotiations with the EZLN. Salinas declared a

unilateral cease-fire and offered amnesty to those EZLN members who chose to reintegrate into

society. The peace negotiations between the Mexican Govermnent, under Salinas, and the EZLN

resulted in the Mexican Government passing an Amnesty Law that became effective on January,

22 1994.

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Defendant Zedillo Becomes President of Mexico

27. On August 21, 1994, Defendant Zedillo, was elected President of Mexico.

28. The transition period between the Salinas administration and Defendant Zedillo's

incoming administration was August 21, 1994 to December 1, 1 994.

29. On December 1, 1994, Defendant Zedillo was sworn into office as the President

of Mexico.

Plan de Campana Chiapas '94

30. In or about December 1994, soon after Defendant Zedillo was sworn in, a military

campaign plan was adopted with the aim of suppressing the EZLN, as well as all political and

military support for that organization in Chiapas (hereinafter, "Plan de Campana Chiapas '94").

A certified translation as well as an apostilled and certified copy of a document outlining the

Plan de Campana Chiapas '94, along with excerpts of the Mexican Senate Record incorporating

same, as introduced in the Senate of the United States of Mexico on or about December 14,

2010, is attached hereto and incorporated herein by reference as Composite Exhibit "1" (the

"Senate Record").

31. The Chiapas campaign contemplated in the Plan de Campana Chiapas '94 was

divided into four designated phases: Preparation Phase, Offense Phase, Development Phase, and

Final Phase. See Plan de Campana Chiapas '94 incorporated as part of Senate Record at 22658-

59 (the page numbers are located on the top right hand comer of that document).

32. The Preparation Phase focused on the organization, training and deployment of

both military and civilian forces that would participate in the Chiapas campaign. Detailed

operational plans for the campaign were to be prepared during this phase. [d. at 22658.

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33. The Offense Phase focused on the eradication, dispersal and expulsion of EZLN

military forces from Chiapas, as well as the subsequent occupation of Chiapas by military and

police forces. ld.

34. The Offense Phase contemplated the application of the principle of war involving

concentration of military forces in areas ofChiapas under EZLN control. Id. at 22667.

35. In applying this philosophy, certain operational aspects of the Offense Phase

included the suspension of civil rights in Chiapas, including:

a. Forced displacement of civilian populations in EZLN-controlled areas to areas

under Mexican Government control;

b. Neutralization of the organization and activities of the diocese of San Cristobal de

las Casas;

c. Capture and detention of "Mexican [nationals] identified with the EZLN;"

d. Capture and expulsion of "pernicious foreigners;"

e. Prohibition of commercial flights into EZLN-controlled areas;

f. Censorship of mass media;

g. Destruction or control of equine and/or bovine herds;

h. Destruction of crops and harvests;

1. Deployment of paramilitary and civilian self-defense forces; and

J. Suspension of communications in EZLN-controlled areas, including mail,

telephone and telegraph service. ld. at 22667-68.

36. The Development Phase focused on the elimination of remammg EZLN

operational nuclei, as well as the prevention of the return of EZLN forces that had been

previously expelled from Chiapas. Id. at 22658.

1 3


37. Part of the Plan de Campana Chiapas '94 encompassed efforts to create, train, and

support self-defense forces and other paramilitary entities which would assist in military

operations during both the Offense and Development Phases. ld at 22663, 22668.

38. The Final Phase focused on continued support to local organizations and

authorities to enable them to carry out self-defense operations against the EZLN. ld at 22659.

39. When applied, the Plan de Campana Chiapas '94 violated the Mexican

Constitution, the laws of Mexico, international treaties and accords, and customary international

law.

40. On or about January 4, 1998, the weekly publication Proceso first revealed the

existence of the Plan de Campana Chiapas '94 (the "Proceso Article"). Excerpts of a certified

and apostilled copy as well as a certified translation of the Proceso Article is attached hereto and

incorporated herein by reference as Exhibit "2".

41. On or about January 6, 1998, the Secretariat of National Defense (the Mexican

Department of Defense) issued a statement denying the existence of the Plan de Campana

Chiapas '94 referred to in the Proceso Article. A copy and a certified translation of an article in

La Jornada periodical dated January 6, 1998 reflecting same is attached hereto and incorporated

herein by reference as Exhibit "3".

Defendant Zedillo Terminates the Chiapas Peace Process

42. Due to mismanagement of the economy during the last year of the Salinas

Administration, on December 20, 1994, Treasury Secretary Jaime Serra Puche announced the

devaluation of the peso, driving the Mexican economy into crisis. The Mexican Government

promptly commenced efforts to obtain bail-out funds from the United States of America and the

International Monetary Fund.

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43. Defendant Zedillo decided to terminate the peace process before he even took

office. In May 1994, when only a candidate for the office of the presidency, Zedillo censured

Manuel Camacho, the Peace Commissioner for Chiapas. Camacho was the Federal

Government's representative for the peace negotiation between the Mexican Government and the

EZLN. Faced with Zedillo's censure, Camacho had no choice but to resign his post, doing so on

or about June 16, 1994. Afterwards, in a public letter, Camacho stated that his resignation was

the product of Zedillo' s decision to denounce the peace process, characterizing it as a failure.

Camacho indicated that "[there exist] two different political paths to achieve peace in Chiapas."

One path, that of negotiation, "consists in creating those conditions that avoid the dynamics of

war." The other path, Zedillo's choice, "involves wearing down the rebel movement, misleading

public opinion and renouncing time and again its offers and public compromises." An apostilled

original and certified translation of Camacho's letter is attached hereto and incorporated herein

as Composite Exhihit "4."

44. On or about January 13, 1 995, Riordan Roett, at the time Chase Manhattan

Bank's consultant on Latin America's emerging markets, authored an internal memorandum

entitled "Political Update on Mexico" (the "Roett Memo"). A copy of the Roett Memo is

attached hereto and incorporated herein by reference as Exhibit "5".

45. The Roett Memo stated, inter alia:

Until the administration of President Ernesto Zedillo identifies the appropriate policies to stabilize the peso and avoid uncontrolled inflation, it will be almost impossible to address issues such as Chiapas and judicial and electoral reform.

***

There are three areas in which the current monetary crisis can undermine political stability in Mexico. The first is Chiapas; the second in [sic] the upcoming state elections; and the third is the role of the labor unions, their relationship to the government and the governing PRI [Partido Revolucionario Institucional ("PRJ"),

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one of Mexico's two largest political parties, which dominated Mexican national politics for approximately 70 years up to 1994. Zedillo was a member of PRI].

***

Moreover, to the degree that the monetary crisis limits the resources available to the government for social and economic reforms, it may prove difficult to win popular support for the Zedillo administration's plans for Chiapas. More relevant, [Sub-cornmander] Marcos and his supporters may decide to embarrass the government with an increase in local violence and force the administration to cede to Zapatista [EZLN] demands and accept an embarrassing political defeat. The

alternative is a military offensive to defeat the insurgency which would create an international outcry over the use of violence and the suppression of indigenous rights.

While Chiapas, in our opinion, does not pose afundamental threat to Mexican political stability, it is perceived to be so by many in the investment community. The government will need to eliminate the Zapatistas to demonstrate their effective control of the national territory and of security policy.

*.*

The Mexican monetary crisis has overshadowed the commitment of the Zedillo administration to a new wave of political reforms that include political negotiations to resolve the Chiapas crisis and to guarantee fair elections at the state and municipal levels.

(Emphasis added.)

46. On or about February 1, 1995, the Roett Memo was leaked to the press. A copy

of an article of that same date in the periodical Counter punch first disclosing the existence and

contents of the Roett Memo and a copy of a March 24, 1995 article in the National Catholic

Reporter regarding the Roett Memo are attached hereto and incorporated herein by reference as

Composite Exhibit "6".

47. Within days of the issuance of the Roett Memo, Defendant Zedillo terminated

peace negotiations between the EZLN and the Mexican Government, begun under the previous

Salinas administration, and unsuccessfully attempted to arrest EZLN leader Marcos, referring to

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him as a seditious traitor. These steps were viewed as a betrayal by the government, creating

further conflict in the region and markedly increasing the distrust between the parties.

48. Thereafter, in or about February 1995, the Mexican Government, using police and

military forces, implemented the Plan de Campana Cbiapas '94 and commenced a military

campaign, including the eradication, dispersal and expulsion of EZLN military forces from

Chiapas, as well as the suppression of all political and civilian entities perceived to be

sympathetic to the EZLN.

49. In or about February of 1995, Chiapas was declared a military zone, and Mexican

Army troops were deployed into its territory.

50. As a consequence of mismanagement of the economy during 1 994 and of the

1 995 economic crisis and the devaluation of the Mexican peso, the armed conflict in Chiapas

intensified. The social infrastructure of Cbiapas was also weakened as a result of mass

migration. The Mexican Senate found that the political and economic policies of Defendant

Zedillo's administration drove over 15 million Mexicans into extreme poverty and caused over

five million Mexicans to emigrate to the United States.

51. In or about 1 996, a special federal cabinet was formed to address the conflict in

Chiapas (the "Special Chiapas Cabinet").

52. The Special Chiapas Cabinet included Defendant Zedillo; the Secretary of

Defense; the Governor of the State of Chiapas; the Director General of the Center for Research

and National Security ("CISEN"); the Commissioner for the Peace Dialogue; the Secretary of

Interior, Emilio Chuayffet ("Chuayffet"); and the Federal Solicitor General and Attorney

General, Jorge Madrazo Cuellar.

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Defendant Zedillo's Administration Arms and Supports Anti-EZLN Villagers In Chiapas

53. As part of the Plan de Campana Chiapas '94, Defendant Zedillo's administration

pursued a policy whereby members of villages in Chiapas opposed to the EZLN (the "Anti

EZLN Villagers") were allowed to obtain military-caliber automatic and semi-automatic

weapons (the "Assault Rifles") directly or indirectly from members of the Mexican Army or

other persons or groups acting in concert with the Mexican Army.

54. Anti-EZLN Villagers also received training and support from members of the

Mexican Army stationed in Chiapas. Anti-EZLN Villagers were allowed to openly carry the

Assault Rifles.

55. Mexican law prohibits civilians from owning or possessing Assault Rifles. The

arming of Anti-EZLN Villagers with Assault Rifles and training them to use those weapons

violated Mexican law.

56. Although many Anti-EZLN Villagers openly displayed Assault Rifles in public,

law enforcement authorities oftentimes took no action, despite these clear violations of Mexican

law. When police officers did occasionally seize Assault Rifles from Anti-EZLN Villagers,

those weapons were eventually returned to the same Anti-EZLN Villagers.

57. The goal of allowing Anti-EZLN Villagers to engage in such conduct with

impunity was to suppress and intimidate villages purportedly sympathetic to the EZLN, and to

coerce those villages to oppose the EZLN.

58. The increase in paramilitary activities of Anti-EZLN Villagers in a particular area

coincided with the arrival and embedding of Mexican Army units in that area, as well as the

training of Anti-EZLN Villagers by those Mexican Army units, pursuant to the Plan de Campana

Chiapas '94. A copy of a report reflecting same that was directed to the U.S. Defense

18


Intelligence Agency ("DIA"), dated May 5, 1 999 (the "May 1 999 DIA Report") and declassified

in February 2008 pursuant to Freedom of Information Act ("FOIA") Request No. 38,435, is

attached hereto and incorporated herein by reference as Exhibit "7".

59. In or about mid-1 997, armed Anti-EZLN Villagers commenced a terror campaign,

including a series of kidnappings and homicides, many in towns throughout about one-fourth of

Chiapas, including within the municipality of ChenalhO.

60. Many residents in the affected villages supported neither the policies of

Defendant Zedillo' s administration nor the armed conflict espoused by the EZLN. As a result of

the kidnappings and murders orchestrated by Anti-EZLN Villagers, many residents of these

affected villages fled to Acteal and other villages.

6 1 . Between approximately May and December 1997, many villagers from towns and

communities around Acteal were displaced due to the conflict in Chiapas. Many of these

displaced villagers were members of or were affiliated with Las Abejas, and fled to Acteal.

62. On September 30, 1997, the inhabitants of Chenalh6 delivered a letter to

Defendant Zedillo, Chiapas State Governor Julio Cesar Ruiz Ferro, and other members of the

Mexican Government (the "September 30 Demand"). A certified translation as well as a

certified copy of the September 30 Demand is attached hereto and incorporated herein by

reference as Composite Exhibit "8".

63. In the September 30 Demand, the inhabitants of ChenalhO reported a string of

attacks and kidnappings, specifically complaining that Anti-EZLN Villagers were being allowed

to possess and openly carry Assault Rifles in violation of Mexican law. The inhabitants of

Chenalh6 demanded that the law be enforced.

1 9


64. On October 18, 1997, Msgr. Raul Vera-Lopez, Coadjutor Bishop of the diocese of

San Cristobal de las Casas, drafted a letter directed to Interior Secretary Chuayffet informing him

of the incidents of violence and the fact that Anti-EZLN Villagers and other paramilitary groups

were being trained and provided with weapons (the "Vera Letter"). In the Vera Letter, Bishop

Vera-Lopez also warned Defendant Zedillo that "a bloodbath" was imminent. A certified

translation as well as an apostilled and certified copy of the Vera Letter is attached hereto and

incorporated herein by reference as Composite Exhibit "9".

65. Bishop Vera-Lopez delivered the Vera Letter to Chuayffet, who personally hand-

delivered that letter to Defendant Zedillo, before the Acteal Massacre.

66. On or about December 7, 1997, Televisa nationally televised a special news report

prepared by Ricardo Rocha regarding the condition of displaced civilians around Acteal, caused

by violence attributed to counter-insurgency activities of Anti-EZLN Villagers.

67. On December 2 1, 1997, a group of displaced villagers who had sought refuge in

Acteal called for the aid of Mexican legislators who were visiting the nearby town of Polho. The

displaced villagers advised the legislators that members of their communities were being held

against their will by Anti-EZLN Villagers and other paramilitary groups. These villagers further

advised the legislators that they were under imminent threat of death or serious bodily harm.

The Acteal Massacre

68. News regarding increasing violence fomented by Anti-EZLN Villagers and other

paramilitary groups in Chiapas, brought by displaced persons seeking refuge in Acteal, caused

grave concern to the residents of Acteal.

20

Case 3:11-cv-01433-AWT Document 1 Filed 09/16/11 Page 21 of 28•

69. As a result of this news, on or about December 20, 1 997, most of the residents of

Acteal, who were also members of Las Abejas, held a retreat in and around the small chapel

located within Acteal proper (the "Acteal Chapel") to pray and fast as a community.

70. The retreat in the Acteal Chapel was held in the name of peace and the hope for

an end to the violence in Chiapas. Over 350 people attended the retreat.

71. On December 22, 1997, Anti-EZLN Villagers from surrounding villages, armed

with Assault Rifles, arrived at Acteal. Many of the Anti-EZLN Villagers wore red bandanas to

identify themselves to each other.

72. Accompanying the Anti-EZLN Villagers arriving at Acteal were individuals who

spoke only Spanish, had crew-cut style haircuts, and wore uniforms of the local police and/or the

Mexican Army. These persons appeared to be directing, coordinating, acting in concert with,

and/or aiding and abetting the activities of the Anti-EZLN Villagers. At that time, there were no

peace-keeping operations being conducted in the area around Acteal.

73. At approximately 10:30 a.m. on December 22, 1997, the Anti-EZLN Villagers

encircled the perimeter of Acteal and began firing on its residents.

74. As the Anti-EZLN Villagers shrank the perimeter, they concentrated their fire on

the residents of Acteal, who were praying and fasting at their retreat in the Acteal Chapel.

75. Fearing for their lives, many of the residents of Acteal were able to escape

through the perimeter and flee into the countryside.

76. Anti-EZLN Villagers pursued the escaping Acteal residents and continued firing

upon the villagers, killing or injuring many of them.

77. Although both Mexican Army and local police units were in the vicinity of Acteal

and could hear the gunshots fired by the Anti-EZLN Villagers throughout the Acteal Massacre,

21


local police units did not enter Acteal, to recover the bodies of the dead or dying, until

approximately 12:30 a.m. on December 23, 1 997, some 14 hours after the massacre had begun.

78. By that time, the Anti-EZLN Villagers and supporting personnel had left Acteal.

79. The Acteal Massacre crime scene was not maintained for investigation.

80. All told, the Anti-EZLN Villagers slaughtered 45 residents of Acteal, including

seven adult males, twenty adult females (four of whom, on information and belief, were

pregnant), and eighteen minors, one of them a toddler. A copy of a report directed to the DIA

and summarizing the Acteal Massacre, prepared soon thereafter (the "December 1997 DIA

Report"), declassified in February 2008 pursuant to FOIA Request No. 38,435, is attached hereto

and incorporated herein by reference as Exhibit "10".

8 1. Additionally, 17 other Acteal residents were wounded as a result of the massacre.

82. Among those slain by the Anti-EZLN Villagers and/or supporting personnel were

Decedents Richard Roe I, Mary Roe I and Mary Roe 2.

83. Among those wounded by the Anti-EZLN Villagers and/or supporting personnel

were Jane Doe 2, John Doe 2, and John Doe 3. Specifically:

a. Plaintiff Jane Doe 2 [was physically injured as a result of the Acteal

Massacre];

b. Plaintiff John Doe 2 [was physically injured as a result of the Acteal

Massacre]; and

c. Plaintiff John Doe 3 [was physically injured as a result of the Acteal

Massacre].

22


84. Among those fired upon by the Anti-EZLN Villagers and/or their supporting

personnel, but who escaped immediate physical injury, were Plaintiffs Jane Doe 1, Jane Doe 3,

Jane Doe 4, John Doe I, John Doe 4, John Doe 5, and John Doe 6.

Zedillo's Conduct During the Acteal Massacre

85. On December 22, 1997, the Director General of CIS EN (the Center for Research

and National Security) and, thereafter, Chuayffet personally notified Defendant Zedillo of the

Acteal Massacre while it was in progress.

86. Defendant Zedillo was taping a Christmas message to the nation at the time when

he was notified of the Acteal Massacre, causing him to interrupt taping for a period of time.

87. Notwithstanding, the Acteal Massacre continued unabated for hours.

88. After finishing taping his Christmas message, Defendant Zedillo met with Felipe

Calderon, then the leader of the opposition party, Partido de Action Nacional (the "PAN"), and

currently the President of Mexico. A certified translation as well as an apostilled and certified

copy of Defendant Zedillo's agenda for December 22, 1997, is attached hereto and incorporated

herein by reference as Composite Exhibit "11".

The Cover-Up

89. In order to hide his complicity and liability for the Acteal Massacre, Defendant

Zedillo, along with Jorge Madrazo Cuellar, the Solicitor General and Attorney General of

Mexico ("Madrazo"), and other individuals known and unknown to Plaintiffs, and other

members of the Mexican Government including, inter alia, individual members and/or agents of

one or more subdivisions, instrumentalities and/or agencies of Zedillo's government,

orchestrated and participated in a conspiracy to cover up any connection to, responsibility for,

involvement with, or participation in the Acteal Massacre (the "Cover-Up").

23


90. Following the Acteal Massacre, both national and international media arrived at

Acteal to cover the scene. Defendant Zedillo and Madrazo initially represented to the press that

the Acteal Massacre was nothing more than a local, inter-community dispute.

91. In furtherance of the Cover-Up, 128 persons from the area surrounding Acteal

were arrested at the direction of the PGR (Procuraduria General de la Republica), the Attorney

General's Office for the Republic of Mexico, the agency that led the investigation and

prosecutions relating to the Acteal Massacre. Madrazo was director ofPGR at the time.

n. In or about 1998, the PGR issued the Libra Blanco Sabre Acteal (White Book on

Acteal, or the "White Book"), a publication which set forth the position of the Mexican

Government purporting to finally resolve, settle, and put to rest all issues relating to the Acteal

Massacre. (The White Book is too voluminous to file as an exhibit at this time. Plaintiffs

possess a copy and will produce and/or file it upon request.)

93. In the White Book, the PGR attributed the causes of the Acteal Massacre to, inter

alia, (a) local, inter-community disputes; (b) the continued existence and operations of the

EZLN; and (c) a lack of competent local judicial, administrative and law enforcement

infrastructure in Chiapas. See White Book at 99.

The Plan de Campana Chiapas '94 is Disclosed to the Public

94. Although the existence of the Plan de Campana Chiapas '94 had been the subject

of news articles since 1 998, its existence was denied for years by the Secretariat of National

Defense.

95. In February 2008, both the December 1997 DIA Report and the May 1 999 DIA

Report, previously classified as secret documents, were declassified under FOIA Request No.

38,435. The DIA reports are attached to and incorporated by reference in the April 7, 201 1

24


report submitted by the Chiapas Special Prosecutor's Office for the Acteal Case, entitled Balance

de Situacion ("Summary of the Situation"). (This report is too voluminous to file as an exhibit at

this time. Plaintiffs possess a copy and will file and/or produce it upon request.)

96. The declassification of the December 1 997 DIA Report and the May 1999 DIA

Report confirmed the de facto involvement of members and/or personnel of the Mexican Army,

and/or persons or groups acting in coordination with or under the control and protection of the

Mexican Army, in the training and arming of Anti-EZLN Villagers.

97. On or about December 14, 2010, the contents of the Plan de Campafia Chiapas

'94 became part of the Mexican Senate Record, when incorporated into a legislative resolution

stipulating that further investigation into the Acteal Massacre was required. See Exhibit 1 .

98. On information and belief, the Secretariat of National Defense has, to date, not

commented on the introduction into the Senate Record of the Plan de Campafia Chiapas '94.

Investigation of the Acteal Massacre by the Chiapas Special Prosecutor

99. On or about December 22, 2007, Attorney Noe Maza was nominated by the state

government of Chiapas as special prosecutor for the purpose of investigating the Acteal

Massacre (the "Chiapas Special Prosecutor").

I 00. Shortly after his appointment as Chiapas Special Prosecutor, Mr. Maza was

ordered by Amador Rodriguez, the Chiapas Minister of Justice, to not take the testimony of

Defendant Zedillo, Chuayffett, or Liebano Saenz, Defendant Zedillo' s chief of staff at the time

of the Acteal Massacre ("Saenz").

1 0 1 . On information and belief, notwithstanding the order to the contrary, Mr. Maza

continued in his efforts to take the testimony of Defendant Zedillo, Chuayffett, and Saenz. Mr.

Maza was unsuccessful in this regard.

25


102. In or about July 2008, Mr. Maza held a press conference announcing that it was

possible that some of the alleged perpetrators of the Acteal Massacre could be innocent of the

crimes for which they were charged and ultimately convicted.

103. Shortly after this press conference, Mr. Maza was relieved of his duties as

Chiapas Special Prosecutor. A certified translation as well as an apostilled and certified copy of

a September 7, 2008 article in La Jornada reflecting this fact is attached hereto and incorporated

herein by reference as Composite Exhibit " 12".

The Decision of The Supreme Judicial Court of Mexico

I 04. On October 4, 2007, over 34 persons were convicted of various crimes arising

from the Acteal massacre, including culpable homicide, aggravated battery, possession or

carrying of weapons of restricted and/or military use, and other violations of Mexican law

relating to weapons and explosives, and were sentenced to 26 years' incarceration. Not less than

20 of those convicted were innocent of any wrongdoing in connection with the Acteal Massacre.

1 05. On or about August 12, 2009, the Supreme Judicial Court of Mexico (the

"Supreme Court") entered a decision determining that the arrests and convictions of 20

individuals resulting from the PGR's prosecution of the Acteal Massacre had violated Mexican

criminal procedure, criminal law and constitutional due process, and were released from prison

(the "Supreme Court Decision"). Another six were granted new trials due to those violations.

106. In the Supreme Court Decision, the Supreme Court found, inter alia, that:

a. There were materially significant discrepancies in testimony between and

among victims regarding both the appearance and clothing of the alleged perpetrators of

the Acteal Massacre, Supreme Court Decision, Juicio de Amparo Directo No. 39/2008

Folio 280.

26


b. There were material retractions of testimony which could have exonerated

one or more defendants in the prosecution of the Acteal Massacre. Id.

c. Prosecution witnesses, who could not identify many of the alleged

perpetrators of the Acteal Massacre during their initial declarations, later confessed that

the Federal Judicial Police provided them with a list of the names and villages of

residence of those alleged perpetrators after those witnesses had provided their initial

declarations. It was then that these prosecution witnesses supplemented their initial

declarations with additional details including the names and communities ofthose alleged

perpetrators, within 12 hours of the initial declarations in many instances. Acteal

Massacre, Supreme Court Decision, Juicio de Amparo Directo No. 9/2008 Folio 237, af

reverso, hasta 239.

d. The Federal Judicial Police obtained a book of photographs used for

identification of the accused, prior to the arrest of those individuals and prior to any

victim identifying the persons whose photographs were contained in that book. That

photographic evidence was obtained for the intentional purpose of altering the testimony

of witnesses to identify and implicate the persons in the photographs as the alleged

perpetrators of the Acteal Massacre. Acteal Massacre, Supreme Court Decision, Juicio

de Amparo Directo No. 10/2008 Folio 278.

e. The PGR illegally obtained and formulated evidence for the purpose of

convicting the alleged perpetrators of the Acteal Massacre. Acteal Massacre, Supreme

Court Decision, Juicio de Amparo Directo No. 1012008 Folio 275.

f. Defendants in the prosecution of the Acteal Massacre were denied their

constitutional right to a live face-to-face confrontation of those prosecution witnesses

27


who had previously given declarations implicating those defendants. Acteal Massacre,

Supreme Court Decision, Juicio de Amparo Directo No. 10/200S Folio 2S0.

g. The PGR misrepresented the dates and proceedings corresponding to

various witness declarations used as substantive evidence, in order to obtain guilty

verdicts, in direct violation of Mexican criminal procedure. Acteal Massacre, Supreme

Court Decision, Juicio de Amparo Directo No. 1 01200S Folio 255.

107. As a result of the Supreme Court Decision, the convictions of 20 defendants were

reversed and those defendants were released from prison after I I years of incarceration.

Conduct of the Elements of the Mexican Army Stationed In Chiapas Since the Acteal Massacre

l OS. Despite the Acteal Massacre on December 22, 1997, elements of the Mexican

Army stationed in Chiapas have continued to arm and support Anti-EZLN Villagers as part of

the Plan de Campana Chiapas '94.

109. On information and belief, between 1 997 and the present, Anti-EZLN Villagers,

elements of the Mexican Army, and the police have continued to engage in summary executions,

detentions, and forced displacement of members of indigenous communities in Chiapas,

notwithstanding the subsequent changes in administrations and the Supreme Court Decision.

GENERAL ALLEGATIONS

1 10. The acts described herein were carried out under actual or apparent authority or

color of law of the Mexican Government. Defendant Zedillo bears responsibility for exercising

command responsibility over, ordering, engaging in a joint criminal enterprise with, conspiring

with, and/or aiding and abetting other members of the Mexican Government including, inter alia,

individual members and/or agents of one or more subdivisions, instrumentalities and/or agencies

2S

Case 3:11-cv-01433-AWT Document 1-1 Filed 09/16/11 Page 1 of 25

of that government, to carry out and/or participate In the Acteal Massacre, as well as the

subsequent Cover-Up.

I l l . Defendant Zedillo knew or should have known about the events leading up to the

Acteal Massacre, as well as the human rights abuses committed during the Acteal Massacre.

1 1 2. The extrajudicial killings and attempted extrajudicial killings inflicted upon the

Decedents and the Plaintiffs formed part of a widespread pattern and practice of systematic

human rights violations committed against the civilian population of Chiapas by members and/or

agents of one or more subdivisions, instrumentalities andlor agencies of the Mexican

Government.

1 1 3 . Defendant Zedillo exercised command responsibility over, conspired, andlor

acted in concert, directly andlor indirectly, with various members andlor agents of one or more

subdivisions, instrumentalities andlor agencies of the Mexican Government to commit

extrajudicial killings, attempted extrajudicial killings, war crimes, crimes against humanity,

cruel, inhuman and degrading punishment, terror and violence to violate freedom of association,

and terror and violence to violate freedom of thought, political opinion and freedom to exercise

the political franchise. In addition to being personally liable for his own actions, Defendant

Zedillo is jointly and severally liable for the actions of various members andlor agents of one or

more subdivisions, instrumentalities andlor agencies of the Mexican Government, all of which

were actions undertaken in furtherance of a common plan, design and scheme to commit human

rights abuses against the civilian population of Chiapas, including the Acteal Massacre and the

subsequent Cover-Up.

1 14. Defendant Zedillo knew or should have known that his actions and omissions

would assist in these abuses at a time when he exercised command responsibility over, ordered,

29


and/or aided and abetted those members and/or agents of one or more subdivisions,

instrumentalities and/or agencies of the Mexican Government who participated directly or

indirectly in the Acteal Massacre and the Cover-Up. In addition to being personally liable for his

own actions, Defendant Zedillo is jointly and severally liable for the actions of those he

exercised command responsibility over, ordered, and/or aided and abetted.

1 1 5. Defendant Zedillo knew or should have known that his subordinates were

committing human rights abuses, and he failed to prevent the abuses or punish those responsible.

1 1 6. Defendant Zedillo also engaged in a j oint criminal enterprise with members

and/or agents of one or more subdivisions, instrumentalities and/or agencies of the Mexican

Government who carried out the Acteal Massacre to commit extrajudicial killings, attempted

extrajudicial killings, war crimes, crimes against humanity, cruel, inhuman and degrading



1 1 7. The extrajudicial killings, attempted extrajudicial killings, war crimes, crimes


freedom of association and terror and violence to violate freedom of thought, political opinion

and freedom to exercise the political franchise committed during the Acteal Massacre were part

of an organized system of repression against the civilian population of Chiapas. Defendant

Zedillo had knowledge of, exercised command responsibility over, ordered, and/or was a

participant in this system of repression against the civilian population of Chiapas. It was

Defendant Zedillo's intent to further this system of repression.

1 1 8. The extrajudicial killings, attempted extrajudicial killings, war crimes, cnmes


30


freedom of association and terror and violence to violate freedom of thought, political opinion

and freedom to exercise the political franchise committed during the Acteal Massacre were

foreseeable consequences of a common, shared intent by Defendant Zedillo and various

members and/or agents of one or more subdivisions, instrumentalities and/or agencies of the

Mexican Government to further the system of repression against Chiapas' civilian population.

1 1 9. The acts and omissions were outside the scope of Defendant Zedillo' s lawful

authority and were not authorized by international or Mexican law.

Equitable Tolling of the Statute of Limitations

120. The Statute of Limitations was equitably tolled through August 12, 2009.

1 2 1 . Plaintiffs could not have brought their lawsuit in the United States against

Defendant Zedillo prior to the date when the Supreme Court Decision was published.

122. Specifically, the Supreme Court Decision de facto finally recognized that

Defendant Zedillo and other members of the Mexican Government including, inter alia,

individual members and/or agents of one or more subdivisions, instrumentalities and/or agencies

of said government, including Madrazo, had orchestrated and participated in the Cover-Up.

123. Immediately after the Acteal Massacre, Defendant Zedillo, Madrazo and others

knowingly and falsely represented to the press that the atrocity was merely a local, inter

community dispute in which the Mexican Government had played no part.

124. In furtherance of the Cover-Up, the PGR, under Madrazo' s direction, arrested

over 128 persons and falsely charged them for the Acteal Massacre. Of these, none were the

Anti-EZLN Villagers but, rather, local politicians and residents of villages surrounding Acteal

and members of the local police force.

3 1


1 25. As set forth in the Supreme Court Decision, in prosecuting those accused of

having committed the Acteal Massacre, the PGR obviously, blatantly and/or egregiously violated

Mexican criminal procedure, criminal law and constitutional due process, which should have

been prohibited by the Mexican Federal Court in Chiapas, but were not.

126. On or about October 4, 2007, as a result of the Mexican Federal Court in Chiapas

having permitted those procedural, legal and constitutional violations, at least 20 innocent people

were falsely convicted of crimes committed during the Acteal Massacre and sentenced to 26

years of incarceration.

127. Those falsely convicted persons were incarcerated from their initial arrests III

1998 until finally released in August 2009, upon publication of the Supreme Court Decision.

128. That miscarriage of justice by the PGR, among others, was evidenced by the

PGR's publication of the White Book under color of law, which represented the official position

of the PGR and the Mexican Government, purporting to finally resolve, settle, and put to rest all

issues relating to the Acteal Massacre.

1 29. The Cover-Up was furthered when Noe Maza, the newly appointed Chiapas

Special Prosecutor, was prohibited from obtaining the testimony of Defendant Zedillo, Saenz and

Chuayffett, and was then relieved of his position in or about July 2008 when he made statements

contrary to the White Book's findings, declaring that some of the alleged perpetrators of the

Acteal Massacre could have been innocent.

130. The Cover-Up was finally brought to light by the Supreme Court Decision which,

for the first time, held that the PGR had committed procedural, legal and constitutional violations

in the prosecution of the Acteal Massacre and thereby confirmed that, contrary to the White

Book's findings, those responsible, including Zedillo, had not been brought to justice.

32


1 3 1 . Moreover, the 2008 declassification of the December 1 997 D1A Report and the

May 1 999 D1A Report confirmed for the first time the de facto involvement of members and/or

personnel of the Mexican Army, or persons or groups acting in coordination with the Mexican

Army, or under its control and protection, in the training and arming of the Anti-EZLN Villagers.

132. Furthermore, since 1997, and continuing to the present time, Anti-EZLN

Villagers, elements of the Mexican Army, and the police have consistently engaged in summary

executions, detentions, and forced displacement of members of indigenous communities in

Chiapas. These actions have had the intended effect of creating an atmosphere of such extreme

fear and intimidation that Plaintiffs have been traumatized and unable to pursue their claims. In

fact, Plaintiffs continue to fear for their lives and personal safety and must bring these claims

anonymously.

1 33. For the aforementioned reasons, August 1 2, 2009 is the date upon which the

Statute of Limitations commenced to run.

Absence and/or Exhaustion of Legal Remedies in Mexico

1 34. The complexity of the Cover-Up, including the arrest and conviction of 34

persons, the subsequent publication of the White Book, the denial of the existence of the Plan de

Campafia Chiapas '94 by the Secretariat of National Defense, and the longevity of the Cover-Up,

confirmed that neither the justice system nor law enforcement in Mexico would protect the rights

of the victims of the Acteal Massacre, including the Plaintiffs and Decedents, provide

appropriate remedies for same, or bring to justice those truly responsible for that atrocity.

1 3 5. The absence of adequate legal remedies for the Plaintiffs and Decedents III

Mexico was further confirmed by the promotion to appellate judge of the presiding judge of the

Mexican Federal Court in Chiapas, notwithstanding the prior Supreme Court Decision finding

33


that that judge wrongfully permitted the POR to commit obvious, blatant and/or egregious

violations of Mexican criminal procedure, criminal law and constitutional due process.

1 36. Furthermore, Plaintiffs brought legal proceedings in Mexico against Defendant

Zedillo and others for, inter alia, their responsibility for the Acteal Massacre and sought

damages. Those proceedings were dismissed and the dismissal was affirmed on appeal .

Plaintiffs have therefore exhausted all legal remedies in Mexico.

137. As a result of the evident lack of protection afforded by the Mexican justice

system or civil authorities as set forth above, Plaintiffs to this day remain in fear of reprisals

against themselves or their families due to their participation in this lawsuit and, as such, must

proceed under pseudonyms.

138 . As such, to the extent that they did exist, legal remedies available to Plaintiffs and

Decedents in Mexico were "inetIective, unobtainable, unduly prolonged, inadequate, or

obviously futile." S.Rep. No. 1 02-249 at 9-10.

MISCELLANEOUS

1 39. All conditions precedent to the institution of this action have occurred, have been

performed, or have been waived.

140. Plaintiffs have retained undersigned counsel in this action and have obligated

themselves to pay them a reasonable fee.

CLAIMS FOR RELIEF

Count ! Extrajudicial Killing

1 4 1 . Plaintiffs Jane Doe 1 , Jane Doe 2, Jane Doe 3 and John Doe 1 , John Doe 2 , John

Doe 3, and John Doe 6 reallege and incorporate by reference the allegations set forth in

paragraphs I through 140 as if fully set forth herein.

34


142. The extrajudicial killings of Decedents Richard Roe I, Mary Roe I , and Mary

Roe 2 constitute extrajudicial killings as defined by the Torture Victim Protection Act, Pub. L.

No. 102-256, 106 Stat. 73 (1992) (codified at 28 U .S.C. § 1 350 Note). Additionally, the killings

constitute "tort[s] . . . committed in violation of the law of nations or a treaty of the United

States" under the Alien Tort Claims Act, 28 U.S.C. § 1 350, in that they are in violation of

customary international law prohibiting extrajudicial killings as reflected, expressed, defined and

codified in multilateral treaties and other international instruments, international and domestic

judicial decisions and other authorities.

143. The extrajudicial killings of the Decedents were not authorized by a judgment

pronounced by a regularly constituted court affording all judicial guaranties which are

recognized as indispensable by civilized peoples.

144. Defendant Zedillo exercised command responsibility over, ordered, conspired

with, acted in concert with, engaged in a joint criminal enterprise with, and/or aided and abetted,

directly and/or indirectly, various members and/or agents of one or more subdivisions,

instrumentalities and/or agencies of the Mexican Government who carried out the Acteal

Massacre, including the extrajudicial killings of the Decedents.

145. The Decedents sustained pain and suffering and bodily injuries causing death as a

result of the extrajudicial killings.

1 46. Defendant Zedillo's acts or omissions described above, and the acts committed by

various members and/or agents of one or more subdivisions, instrumentalities and/or agencies of

the Mexican Government who carried out the Acteal Massacre, caused the extrajudicial killings

of the Decedents and caused Plaintiffs to suffer severe mental pain and suffering.

35




the Mexican Government, were committed under actual or apparent authority or color of law of

the Mexican Government.

148. As a result of the extrajudicial killings of the Decedents, Plaintiffs Jane Doe 1 ,

Jane Doe 2, Jane Doe 3, John Doe 1 , John Doe 2, John Doe 3, and John Doe 6, in their individual

capacities and in their capacities as next-of-kin of the Decedents are entitled to damages in an

amount to be determined at trial.

149. Defendant Zedillo's acts or omiSSIOns were deliberate, willful, intentional,

wanton, malicious and oppressive, and should be punished by an award of punitive damages in

an amount to be determined at trial.

Count II Attempted Extrajudicial Killing Causing Injuries

(Plaintiff Jane Doe 2)

1 50. Plaintiff Jane Doe 2 realleges and incorporates by reference the allegations set

forth in paragraphs 1 through 140 as if fully set forth herein.

l S I . The attempted extrajudicial killing of Plaintiff Jane Doe 2 constitutes an attempt

to commit an extrajudicial killing as defined by the Torture Victim Protection Act, Pub. L. No.

1 02-256, 106 Stat. 73 ( 1992) (codified at 28 U.S.C. § 1350 Note). Additionally, the attempted

extrajudicial killing constitutes a "tort . . . committed in violation of the law of nations or a treaty

of the United States" under the Alien Tort Claims Act, 28 U.S.C. § 1350, in that it is in violation

of customary international law prohibiting extrajudicial killings as reflected, expressed, defined

and codified in multilateral treaties and other international instruments, international and

domestic judicial decisions and other authorities.

36


1 52. The attempted extrajudicial killing of Jane Doe 2 was not authorized by a

judgment pronounced by a regularly constituted court affording all judicial guaranties which are






Massacre, including the attempted extrajudicial killing of Jane Doe 2.

1 54. As a result of the attempted extrajudicial killing, Plaintiff Jane Doe 2 sustained

pain and suffering and bodily injuries.

155 . Defendant Zedillo's acts or omissions described above, and the acts committed by


the Mexican Government who carried out the Acteal Massacre, caused the attempted

extrajudicial killing of Jane Doe 2 and caused her to suffer severe physical and mental pain and

suffering.

156. Defendant Zedillo's acts or omissions described above, and the acts committed by




1 57. As a result of the attempts to kill her extrajudicially, Plaintiff Jane Doe 2 is

entitled to damages in an amount to be determined at trial.

37


1 58. Defendant Zedillo's acts or omiSSIOns were deliberate, willful, intentional,



Count III Attempted Extrajudicial Killing Causing Injuries

(Plaintiff John Doe 2)

1 59. Plaintiff John Doe 2 realleges and incorporates by reference the allegations set


1 60. The attempted extrajudicial killing of Plaintiff John Doe 2 constitutes an attempt

to commit an extrajudicial killing as defined by the Torture Victim Protection Act, Pub. L. No.

1 02-256, 1 06 Stat. 73 (1 992) (codified at 28 U.S.C. § 1350 Note). Additionally, the attempted


of the United States" under the Alien Tort Claims Act, 28 U.S.C. § 1350, in that it is in violation



domestic judicial decisions, and other authorities.

1 6 1 . The attempted extrajudicial killing of John Doe 2 was not authorized by a






instrumentalities andlor agencies of the Mexican Government who carried out the Acteal

Massacre, including the attempted extrajudicial killing of John Doe 2.

38


1 63. As a result of the attempted extrajudicial killing, Plaintiff John Doe 2 sustained





extrajudicial killing of John Doe 2 and caused him to suffer severe physical and mental pain and

suffering.





1 66. As a result of the attempts to kill him extrajudicially, Plaintiff John Doe 2 is


167. Defendant Zedillo's acts or omissions were deliberate, willful, intentional,



Count IV Attempted Extrajudicial Killing Causing Injuries

(Plaintiff John Doe 3)

168. Plaintiff John Doe 3 realleges and incorporates by reference the allegations set


1 69. The attempted extrajudicial killing of Plaintiff John Doe 3 constitutes an attempt

to commit an extrajudicial killing as defined by the Torture Victim Protection Act, Pub. 1. No.

1 02-256, 106 Stat. 73 (1 992) (codified at 28 U.S.C. § 1 350 Note). Additionally, the attempted

39



of the United States" under the Alien Tort Claims Act, 28 U.S.C. § 1 350, in that it is in violation



domestic judicial decisions, and other authorities.

1 70. The attempted extrajudicial killing of John Doe 3 was not authorized by a



1 7 1 . Defendant Zedillo exercised command responsibility over, ordered, conspired




Massacre, including the attempted extrajudicial killing of John Doe 3.

1 72. As a result of the attempted extrajudicial killing, Plaintiff John Doe 3 sustained


1 73 . Defendant Zedillo' s acts or omissions described above, and the acts committed by



extrajudicial killing of John Doe 3 and caused him to suffer severe physical and mental pain and

suffering.



40




1 75 . As a result of the attempts to kill him extrajudicially, Plaintiff John Doe 3 IS


1 76. Defendant Zedillo's acts or omissions were deliberate, willful, intentional,



Count V Attempted Extrajudicial Killing

(Plaintiffs Jane Doe 1, Jane Doe 3, Jane Doe 4, John Doe 1, John Doe 4, John Doe 5, and John Doe 6)

1 77. Plaintiffs Jane Doe I, Jane Doe 3, Jane Doe 4, John Doe I, John Doe 4, John Doe

5, and John Doe 6 reallege and incorporate by reference the allegations set forth in paragraphs I

through 140 as if fully set forth herein.

1 78. The attempted extrajudicial killings of Plaintiffs Jane Doe I, Jane Doe 3, Jane

Doe 4, John Doe 1 , John Doe 4, John Doe 5, and John Doe 6 constitute attempts to commit

extrajudicial killings as defined by the Torture Victim Protection Act, Pub. L. No. 102-256, 1 06

Stat. 73 (1 992) (codified at 28 U.S.c. § 1 350 Note). Additionally, the attempted extrajudicial

killings constitute "tort[ s 1 . . . committed in violation of the law of nations or a treaty of the

United States" under the Alien Tort Claims Act, 28 U.S.C. § 1 350, in that they are in violation of

customary international law prohibiting extrajudicial killings as reflected, expressed, defined and

codified in multilateral treaties and other international instruments, international and domestic

judicial decisions, and other authorities.

1 79. The attempted extrajudicial killings of Jane Doe I, Jane Doe 3, Jane Doe 4, John

Doe I, John Doe 4, John Doe 5, and John Doe 6 were not authorized by a judgment pronounced

41


by a regularly constituted court affording all judicial guaranties which are recognized as

indispensable by civilized peoples.

1 80. Defendant Zedillo exercised command responsibility over, ordered, conspired




Massacre, including the attempted extrajudicial killings of Plaintiffs Jane Doe 1 , Jane Doe 3,

Jane Doe 4, John Doe I, John Doe 4, John Doe 5, and John Doe 6.

1 8 1 . Defendant Zedillo' s acts or omissions described above, and the acts committed by



extrajudicial killings of Plaintiffs Jane Doe I, Jane Doe 3, Jane Doe 4, John Doe 1 , John Doe 4,

John Doe 5, and John Doe 6 and caused them to suffer severe mental pain and suffering.





1 83. As a result of the attempts to kill them extrajudicially, Plaintiffs Jane Doe I, Jane

Doe 3, Jane Doe 4, John Doe I, John Doe 4, John Doe 5, and John Doe 6 are entitled to damages

in an amount to be determined at trial.

1 84. Defendant Zedillo's acts or omiSSIOns were deliberate, willful, intentional,



42


Count VI

Cruel, Inhuman or Degrading Treatment or Punishment

(All Plaintiffs and Decedents)

1 85. Plaintiffs reallege and incorporate by reference the allegations set forth In


1 86. The acts described herein constitute "tort[ s 1 . . . committed in violation of the law

of nations or a treaty of the United States" under the Alien Tort Claims Act, 28 U.S.C. § l 350, in

that they are in violation of customary international law prohibiting cruel inhuman or degrading

punishment or treatment as reflected, expressed, defined and codified in multilateral treaties and

other international instruments, international and domestic judicial decisions, and other

authorities.

1 87. The acts of cruel, inhuman or degrading punishment or treatment described herein

had the intent and effect of humiliating Plaintiffs and Decedents and inducing fear and anguish.

As an intended result of these acts, Plaintiffs and Decedents were placed in great fear of their

lives and suffered psychological abuse and agony.

1 88. The cruel, inhuman or degrading punishment or treatment of Plaintiffs and

Decedents did not arise from, and was not inherent in or incidental to, lawful sanctions.

1 89. Defendant Zedillo exercised command responsibility over, ordered, conspired




Massacre, including inflicting cruel, inhuman or degrading punishment or treatment upon

Plaintiffs and Decedents.

43




the Mexican Government who carried out the Acteal Massacre, including inflicting cruel,

inhuman or degrading punishment or treatment upon Plaintiffs and Decedents, caused them to

suffer severe mental pain and suffering, including prolonged mental harm.

1 9 1 . Defendant Zedillo's acts or omissions described above, and the acts committed by




1 92. As a result of the cruel, inhuman or degrading punishment or treatment described

above, Plaintiffs, in both their individual capacities and their capacities as next-of-kin of the

Decedents, are entitled to damages in an amount to be determined at trial.

193 . Defendant Zedillo's acts or omissions were deliberate, willful, intentional,



Count VII

Use of Terror and Violence to Violate Freedom of Association (All Plaintiffs and Decedents)

194. Plaintiffs reallege and incorporate by reference the allegations set forth III

paragraphs 1 through 140 as if fully set forth herein.

195. The acts described herein constitute "tort[s] . . . committed in violation of the law

of nations or a treaty of the United States" under the Alien Tort Claims Act, 28 U.S.c. § 1 350, in

that they are violate customary international law prohibiting terror and violence to violate

freedom of association as reflected, expressed, defined and codified in multilateral treaties and

44


other international instruments, international and domestic judicial decisions and other

authorities, including inter alia the 1949 Geneva Conventions, Convention Against Torture and

Other Cruel, Inhuman, or Degrading Treatment or Punishment, United Nations Charter,

Universal Declaration of Human Rights, and the International Covenant on Civil and Political

Rights.

1 96. The acts of terror and violence to violate freedom of association described herein

were orchestrated and designed by Defendant Zedillo and/or various members and/or agents of

one or more subdivisions, instrumentalities and/or agencies of the Mexican Government to

physically terrorize, brutalize, kill, torture, and suppress by any means necessary the political

support for the EZLN.

197. The acts of terror and violence to violate freedom of association described herein

were directed against Plaintiffs and Decedents and induced fear and anguish intended to suppress

their right to freedom of association.

198. The terror and violence to violate Plaintiffs' and Decedents' freedom of

association did not arise from, and was not inherent in or incidental to, lawful sanctions.





Massacre, including inflicting terror and violence to violate freedom of association upon

Plaintiffs and Decedents.



45




20 I . As a result of the terror and violence to violate freedom of association described

above, Plaintiffs, in both their individual capacities and their capacities as next-of-kin of the

Decedents, are entitled to damages in an amount to be determined at trial.

202. Defendant Zedillo's acts or omissions were deliberate, willful, intentional,



Count VIII Use of Terror and Violence to Violate Freedom of Thought,

Political Opinion, and Freedom to Exercise the Political Franchise (All Plaintiffs and Decedents)

203. Plaintiffs reallege and incorporate by reference the allegations set forth In

paragraphs I through 1 40 as if fully set forth herein.

204. The acts described herein constitute "tort[s] . . . committed in violation of the law

of nations or a treaty of the United States" under the Alien Tort Claims Act, 28 U .S.C. § 1350, in

that they are in violation of customary international law prohibiting terror and violence to violate

freedom of thought, political opinion and freedom to exercise the political franchise as reflected,

expressed, defined, and codified in multilateral treaties and other international instruments,

international and domestic judicial decisions and other authorities, including inter alia the 1 949

Geneva Conventions, Convention Against Torture and Other Cruel, Inhuman, or Degrading

Treatment or Punishment, United Nations Charter, Universal Declaration of Human Rights, and

the International Covenant on Civil and Political Rights.

205. The acts of terror and violence to violate freedom of thought, political opinion and

freedom to exercise the political franchise described herein were orchestrated and designed by

46


Defendant Zedillo and/or varIOus members and/or agents of one or more subdivisions,

instrumentalities and/or agencies of the Mexican Government to physically terrorize, brutalize,

kill, torture, and suppress by any means necessary the political support for the EZLN.

206. The acts of terror and violence to violate freedom of thought, political opinion and

freedom to exercise the political franchise described herein were directed against Plaintiffs and

Decedents and induced fear and anguish intended to suppress their right to freedom of thought,

political opinion and freedom to exercise the political franchise.

207. The terror and violence to violate Plaintiffs' and Decedents' freedom of thought,

political opinion and freedom to exercise the political franchise did not arise from, and was not

inherent in or incidental to, lawful sanctions.





Massacre, including inflicting upon Plaintiffs and Decedents terror and violence to violate their

freedom of thought, political opinion and freedom to exercise the political franchise.





210. As a result of the terror and violence to violate freedom of thought, political

opinion and freedom to exercise the political franchise described above, Plaintiffs, in both their

47


individual capacities and their capacities as next-of-kin of the Decedents, are entitled to damages

in an amount to be determined at trial.

21 1 . Defendant Zedillo' s acts or omiSSIOns were deliberate, willful, intentional,



Count IX

Crimes Against Humanity (All Plaintiffs and Decedents)

212. Plaintiffs reallege and incorporate by reference the allegations set forth III

paragraphs 1 through 140 as if fully set forth herein.

213 . The extrajudicial killings of Decedents Richard Roe 1 , Mary Roe 1 and Mary Roe

2; the attempted extrajudicial killings causing injuries of Jane Doe 2, John Doe 2, and John Doe

3; the attempted extrajudicial killings of Jane Doe 1 , Jane Doe 3, Jane Doe 4, John Doe 1 , John

Doe 4, John Doe 5, and John Doe 6; the acts of cruel, inhuman or degrading punishment or

treatment upon all Plaintiffs and Decedents; the acts of terror and violence to violate freedom of

association upon all Plaintiffs and Decedents; and acts of terror and violence to violate freedom

of thought, political opinion and freedom to exercise the political franchise upon all Plaintiffs

and Decedents, as described herein constitute "tort[ s 1 . . . committed in violation of the law of

nations or a treaty of the United States" under the Alien Tort Claims Act, 28 U.S.C. § 1 350, in

that they violate customary international law prohibiting crimes against humanity as reflected,

expressed, defined, and codified in multilateral treaties and other international instruments,

international and domestic judicial decisions and other authorities.

214. The acts described herein were orchestrated and designed by Defendant Zedillo

and/or various members and/or agents of one or more subdivisions, instrumentalities andlor

48


agencies of the Mexican Government to physically terrorize, brutalize, kill, torture and suppress

by any means necessary the political support for the EZLN.

2 1 5. These acts did not arise from, and were not inherent in or incidental to, lawful

sanctions.





Massacre, including committing crimes against humanity upon PlaintifIs and Decedents.

2 1 7. Defendant Zedillo' s acts or omissions described above, and the acts committed by




21 8. As a result of the crimes against humanity described above, Plaintiffs, in both

their individual capacities and their capacities as next-of-kin of the Decedents, are entitled to

damages in an amount to be determined at trial.

2 1 9. Defendant Zedillo' s acts or omissions were deliberate, willful, intentional,


an amount to be determined at trial .

Count X

War Crimes (All Plaintiffs and Decedents)

220. Plaintiffs reallege and incorporate by reference the allegations set forth in


49


22 1 . The extrajudicial killings of Decedents Richard Roe I, Mary Roe I and Mary Roe

2; the attempted extrajudicial killings causing injuries of Jane Doe 2, John Doe 2, and John Doe

3 ; the attempted extrajudicial killings of Jane Doe I, Jane Doe 3, Jane Doe 4, John Doe I, John

Doe 4, John Doe 5, and John Doe 6; the acts of cruel, inhuman or degrading punishment or

treatment upon all Plaintiffs and Decedents; the acts of terror and violence to violate freedom of

association upon all Plaintiffs and Decedents; and acts of terror and violence to violate freedom

of thought, political opinion and freedom to exercise the political franchise upon all Plaintiffs

and Decedents, as described herein constitute "tort[ s 1 . . . committed in violation of the law of

nations or a treaty of the United States" under the Alien Tort Claims Act, 28 U.S.c. § 1 350, in

that they are in violation of customary international law prohibiting war crimes as reflected,

expressed, defined and codified in multilateral treaties and other international instruments,

international and domestic judicial decisions, and other authorities.




instrumentalities and/or agencies of the Mexican Government who planned to commit war

crimes, including the Acteal Massacre.





50


224. The acts were committed during and in connection with the armed conflict

between the Mexican Government and the EZLN in Chiapas, which was an armed conflict not of

an international character.

225. Under Mexican and international law, this armed conflict bound Defendant

Zedillo to follow at least some of the obligations of the Four Geneva Conventions of 1949,

including inter alia Common Article 3 thereof and the customary norms of international law

regarding internal armed conflicts.

226. As a result of the war crimes described above, Plaintiffs, in both their individual

capacities and their capacities as next-of-kin of the Decedents, are entitled to damages in an

amount to be determined at trial.

227. Defendant Zedillo's acts or omISSIOns were deliberate, willful, intentional,



Count Xl

Claimfor Declaratory Relief Pursuant to the Federal Declaratory Judgment Act, 28 U.S.c. § 2201

(All Plaintiffs and Decedents)

228. Plaintiffs reallege and incorporate by reference the allegations set forth m

paragraphs 1 through 1 40 as iffully set forth herein.

229. This Court is authorized to declare the rights and other legal relations of any

interested party seeking such a declaration, whether or not further relief is or could be sought.

230. A real and justiciable controversy exists between the parties with respect to the

acts and omissions by Defendant Zedillo as set forth hereinabove. Plaintiffs are entitled to a

declaration of the rights and liabilities of the parties to this action pursuant to the Federal

Declaratory Judgment Act, 28 U.S.C. § 2201 .

5 1


231 . Plaintiffs are uncertain as to all of their rights and obligations and require a

detennination by the Court of their respective present and future rights and obligations based

upon Zedillo' s actions and omissions, as set forth hereinabove.

232. Accordingly, Plaintiffs request judgment declaring the rights and interests of

Plaintiffs and Zedillo, based on the acts and omissions by Defendant Zedillo as set forth herein.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs Jane Doe 1, Jane Doe 2, Jane Doe 3, Jane Doe 4, John Doe I,

John Doe 2, John Doe 3, John Doe 4, John Doe 5, and John Doe 6, in both their individual

capacities and their respective capacities as representatives of Decedents Richard Roe 1, Mary

Roe I, and Mary Roe 2, pray for judgment against Defendant, Ernesto Zedillo Ponce de Leon as

follows:

1. For compensatory damages according to proof;

2. For punitive and exemplary damages according to proof;

3. For pre-judgment interest as allowed by law;

4. For attorneys' fees and costs of suit, according to proof;

5 . For a declaration of the rights, interests, liabilities and obligations of Plaintiffs,

Decedents, and Defendant Zedillo, based on the acts and omissions by Defendant Zedillo as set

forth hereinabove; and

6. For any such other and further relief as this Court deems just and proper.

52


DEMAND FOR JURY TRIAL

Plaintiffs hereby demand trial by jury of all issues so triable as of right.

Dated this 16th day of September, 20 II.

By:

MATTHEW DALLAS GORDON LLC 836 Farmington Ave., Suite 221A West Hartford, Connecticut 061 1 9 (860) 523-0471 Tel. (860) 523-0472 Fax

�� Matthew D. Gordon (Bar No. ct02355) [email protected]

- and -

RAFFERTY KOBERT TENENHOLTZ BOUNDS & HESS, P.A. Roger S. Kobert (Not admitted in D.Conn.) [email protected] Marc C. Pugliese (Not admitted in D.Conn.) [email protected] 1401 Brickell Avenue, Suite 825 Miami, Florida 33 1 3 1 -3502 (305) 373-0330 Tel. (305) 373-2735 Fax

Counsel for Plaintiffs

53

Ernesto Zedillo Complaint

Documents

joint criminal

joint criminal

speaking indigenous

supreme court

supreme court

domestic judicial

domestic judicial

domestic judicial