Shanquella Robinson Complaint-Combined
Shanquella Robinson Complaint-Combined
Shanquella Robinson Complaint-Combined
SALLAMONDRA ROBINSON,
INDIVIDUALLY AND AS
PERSONAL REPRESENTATIVE OF
THE ESTATE OF SHANQUELLA ROBINSON, )
DECEASED.
Plaintiff,
) VERIFIED COMPLAINT
(JURY TRIAL DEMANDED)
DAEJHANAE JACKSON,
ALYSSE HYATT,
MALIK DYER,
WENTER DONOVAN,
KHALIL COOKE,
NAZEER TYREE WIGGINS,
UNITED STATES DEPARTMENT OF
STATE, AND THE
FEDERAL BUREAU OF INVESTIGATION,
Defendants.
NATURE OF THE ACTION
COMES NOW, Plaintiff Sallamondra Robinson, individually and as personal
representative of the Estate of Shanquella Robinson, deceased, by and through undersigned
counsel, complaining of the actions and inactions of Daejhanae Jackson, Alysse Hyatt, Malik
Dyer, Wenter Donovan, Khalil Cooke, Nazeer Tyree Wiggins, the United States Department of
State, and the Federal Bureau of Investigation states as follows:
NOTICE OF CLAIM
3. Plaintiffs presented timely Notices of Tort Claims, pursuant to the FTCA, 28 U.S.C. §§
2671, et seq.; 2401; 2675(a) and all applicable federal regulations, giving notice of the
negligence caused by the acts or omissions of the United States Department of State and
Electronically Filed Date: 10/28/2024 4:52 PM Mecklenburg County Clerk of Superior Court
the Federal Bureau of Investigation, while acting within the scope of their scope of
employment with the United States of America, under circumstances in which the United
States, if a private person, would be liable to the Plaintiff, in accordance with the laws of
the state of North Carolina.
PARTIES
4. Sallamondra Robinson, Plaintiff, individually and as the Personal Representative of the
Estate of Shanquella Robinson, is a resident and citizen of Mecklenburg County, North
Carolina, and the Estate of Shanquella Robinson is presently open and pending before the
Clerk of Superior Court in Mecklenburg County Case File No.: 2024 E 2019 590.
5. Defendant Daejhanae Jackson is being sued in her individual capacity. Upon information
and belief, she is a resident and citizen of Guilford County, North Carolina, with a
personal address: 3023 Sherrill Avenue, Jamestown, North Carolina.
6. Defendant Alysse Hyatt is being sued in her individual capacity. Upon information and
belief, she is a resident and citizen of Forsyth County, North Carolina, with a personal
address: 412 Meshire Court, Winston-Salem, North Carolina.
7. Defendant Malik Dyer is being sued in his individual capacity. Upon information and
belief, he is a resident and citizen of Davidson County, North Carolina, with a personal
address: 63 Hamil Street, Lexington, North Carolina.
8. Defendant Wenter Donovan is being sued in her individual capacity. Upon information
and belief, she is a resident and citizen of Person County, North Carolina, with a personal
address: 36 Friendship Crossing, Roxboro, North Carolina.
9. Defendant Khalil Cooke is being sued in his individual capacity. Upon information and
belief, he is a resident and citizen of Mecklenburg County, North Carolina, with a
personal address: 3514 Charterhall Lane, Charlotte, North Carolina.
10. Defendant Nazeer Tyree Wiggins is being sued in his individual capacity. Upon
information and belief, he is a resident and citizen of Mecklenburg County, North
Carolina, with a personal address: 5521 Londonderry Road, Charlotte, North Carolina.
11. Defendant United States Department of State is a cabinet-level executive agency of the
United States of America. The agency's mailing address is 2201 C. Street NW,
Washington, D.C. 20520.
12. Defendant Federal Bureau of Investigation is a federal law enforcement agency of the
United States of America. The agency's mailing address is 935 Pennsylvania Ave., NW,
Washington, D.C 20535-0001.
FACTUAL ALLEGATIONS
The Murder in Mexico
13. Shanquella Robinson was a vibrant and driven 25-year-old, who had already established
herself as a remarkable entrepreneur and a beloved community member.
14. As a proud college graduate, she pursued her degree with dedication and passion,
embodying the spirit of hard work and perseverance.
15. In addition to her business endeavors, she had a special talent for braiding hair,
particularly for children. This skill allowed her to build strong relationships with families
in her community, because she offered a service that brought confidence and joy to young
clients.
16. Her gentle demeanor and creativity made her a favorite among kids and parents.
17. Before her entrepreneurial journey, Shanquella was also a cheerleader, known for her
infectious enthusiasm and dedication to her team.
18. Her spirited nature and leadership skills were evident in every aspect of her life, inspiring
those around her to strive for the best.
19. Tragically her life was cut short, leaving a profound impact on her community and loved
ones.
20. She is remembered not only for her accomplishments and excitement for travel but also
her kindness, positivity, and the light she brought to the lives of so many.
21. Defendants, Daejhanae Jackson, Alysse Hyatt, Malik Dyer, Wenter Donovan, Khalil
Cooke, and Nazeer Tyree Wiggins, (hereinafter referred to as "Cabo Six Defendants")
were believed to be friends of the decedent, Shanquella Robinson.
22. Khalil Cooke, knowing Shanquella the longest and best, invited her to join the Cabo Six
Defendants on what was supposed to be a fun and safe luxury vacation in Cabo San
Lucas, Mexico in October of 2022.
23. Shanquella was invited to attend the trip to Mexico at the last minute, because other
guests declined or otherwise canceled their plans to join.
24. When she arrived at the Puerto Los Cabos Villa Linda in Mexico on or about October 28,
2022, Shanquella spoke with her mother, Sallamondra Robinson. Neither Shanquella nor
her mother knew that this call would be their last conversation.
25. On or about October 29, 2022, the rest of the Cabo Six Defendants arrived at the villa in
Cabo San Lucas, as evidenced by the Cabovillas.com Private Villa and Condominium
Guest Register, attached as (Exhibit A) and fully incorporated by reference herein.
26. On or about October 29, 2022, Defendant Daejhanae brutally attacked Shanquella
Robinson, in one of the bedrooms at the villa.
27. Defendant Daejhanae repeatedly punched Shanquella in the face, head, neck, and other
parts of her body.
28. During the attack, Shanquella was naked, completely exposed, and unable to respond or
defend herself.
29. Still, Defendant Daejhanae tossed Shanquella around the room, in the presence of the
other Cabo Six Defendants.
30. Not one of the other Cabo Six Defendants intervened to assist Shanquella while
Defendant Daejhanae's violent and relentless attack persisted.
31. Not one of the Cabo Six Defendants attempted to contact local law enforcement during
the attack.
32. Instead, the members of the Cabo Six Defendants revelled at the spectacle and recorded
the incident that would be shared later on social media.
33. Multiple members of the Cabo Six Defendants can be seen watching the brutal attack
with phones out and heard yelling at Shanquella, not Defendant Daejhanae.
34, The attack continued for several minutes.
35. Upon information and belief, Defendant Wenter facetimed Defendant Daejhanae's
boyfriend so he could watch the attack.
36. Upon information and belief, Defendant Daejhanae's boyfriend cheered her on as she
continued to strike Shanquella.
37. Upon information and belief, there was nothing Shanquella could have done to warrant
this fatal attack.
38. No one tried to console or help Shanquella with her severe and apparently painful
injuries.
39. When members of the Cabo Six Defendants finally called the villa concierge, hours later,
they requested medical personnel to get Shanquella hydrated and implied that she needed
to be treated for alcohol poisoning.
40. Shanquella was not verbally responsive and was lethargic prior to the doctor arriving
upon the scene.
41. Defendant Khalil contacted Sallamondra Robinson advising that Shanquella had alcohol
poisoning and that the Cabo Six Defendants were going to put her in the shower.
42. When the doctor arrived, Shanquella was unable to advocate for her own medical
treatment or advise the doctor that she had been beaten because her injuries rendered her
unable to speak.
43. None of the Cabo Six Defendants told the doctor that Shanquella was the victim of blunt
force to the head and neck.
44, None of the Cabo Six Defendants provided any information to the doctor about the brutal
attack.
45. The Cabo Six Defendants continuously told the doctor that Shanquella was sick from
drinking too much alcohol and did not need to be transported to the local hospital for
immediate medical attention.
46. After taking Shanquella's vitals, it became clear to the doctor that Shanquella needed
more than hydration.
47. The doctor implored the Cabo Six Defendants to authorize Shanquella's immediate
transportation to the hospital and notified her supervisor when the Cabo Six Defendants
indicated they would not provide authorization. Attached as (Exhibit B) and fully
incorporated by reference herein is the physician's interview report.
48. Her vital signs were dangerously abnormal.
49. The Cabo Six Defendants denied Shanquella this life-saving treatment by refusing to
authorize transportation for her.
50. The Cabo Six Defendants insisted that Shanquella only be treated with fluids for "alcohol
poisoning".
51. The doctor repeatedly requested authorization from the Cabo Six Defendants to transport
Shanquella via ambulance to the hospital, because her vital signs were weakening.
Furthermore, the doctor provided information about local public hospitals that could treat
Shanquella at no cost. The Cabo Six Defendants refused. See Exhibit B.
52. Defendant Khalil called Sallomandra Robinson and told her that Shanquella needed
medical treatment for dehydration. Defendant Khalil requested Shanquella's social
security number, insurance information, and $5,000 USD.
53. Sallamondra Robinson provided the social security number and advised that everything
else would be in her purse.
54. Defendant Khalil never told Sallamondra Robinson that Shanquella was dying, was
violently attacked by Defendant Daejhanae, or otherwise unsafe. Instead, Defendant
Khalil insisted that Shanquella was merely dehydrated and needed an IV.
55. At all times during the final moments of Shanquella's life, Sallamondra Robinson was
unable to communicate directly with villa staff, local law enforcement, or medical
personnel, to get the truth of her daughter's condition.
56. The doctor requested help from the Cabo Six Defendants, so that she could attempt
resuscitation.
57. Defendant Malik remained in the room while all of the other members of the Cabo Six
Defendants left.
58. When Shanquella no longer had a pulse, the doctor called 911 to notify law enforcement
that emergency services were needed.
59. Three emergency medical service providers arrived at the villa, including the Mexican
Red Cross.
60. Allthree ambulance agencies confirmed that Shanquella could not be transported to the
hospital at this point because she no longer had any measurable vital signs.
61. Shanquella was pronounced dead at the villa, in the presence of medical personnel and all
of the Cabo Six Defendants, on October 29, 2022.
62 . According to the autopsy report, Shanquella Robinson's cause of death was a spinal cord
injury and atlas luxation. Attached as (Exhibit C) and fully incorporated by reference
herein is an excerpt of the autopsy report.
63. Police officers arrived to prepare the necessary paperwork and take Shanquella's body to
the morgue.
64. During his interview with law enforcement, Defendant Khalil claimed Shanquella got the
bruises on her head and arms from fall in the pool. At no point during this interview did
a
CAUSES OF ACTION
A. COUNT I: WRONGFUL DEATH (DAEJHANAE JACKSON)
95. Plaintiff realleges and incorporates by reference all allegations and statements in
Paragraphs 1- 94 as if they were fully set forth herein.
96. Defendant Daejhanae viciously attacked Shanquella Robinson, causing her fatal
injuries.
97. Undoubtedly, Shanquella suffered excruciating personal injury, pain and suffering prior to
her death. Had Decedent survived, she would have been entitled to bring an action
against Defendant Daejhanae for damages.
98. Pursuant to N.C. Gen. Stat. § 28A-18-2, those persons being identified as beneficiaries
include Sallamondra Robinson, who has suffered the following damages and is entitled to
compensation:
a. Compensation for pain and suffering for the Decedent;
b. Compensation for the loss of the reasonably expected:
i. Net income of the decedent;
ii. Services, protection, care and assistance of the Decedent;
Society, companionship, comfort, guidance, kindly offices and advice of
iii.
the decedent to the persons entitled to the damages recovered;
c. Compensation for the expense of:
i. transporting Ms. Robinson's body from Mexico,
ii. funeral and burial expenses
99. Plaintiff, Sallamondra Robinson, as the personal representative of the Estate of
Shanquella Robinson has suffered damages, in excess of $25,000 as a result of the
wrongful death caused by Defendant Daejhanae Jackson.
and grant other relief the Court deems just and proper.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs, for their causes of action, pray this Honorable Court for relief as
follows:
a. The entry of judgment against Daejhanae Jackson in favor of the Plaintiff for Count I
wrongful death in an amount in excess of $25,000;
b. The entry of judgment against Daejhanae Jackson in favor of the Plaintiff for Count II
battery in an amount in excess of $25,000;
The entry of judgment against each of the Cabo Six Defendants (Daejhanae Jackson,
Alysse Hyatt, Malik Dyer, Wenter Donovan, Khalil Cooke, and Nazeer Wiggins) in favor
of the Plaintiff for Count III negligence in an amount in excess of $25,000;
d The entry of judgment against each of the Cabo Six Defendants (Daejhanae Jackson,
Alysse Hyatt, Malik Dyer, Wenter Donovan, Khalil Cooke, and Nazeer Wiggins) in favor
of the Plaintiff for Count IV civil conspiracy in an amount in excess of $25,000;
e. The entry of judgment against each of the Cabo Six Defendants (Daejhanae Jackson,
Alysse Hyatt, Malik Dyer, Wenter Donovan, Khalil Cooke, and Nazeer Wiggins) in favor
of the Plaintiff for Count V intentional infliction of emotional distress in an amount in
excess of $25,000;
The entry of judgment against each of the Cabo Six Defendants (Daejhanae Jackson,
Alysse Hyatt, Malik Dyer, Wenter Donovan, Khalil Cooke, and Nazeer Wiggins) in favor
of the Plaintiff for Count VI negligent infliction of emotional distress in an amount in
excess of $25,000;
g The entry of judgment against the United States Department of State in favor of the
Plaintiff for Count VII negligence in an amount in excess of $25,000;
h The entry of judgment against the Federal Bureau of Investigation in favor of the
Plaintiff for Count VIII negligence in an amount in excess of $25,000;
Injunctive relief from the Federal Bureau of Investigation;
j An order compelling the immediate release of responsive records from the Federal
Bureau of Investigation;
k Award compensatory damages to the Plaintiff and against the Defendants;
1. Award punitive damages to the Plaintiff against all individual Defendants, in an amount
to be determined at trial, that will deter such conduct by Defendants in the future;
m Award Plaintiff their costs and reasonable attorneys' fees;
n. That all triable issues of fact be determined by a jury; and
0. For such other and further relief, the Court deems just and equitable under law.
FRONTLINE FIRM
/s/ Sue-Ann Robinson
Sue-Ann Robinson, Esq.
FBN: 29463
614 S. Federal Highway
Fort Lauderdale, FL 33301
T: 754-801-0897
sueann@frontlinefirm.com
Pro hac vice forthcoming
/s/ GabrielleHiggins
Gabrielle Higgins, Esq.
FBN: 1025840
614 S. Federal Highway
Fort Lauderdale, FL 33301
T: 754-801-0897
gabrielle@frontlinefirm.com
Pro hac vice forthcoming
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EXHIBIT B
34
Reference No.
sJc/3063/2022
Body/lnstitution PGJ E
Legal Basis: Article 21, Paragraph l ofthe Political Constitution ofthe United Mexican States, nrticle
132, Section X of the National Code of Criminal procedure.
Witness E lnjured Pa rty D Victim E
Telephon e 33 32 01 30 89
ID: INE Voter Code ORGTKR93050702M300
35
IOfficialseal] lOfficialseall
PG-'E
Baja California State
Attorney General's Office
lnterview
Th is is my statement given to investigation agent Suni.,ehseel Popoca Milldn in relation to the facts
that are investigated by the Attorney General's Office ofthe state of Baja California Sur. On October
29 of the year 2022 when I was at my place of work in the AMC hospital which means American
Medical Center in Cabo San Lucas in the municipality of Los Cabos, where lwork as a general
practitioner, at 14:13 hours approximately lwas informed by WhatsApp message that medical
assistance had been requested for a person in Puerto Los Cabos in San Jose del Cabo, at Villa Linda
Puerto Fundadores number 32. The reason for the medical assistance was that the person had
consumed a lot ofalcohol and they wanted to hydrate her. larrived at the aforementioned address
by means of a hospital vehicle at approximately 15:15 hours, where I was able to see six individuals,
including Miss Shanquella. I was received by a male person of dark complexion, slim build, English
lnterview Transcript
of dark complexion, of regular build, dressed in blue, approximately 26 years old; further back there
was a tall African-America n person of stocky build, with a bulging cap on his head, approximately 28
years old. These people pointed out to me a dark-skinned female of African-American descent, of slim
build, approximately 25 years old, sitting on the couch with her head resting on the top edge of the
couch and the rest of her body resting on the couch, covered with a light blanket from the chest down
and wearing a blouse (l don't remember the details of it) and purple leggings. Her eyes were open,
she was disheveled, dehydrated, her lips were dry, she did not articulate words, only sounds. She had
a blow to the forehead on the right side, no deformities were felt in the skull, she had poor response
to light. I proceeded to call her name, which was provided seconds before by her companions, I
touched her shoulder, I put myself at her height visually without obtaining any response from the
I proceeded to tak e vital signs, temperature of 36.1 "C, heart rate of 66, respiratory rate of 17, pulse
saturation by oximeter of 98% and blood pressure of 98/oo. she also had a right conjunctival
hemorrhage. lauscultated her heart and lungs, no abnormal sounds were heard. I noticed that her
nails were painted and her capillary filling was delayed, which confirms that she was dehydrated. I
informed her companions that she was dehydrated but that she did need to be evaluated at the
hospital; I asked if there was a history of drug use, illnesses, allergies, all denied; I asked how much
alcohol she had consumed and what she had consumed. The answer was "countless and of all kinds,,;
this answer was given to me by the female person, who will be named as person number 1 and is thin
and tall, with very long hair; and a second female person of robust build, tall, dark complexion, who
will be identified as number 2, who told me that Miss shanquella had drunk a lot. I asked everyone
lnterview Transcript
and I was told that they are all friends from college. To help me with Shanquella's assessment, the
male identified as number 1, of slim build, dark complexion, about 25 years old, wearing a cap, and
the female named Wenter (l know her name because the emergency call was made from her number
and it was necessary to provide her name) stayed with me. -Ihe girl number 2 and Wenter requested
that Shanquella be seen at that address and the other girl identified as number 1 said that she had
been like this before and that she used to get better with hydration. I insisted that it was better for
her friend to be taken care ofat the hospital and that I can proceed to start hydration but that she
will require assessment and care at the hospital and continue her care there and immediately; that
they needed to notify a family member to find out if they would be in charge, since there were no
direct family members, to which they are reluctant. Wenter and the girl No. 2 told me that they had
the means to pay me but they did not have the money to pay an expensive hospital bill.
lnterview Transcript
I did not want to receive any kind of remuneration. Taking into account that it was going to be
necessary to cover the cost of the materials, either on site or outside, linsisted on taking her to the
hospital; I informed them that there were public hospitals that had no cost, and told them to ask the
family members if she (Shanquella) had any type of insurance, and told them to start making the calls,
because she had to be treated in a hospital. The one who stayed to assist me was the male identified
with number 1, who helped me to hold her hand to try to place an lV. While they were deliberating
what to do, I know that the female identified as number 2 and Wenter called someone, reporting
Shanquella's condition, and the need to make decisions, they insisted during the call that Shanquella
was only dehydrated and only needed an lV and that I was insisting on taking her to a hospital, but
that they had no money. ln turn, I called my boss, Dr. Alvaro Atilano, who confirmed that if lfelt it was
necessary to take her to a hospital, to emphasize to her friends the need to take her to a hospital.
and that I must not move her under any circumstance if they do not accept; and that in case they do
not reach a decision, that lshould leave the place. I then informed them that I could not place the lV
because she is dehydrated and does not speak well. Their new response was that they did not have a
car to take her in, to which I told them to call 911 or to look for a way to take her there; they replied
that all that costs money. They ask me which hospital they could take her to and ltell them the
nearest public hospital or the closest hospital. They deliberate again and ltell them that lam going to
leave. They tell me that they were already checking with her relatives to see if she had insurance and
ask me to try to place the lV one last time. For the third time I tried to place an lV in her left arm and I
succeeded, but when I tried to secure the lV, she began to have generalized tonic-clonic convulsions.
At that moment the person identified as female number 1, Wenter, and the male identified as
number l were present. During the convulsions the lV came out, lcompressed her hand, they got
I told th em not to put anything in her mouth and that now they really needed to call 911. Then
Wenter told me to do it mysell to which I told her that she needed to make the call because I had to
take care of Shanquella. Then I realized her sphincter had relaxed. At that moment the male identified
as number l told me that she had peed already; this changed my perspective and reinforced the need
for a complete evaluation in a complete imaging study with urgent hospital attention and transfer by
ambulance. After a few minutes and when Shanquella stopped convulsing, I realized her companions
were gone; only male number 1 and Wenter had stayed with me. I then proceed to monitor her vital
signs as much as I could; I request support to position her airway and verify that 911 is being called.
wenter called and passed me her phone; I report a female in post-ictal state, requested an urgent
unit; I notice that abnormal sounds are heard in her breathing (rales) and it is difficult to open the
By this time about an h our had elapsed. Patient with pulse, increased respiratory effort. Help is
requested from the only friend left within my reach, who is the male identified as number 1, to look
for a hard plastic tube to keep her mouth open. He asks me to transfer shanquella in my vehicle, to
which ltell him that she is in serious condition and requires an ambulance. He then left and I was left
alone with her and ltry to position the ainrvay, take a pulse; at 1E:49 she ls detected without pulse,
verbally lshouted to them "she no longer has a pulse, I need help". The thin girl identified as number
1 looks out, panics and leaves; male number t helps me lower her to the floor next to the couch and
place her in a flat position. lcalled 911, indicate this was as a follow up to the previous report, that
the patient is now in arrest; cPR maneuver is initiated, with me giving compressions and his friend
helping me with rescue ventilation, until the Red Cross ambulance arrived, about five minutes after
she went into arrest. lasked them to transfer the patient by ambulance, but they refused saying that
they cannot take her without a pulse; the same thing that the other three ambulances that came to
Name and signature of the interviewed party Name and grade of the police officer
43
[Official seal] IOfficial seal]
PGJE
Baja California state
Attorney General's Off ice
lnterview Transcript
then the other th ree responder teams joined in. The AED device is placed and they were advised not
to discharge. lmmediately a lillegible] cannula is placed and ventilation with bag mask; lam informed
that there is a laryngeal mask but it cannot be placed because there is still trismus. I insist on
transferring the patient. Five ampoules ofadrenaline were applied in 2 resuscitation efforts. Until
they accepted my advice and they were told via monitor to discharge, and defibrillation was
performed 5 times. The monitor was placed with an asystolic trace and her friends were informed
that there was no response. After approximately one hour of maneuvers, I informed one of her
friends, identified as male number 2, of regular build, dark complexion, bald, bearded, who asked me
why they did not take her to a hospital, to which I replied that no paramedic accepted to transfer her
to a hospital in her condition. He was shaking and left the scene. The paramedics informed me that
there was no longer any motor response and that the monitor was in asystolic and that there was no
adrenaline left and that in that condition they were not going to transfer her; another attempt at
reanimation was made, no pulse was detected in asystolic without any type of motor response with
dilated pupils, without pupillary or corneal response, so she was declared decease d at L7..57 hours. At
the end of the third round of maneuvers, the municipal police officers had already arrived at the
scene and did not interfere in any way, only in one ofthe relays that were made, they asked me about
the patient's condition, to which I responded that she needed to be transferred to the hospital, letting
the medics work. After she was declared deceased, I waited for them to finish interviewing one of the
Red Cross paramedics, as he was one of the first to arrive in the ambulance. One of the officers took
my statement and about 10 minutes before the end ofthe interview Giovanni the administrator
arrived and the officers told me that lcould not leave yet; I stayed there for about 15 more minutes,
Remarks
By hand
On December 8,2022 this investigative unit received a response on order 642/2022 from the group's
chief Juan Pablo Sepulveda, assigned to this investigative unit by CHRISTIAN ARMENDARIZ, GENERAL
MANAGER OF THE HOTEL AEROPUERTO LOS CABOS, annexed herein.
Ordet 7O4/2O22 was sent to the General Director of the Control Center, Communication and
Computation Command of the Baja California Sur State BRUNO KHMER CANTARELL MAYTORENA by
email direccion4losca bos@ hotma il.com, c4bcs@hotmail.com, order annexed herein.
A response was received on December 12, 2022 by email from BRUNO KHMER CANTARELL
MAYTORENA, General Director of the Control CenteI Communication and Computation Command (C4),
annexed herein.
On December t4,2022 RODOLFO PALOMERA JIMENEZ was interviewed and the record is annexed
h e rein.
Calle Palo de Escopeta Esq. Cerro de la Cruz, Col. Vivah las Veredas, San lose del Cabo C.P 23435
Email: aeicutrnsjcbcs@gmail.com
lOfficialseall lofficialseall
PGIE
State of Baja California Sur
Attorney General's Office
Government of the State of Baja California Sur
State Attorney General's Office
Specialized Unit for the lnvestigation and
Prosecution of Miscellaneous Offenses
The aforesaid is based on the first paragraph of Article 21 of the Constitution of the United Mexican
States, as related to Article 132 Section Vll of the National Penal Procedures Code, and Section V of
Article 46 of the organic law of the Prosecutor's Office of the Baja California Sur State
Sincerely,
lRubbeFstamped seall llegible signatu re]
ltllesiblel
Lic. SuniJehsee Popoca Millan
Criminal lnvestigation State Agent
Assigned to the Specialized Unit for the Investigation and
Prosecution of Miscellaneous Offenses
Calle Palo de tscopeta Esq. Cerro de la Cruz, Col. Vivah las Veredas, San lose del Cabo C.p 23435
6mail: aeicutrnsicbcs@gmail.com
lOfficialseall GOVERNMENT OF THE STATE OF BA]A CALIFORNIA SUR IOfficialseal]
STATE ATTORNEY GENERATS OFFICE PGIE
State of Baja California Sur
Attorney General's Office
DIRECTORATE OF FORENSIC SERVICES
DEPARTMENT OF LEGAL AND FORENSIC MEDICINE
RE: NECROPSY REPORT
Page:SJC222048
Filet UETDD/559/2022
NUc: sJC/3063/2022
San Jose del Cabo, Baja California Sut October 30, 2022
The undersigned, attorney Rene Adalberto Galvan Oseguera, expert forensic doctor of Baja California Sur
District Attorney's Office, lD number: 632734 and SSA registry 79278, assigned to the Forensic Services Bureau,
named to intervene in
SIC/3063/2022, page assignmenti 222048 and MF 1319 per official letter:
UEIDD/559/2022, of October 30, 2022, issues this:
REPORT:
tssuE.
"Exomine ond identify o codove4 determine couses of deoth of whom, when alive, wds nomed RoBtNsoN
SHANQUELLA BRENADA, female, apporently 25 yeo6 old, determine opproximdte time of deoth, make o
detoiled description of the external and internol injuries, ds well as the other objectives oJ the necropsy, following
i nte rnatio n o I ly o cce pte d p rotoco ls."
MATERIAL
Surgical table, saw, scalpel, thumb forceps, measuring tape, camera.
METHOD
The analytical and deductive medical forensic scientific methodology will be used in this intervention. Techniques
used: Virchow, Rokitansky, mixed, photographing and video during the procedure. Techniques used: Mixed (x)
Photographs: Yes Sampling: Yes
DESCRIPTION:
Forensic legal or medical examination and necropsy:
The cadaver was received packaged in a white plastic bag, duly labeled and preserved, with a chain of custody
registry. Brought at 20:30 hours to the autopsy table at the Medical Forensic Service on October 29, of this year.
Latei at 09:00 hours on October 30, 2022, we gathered at the autopsy table at the Medical Forensic Service to
examine, identify and perform a necropsy on the cadaver of whom was called in life: ROBINSON SHANqUELTA
BRENADA.
PHYSICAL DESCRIPTION:
Age:25 years. Sex: Female. Skin Color: Black. Anthropometry: Stature: 165 cm. Approximate weight: 65 kilograms.
Build: Regular. Hair color: Black. Type: Curly. Size: Short. Hair insertion: High. Face shape: Oval. Sizer Broad
medium forehead. Type: Rounded. Size: Medium. Forehead type: Oval. Size: Small. Hair insertion: Medium.
Eyebrow type: Scarce tattooed. Type: Th ick. Size: Med ium. Color: Dark. Proximity: Separate. Direction: Horizontal.
Eye type: Oval. Size: Medium. Color: Coffee. Nose type: Broad. Size: Large. Point: Rounded. Side: Convex. Base:
Broad. Nares type: Large.
Size: Large. Lips: Thick. Corners: Horizontal. Denture: Complete, dental work: Malformations: No. Ear type: Oval.
Size: Small. Lobes: Unattached.
DESCRIPTION OF SPECIAL PECULIARITIES
Scars: No
Tattoos: Yes in right anatomic snuffbox, a heart shaped figure of 3 by 3 centimeters, in the dorsal region and left
shoulder to the lumbar region is a female face and flowers of 45 centimeters.
Characteristics birthmarks or nevus: No
OESCRIPTION OF POSTMORTEM SIGNS
Postmortem
Lividity: Yes. Located at: Posterior regions. Disappear when pressed: Yes. Rigor mortis: Yes. Located at: Reducible.
Cadaveric spam: No. Dehydration: Yes. Corneas with black spots: No. Lower body temperature: yes ZO degrees
centigrade.
Transformational Signs
Putrefaction: No. Discoloration period: No. Emphysematous: No. Colliquative: No. Skeletal reduction: No.
Mummification: No. Maceration: No. Saponification: No. Cadaverous entomofauna: No.
Description of External lnjuries
Direct contusion in the frontal region in the median part of 8 X 4 cm. with hematoma.
Direct contusion in the left illiac crest with a hematoma 7 X 3 cm., the injury happened more than 12 hours before
death.
Contusion in the right illiac crest with a hematoma 4 X 8 cm., the injury happened more than 12 hours before
death.
Contusion in the Ieft hand's anatomic snuffbox with a two cm. Hematoma.
ln the left big toe, a one cm. skin excoriation.
Anterior thorax in xiphoid shows signs of defibrillator burns in a 5 x 5 cm. area, and this is the only one with
postmortem characteristics.
The right eyeball has sclerotic internal hemorrhagic zone of .5 cm.
Sampling: Yes. Cavities: Vaginal, anal. Nail scraping. Others: Blood sample for study, packed and given to the
Forensic Chemical Lab through chain of custody.
Postmortem fingerprinting: Yes.
EXTERNAL EXAMINATION OF THE CADAVER
Clothing: Tank top black (Jockey brand, size L), purple shorts without size (Love University brand), no underwear,
without shoes.
Venoclysis in the right extremity.
Anterior thorax in xiphoid shows signs of defibrillator burns in a 6 X 5 cm. area, and this is the only one with
postmortem characteristics.
These injuries can be seen before taking the clothes off.
coNcLUstoNS
1. lnventory (Write the numbe4 letter of a lphanumeric com bination identifying each delivered piece of evidence,
as well as its type or class. Cancel the remainlng spaces.)
ldentification
A Body of the individual named Robinson Shanquella Brenda when alive.
2. Packaging. (Note the conditions of the packaging. when any show alteration, deterioration or any other
anomaly, specify it.)
Full Name, institution, position and signature Full Name, institution, position and signature
1. lnventory (Write the numbe4 letter of alphan umeric combination identifying each delivered piece of evidence,
as well as its type or class. Cancelthe remaini ng spaces.)
ldentification Type or Class
01 1 brown handbag with two books, a notebook, a hygiene kit, a red bag with one S50 bill, five
S20 bills, one S10 bill, nine S1 bills, one black key, a driver,s license underthe name Robinson
Shanquella Brenada, two passports.
oz One white cellphone lRubber stamped seall
llllegiblel
2. Packaging. (Note the conditions of the packaging. When any show alteration, deterioration or any other
anomaly, specify it.
Evidence received without knoqElge-ollE_qen!e4!L-
lRubber-stamped seall
lllleBiblel
Full Name, institution, position and signature Full Name, institution, position and signature
/j