Shanquella Robinson Complaint-Combined

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Mecklenburg County Clerk of Superior Court 24CV050336-590

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE


SUPERIOR COURT DIVISION
COUNTY OF MECKLENBURG 24 CV- -590

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:

JURISDICTION, VENUE, AND APPLICABLE LAW


1. Venue is proper in this county, pursuant to N.C. Gen. Stat. 1-77.
2. Jurisdiction is proper pursuant to N.C. Gen. Stat. 1-82.

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

he inform law enforcementof Defendant Daejhanae's violent attack on Shanquella.


Furthermore, Defendant Khalil never told the doctor or any responding physicians that
Shanquella fell in the pool.
65. Shortly after law enforcement arrived at the villa, the Cabo Six Defendants packed their
belongings and requested transportation to get dinner.
66. Defendant Daejhanae and Defendant Khalil took Shanquella's belongings and suitcase
with them when they exited the villa.
67. Neither Defendant Daejhanae nor any of the other Cabo Six Defendants checked out of
the villa.
68. Once in the vehicle, the Cabo Six Defendants told the driver to take them to a hotel near
to the airport.
69. The Cabo Six Defendants returned to the United States the next morning, a full day ahead
of schedule, without disclosing the attack or the injuries sustained by Shanquella to the
Mexican authorities.
70. When the Cabo Six Defendants arrived in North Carolina, each of the Defendants worked
in concert to conceal information about the facts and circumstances of Shanquella's death
from her family and law enforcement.
71. Defendant Daejhanae and Defendant Khalil came to Sallamondra Robinson's home, and
returned Shanquella's suitcase. In Sallamondra Robinson's home, while she was grieving
the immeasurable loss of her child, Defendant Daejhanae and Defendant Khalil offered
their condolences for Shanquella passing from "alcohol poisoning."
72. Sallamondra Robinson became ill, and experienced and exhibited symptoms of
sleeplessness, anxiety, depression and other forms of severe mental distress, as a result of
learning of her daughter's untimely death.

The Viral Video


73. The disturbing video footage depicting the Defendant Daejhanae beating Ms. Robinson
was released on or about November 15, 2022 to circulate the Internet. Still images of the
viral video are attached as (Exhibit D) and fully incorporated by reference herein.
74. Weeks after Shanquella's death, Cabo Six Defendants continued to perpetuate the lie that
alcohol poisoning was Shanquella's cause of death.
75. The Cabo Six Defendants did not warn or advise Sallamondra Robinson that footage of
Ms. Shanquella Robinson being brutally attacked in the last moments of her life was
circulating the web.
76. Upon watching the gruesome footage, Sallamondra Robinson experienced renewed
anxiety, depression and other forms of severe mental distress.
77. Sallamondra Robinson's trauma was exacerbated as family members, friends, and
strangers discovered the video. Further, media outlets played the video repeatedly on
television and on social media platforms.
78. Sallamondra Robinson continues to suffer from mental distress as a result of Defendants'
wrongful actions and the inescapable exposure to the triggering footage.

Denied Records Request


79. The FBI informs Sallamondra Robinson that it opened an investigation into the murder
of Shanquella Robinson in November 2022.
80. In April of 2023, the FBI advised Sallamondra Robinson, her family, and the public that
no enforcement proceedings would commence and the agency would not be pursuing a
federal prosecution of any of the Cabo Six Defendants.
81. An initial records request seeking nonexempt "FBI records from 10/29/2022 -
08/1/2023
related to Shanquella Robinson" was mailed in compliance with the Freedom of
Information Act on August 31, 2023, four months after the federal agents stated the
conclusion of their investigation into Shanquella's death.
82. On September 28, 2023, the FBI responded to this request, identifying responsive records
and assigning the FOIA Request # 1602946-00.
83. The FBI advised that these records were exempted from disclosure under 5 U.S.C. § 552
(b)(7)(A) "expected to interfere with enforcement proceedings" and this records request
was administratively closed.
84. Despite formally closing the case, the FBI refused to return Shanquella's property or
provide additional details of their investigation.
85. A year after the federal agents publicly announced the discontinuation of their
investigation of Ms. Shanquella Robinson's unlawful death overseas, a renewed records
request was made May 10, 2024.
86. The FBI responded on June 6, 2024. The agency did not, however, confirm or deny the
existence of responsive records.
87. Furthermore, the FBI's June 6th response did not indicate whether the request was being
processed, when documents were expected to be released, whether any exemptions
applied to the requested documents, or whether the responsive records would be posted to
the FBI's electronic FOIA Library (The Vault).
88. The only indication that responsive records may have been identified was the Request #
1602946-00, which was identical to the 2023 request.
89. In an email received on June 13, 2024, the FBI constructively denied the renewed request
by stating the estimated date of completion would be some time within 2,010 days, over
years.
90. In an attempt to justify this unreasonable delay of over five years, the FBI characterized
the request as "complex".
91. According to the agency, "requests are processed in the order in which they are received
through [the] multitrack processing system". According to the FBI, complex requests are
requests having "over 40 pages of potentially responsive documents." These requests are
then assigned to the large track if the potentially responsive pages are between
"501-4,999 pages."
92. The agency aims to further extend this amorphous timeline, by claiming, "The search for
responsive records is ongoing for [the] request, so we do not yet know into which track it
will fall."
93. The FBI claims it will take over five years to produce previously identified documents
related to an investigation that took the agency six months to close.
94. An appeal of this constructive denial was submitted on behalf of Sallamondra Robinson,
and denied.

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.

B. COUNT II: SIMPLE BATTERY DAEJHANAE JACKSON


100. Plaintiff realleges and incorporates by reference all allegations and statements in
Paragraphs 1- 99 as if they were fully set forth herein.
101. Defendant Daejhanae intentionally and repeatedly punched, kicked, and hit
Shanquella Robinson.
102. Shanquella Robinson did not consent to this offensive physical contact at any point
during the altercation. As seen on the video, Shanquella Robinson was unresponsive as
Defendant Daejhanae violently punched, hit, and tossed her across the room. Neither her
nudity nor her apparent physical lethargy deterred Defendant Daejhanae from continuing
her attack.
103. Defendant Daejhanae's offensive contact directly caused Shanquella Robinson's fatal
injuries.
104. 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 battery
caused by Defendant Daejhanae.

C. COUNT III: NEGLIGENCE (CABO SIX DEFENDANTS)


105. Plaintiff realleges and incorporates by reference all allegations and statements in
Paragraphs 1- 104 as if they were fully set forth herein.
106. Defendants Daejhanae Jackson, Alysse Hyatt, Malik Dyer, Wenter Donovan, Khalil
Cooke, And Nazeer Tyree Wiggins ("Cabo Six Defendants") owed Shanquella Robinson
a duty of reasonable care.
107. Each of the Cabo Six Defendants breached their duty by lying to medical staff in
Mexico and failing to disclose critical, potentially life-saving information.
108. Alternatively, each of the Cabo Six Defendants breached their duty to Shanquella
Robinson by refusing to authorize imperative medical transportation.
109. The Cabo Six Defendants' failure to disclose critical information directly and
proximately caused Shanquella Robinson's wrongful death. At all times material, medical
staff in Mexico was unaware of the blunt force to Shanquella Robinsons' head and neck,
and was precluded from assessing these injuries and acting promptly to save her life.
110. Shanquella Robinson died, in part, because each of the Cabo Six Defendants impeded
the life-saving treatment she needed.
111. 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 actions
and inaction of each of the Cabo Six Defendants, Daejhanae Jackson, Alysse Hyatt,
Malik Dyer, Wenter Donovan, Khalil Cooke, and Nazeer Wiggins.

D. COUNT IV: CIVIL CONSPIRACY (CABO SIX DEFENDANTS)


112. Plaintiff realleges and incorporates by reference all allegations and statements in
Paragraphs 1- 111 as if they were fully set forth herein.
113. Defendants Daejhanae Jackson, Alysse Hyatt, Malik Dyer, Wenter Donovan, Khalil
Cooke, And Nazeer Tyree Wiggins ("Cabo Six Defendants") agreed to conceal and
destroy evidence connected to Shanquella Robinson's death.
114. The Cabo Six Defendants knowingly concealed critical information from medical
staff and law enforcement in Mexico in order to evade culpability for Shanquella's death
and return to the United States.
115. Each of the Cabo Six Defendants conspired to impede all investigation into the
wrongful death of Shanquella Robinson, in the United States and Mexico, because any
investigation would reveal their criminal and civil wrongdoing, including but not limited
to Defendant Daejhanae's battery and the Cabo Six Defendants' negligence.
116. Upon information and belief, Cabo Six Defendants tampered with evidence at the
crime scene, including but not limited to, rummaging Shanquella Robinson's purse and
luggage.
117. As planned, the Cabo Six Defendants' scheme to conceal and destroy evidence did
not conclude once they departed from Mexico. Upon information and belief, the parties
agreed to continue to conceal information and evidence related to Shanquella Robinson's
death from law enforcement in the United States.
118. Upon information and belief, when they arrived in the United States, each of the Cabo
Six Defendants discussed how autopsy results, especially Shanquella's neck injuries,
would criminally implicate them.
119. Bound to the conspiracy agreement, members of the Cabo Six provided false
information to and omitted critical information from Shanquella's family.
120. Plaintiff, Sallamondra Robinson, individually and as the personal representative of
the Estate of Shanquella Robinson has suffered damages in excess of $25,000 as a result
of the actions and inaction of each of the Cabo Six Defendants, Daejhanae Jackson,
Alysse Hyatt, Malik Dyer, Wenter Donovan, Khalil Cooke, and Nazeer Wiggins.

E. COUNT V: INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS


(CABO SIX DEFENDANTS)
121. Plaintiff realleges and incorporates by reference all allegations and statements in
Paragraphs 1- 120 as if they were fully set forth herein.
122. The Cabo Six Defendants knowingly released a video depicting Defendant Daejhanae
viciously attacking Shanquella Robinson, while she was naked, unarmed, and
defenseless.
123. Shanquella Robinson's intimate body parts were fully exposed in the room of Cabo
Six Defendants, and on the footage being disseminated on the Internet without her
consent.
124. Members of the Cabo Six Defendants posted this explicit video on social media,
knowing Shanquella's loved ones would be severely, psychologically impacted by
watching, without warning. the gruesome violence that ended her life.
125. The Cabo Six Defendants intentionally posted this video to further expose and
embarrass Shanquella and her family, including her mother, Sallamondra Robinson.
126. None of the Cabo Six Defendants warned Sallamondra Robinson that this video
would be released on the Internet.
127. Itis highly foreseeable that posting this triggering video of the violent attack of
Shanquella Robinson, her last moments alive, would cause Sallamondra Robinson severe
emotional distress.
128. The gruesome video not only reached the community of North Carolina residents
connected to the Cabo Six Defendants, but also went viral, spreading at lightning speed
across the Internet.
129. Sallamondra Robinson, in fact, suffered severe emotional distress, including but not
limited to severe depression, sleeping disorders, and anxiety from the inescapable posting
and reporting of this footage. While grieving her child, Sallamondra Robinson was
subjected to view Shanquella callously and brutally beaten to death.
130. Plaintiff, Sallamondra Robinson, individually and as the personal representative of
the Estate of Shanquella Robinson has suffered damages in excess of $25,000 as a result
of the intentional actions and inaction of each of the Cabo Six Defendants, Daejhanae
Jackson, Alysse Hyatt, Malik Dyer, Wenter Donovan, Khalil Cooke, and Nazeer Wiggins.

F. COUNT VI: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS


(CABO SIX DEFENDANTS)
131. Plaintiff realleges and incorporates by reference all allegations and statements in
Paragraphs 1- 130 as if they were fully set forth herein.
132. The Cabo Six Defendants owed Sallamondra Robinson a duty to use ordinary care.
133. The Cabo Six Defendants knowingly disclosed and circulated a video depicting
Defendant Daejhanae viciously attacking Shanquella Robinson.
134, The explicit and violent video was posted on the social media platform, accessible to
millions of users.
135. Atall times material hereto, it was foreseeable that the rampant circulation of this
violent and explicit video would cause Sallamondra Robinson severe emotional distress.
136. Once the video went viral on the Internet, it was foreseeable that Sallamondra
Robinson would not only have a visceral reaction to the last moments of her daughter's
life, but also that such repetitive exposure would cause severe emotional distress.
137. Sallamondra Robinson, in fact suffered severe emotional distress, including but not
limited to severe depression, sleeping disorders, and anxiety, as a direct and proximate
result of each of the Cabo Six Defendants' actions and inaction.
138. Alternatively, each of the Cabo Six Defendants owed a duty to use ordinary care in
seeking medical care for Shanquella Robinson.
139. Each of the Cabo Six Defendants breached that duty by withholding critical
life-saving information from medical staff in Mexico.
140. Sallamondra Robinson suffered severe emotional distress as a direct and proximate
result of each of the Cabo Six Defendants' negligence, including their inaction which
caused Shanquella Robinson's wrongful death. Sallamondra Robinson suffered severe
emotional distress, a foreseeable result of this negligence.
141. Plaintiff, Sallamondra Robinson, individually and as the personal representative of
the Estate of Shanquella Robinson has suffered damages in excess of $25,000 as a result
of the actions and inaction of each of the Cabo Six Defendants', Daejhanae Jackson,
Alysse Hyatt, Malik Dyer, Wenter Donovan, Khalil Cooke, and Nazeer Wiggins,
negligent actions and inaction.
G. COUNT VII: NEGLIGENCE (DEPARTMENT OF STATE)
142. Plaintiff realleges and incorporates by reference all allegations and statements in
Paragraphs 1- 141 as if they were fully set forth herein.
143. Sallamondra Robinson, as the administratrix of Shanquella Robinson's estate, brings
this claim under the Federal Torts Claim Act, 28 U.S.C. §§ 1346 and 2671-80.
144. For more than 160 years, the United States and Mexico have maintained an
extradition relationship.
145. Atthe conclusion of the murder investigation conducted by the Mexican authorities,
upon information and belief, an extradition request was submitted to the Department of
State for Defendant Daejhanae.
146. Notwithstanding the extradition request, upon information and belief, the Department
of State failed to forward the request for extradition to the Criminal Division's Office of
International Affairs, as required.
147. This failure to submit the extradition request has permitted international fugitive
Defendant Daejhanae to avoid facing legal proceedings for the murder she committed in
Cabo San Lucas, Mexico.
148. Asaresult of the United States Department of State's inaction and undue delay,
Plaintiff, Sallamondra Robinson, individually and as the personal representative of the
Estate of Shanquella Robinson has suffered damages in excess of $25,000.

H. COUNT VIII: NEGLIGENCE (FEDERAL BUREAU OF


INVESTIGATION)
149. Plaintiff realleges and incorporates by reference all allegations and statements in
Paragraphs 1- 148 as if they were fully set forth herein.
150. Sallamondra Robinson, as the administratrix of Shanquella Robinson's estate, brings
this claim under the Federal Torts Claim Act, 28 U.S.C. §§ 1346 and 2671-80.
151. The Federal Bureau of Investigation has the authority and the nondiscretionary duty
to investigate murders of American citizens that occur overseas.
152. The FBI advised Sallamondra Robinson that an investigation into the death of her
daughter, Shanquella Robinson commenced.
153. This investigation was closed a few months later.
154. As the mother of the deceased, the FBI owed Sallamondra Robinson a duty to
thoroughly investigate the death of Shanquella Robinson, maintain her personal property
in good condition, and to inform Sallamondra Robinson of the status of the investigation.
155. The FBI breached this duty by failing to respond to this investigation with the
appropriate seriousness and urgency. Their unreasonable delay to investigate and
mishandling of evidence led to the erosion and destruction of evidence.
156. Ifthe FBI had complied with its duties and statute to investigate, critical evidence
would have been preserved.
157. Due to the FBI's delay, the quality of the second autopsy completed by United States
authorities was compromised, as Shanquella's body had been altered by embalming
chemicals, decomposition, and the effects of being subjected to a full autopsy by Mexican
authorities.
158. Atall times material hereto, the FBI was aware that the members of the Cabo Six
were persons of interest in the murder of Shanquella Robinson.
159. The Mexican authorities have maintained that Shanquella Robinson was killed by the
dislocation of vertebrae in her neck, caused by the barrage of punches from Defendant
Daejhanae.
160. The FBI's incomplete investigation directly and proximately caused the damages
suffered by Sallamondra Robinson and the Estate of Shanquella Robinson. Notably, the
FBI's inaction has impeded Sallamondra Robinson and her family's ability to receive
closure and justice from the criminal prosecution of Shanquella Robinson's murderer.
161. Asaresult of the inaction and undue delay in investigating the murder of Shanquella
Robinson, Plaintiff, Sallamondra Robinson, individually and as the personal
representative of the Estate of Shanquella Robinson has suffered damages in excess of
$25,000.

I. COUNT IX: 5 U.S.C FAILURE TO PROMPTLY RELEASE RECORDS


(FEDERAL BUREAU OF INVESTIGATION)
162. Plaintiff realleges and incorporates by reference all allegations and statements in
Paragraphs 1- 161 as if they were fully set forth herein.
163. Defendant Federal Bureau of Investigation is an agency subject to and within the
meaning of the Freedom of Information Act, (hereinafter "FOIA").
164. Plaintiff Sallamondra Robinson, by and through Counsel, submitted FOIA Requests
requesting records within the possession, custody, and control of the Federal Bureau of
Investigation.
165. The Federal Bureau of Investigation is obligated under 5 U.S.C. § 552(a)(3)(A-D)
and (a)(8)(A)(b) to produce records responsive to Plaintiff's FOIA Requests.
166. Asrepresented in The Federal Bureau of Investigation's response, the agency has in
its possession responsive, non-exempt documents, including those specifically identified
in Plaintiff's requests, that they have failed to produce.
167. Defendant Federal Bureau of Investigation's withholding of nonexempt records
violates the FOIA.

WHEREFORE, Plaintiff requests that this Court order Defendant to:


a. immediately process and release any and all responsive records;
fF

enjoin Defendant from withholding non-exempt responsive documents;


award Plaintiff its costs and reasonable attorneys' fees;
ao

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.

Respectfully submitted this 25th day of October, 2024.

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

WALLIS, BOWENS, AVERHART & ASSOCIATES, PLLC


/s/ Saleisha Nadia Averhart
Saleisha Nadia Averhart, Esq. (NC State Bar No. 40178)
5500 McNeely Drive, Ste. 102
Raleigh, North Carolina 27612
T: 919-741-6798
saleisha@wbaalaw.com
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EXHIBIT A
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EXHIBIT B
34

IOfficial seal] lOfficial seall


PGJE
Baja California State Attorney
General's Office

Reference No.
sJc/3063/2022

Body/lnstitution PGJ E

State Baja California Sur


INTERVIEW REPORT City, municipality, 5an Jose del Cabo
delegation, locality
Day Month Year
Date 1,6 November 2022
Time 14:00 hours

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

INFORMATION ABOUT THE INTERVIEWER


Name: Suni Jehseel Popoca Milldn Title: AEIC
Assignment lilr iblel
Place of interview Av. Paseo de la Marina 4113 Col. El Medano
CP 23453, Cabo san Lucas, AMC Hos pital

INFORMATION ABOUT THE INTERVIEWED PARTY


Name Karolina Beatriz Ornelas Gutierrez Age 29
DOB 07/0s/rse3 Gender: MN Ftr Civilstatus: Single
Place of birth: Ensenada Nationa lity M exica n
Profession or trade: Genera I Doctor Language: Spanish
82 - English
Education Bachelor Native of Baja
Ca lifornia
Address: Av. Paseo de la Marina 4113 Col. El Medano
CP 23453, Cabo San Lucas, AMC Hospital
Tattoos, birthma rks, No Alia ses: No
visible marks I

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

speaking, approximately 25 years old, as well as by a female

{lllegible signaturel SuniJehseel


Popoca MillSn ulegible signaturel
Karolina Beatriz Ornelos Gutierrez AEIC
PGJE
Name and signature of the interviewed party Name and grade of the police officer
36
lOfficialseall IOfficial seal]
PGJE
Baja California State
Attorney General's Office

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

person, so lsuggested that she needed to be taken to the hospital

Illlegible signature] SuniJehseel


PopocaMilldn Illlegiblesignature]
Ka rolina Beatriz Ornelos Gutierrez AEIC
PGJE
Name and signature of the interviewed party Name and grade of the police officer
[Official seal] IOfficial seal]
PGJE
Baia California State
ARorney General's Of{ice

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

how they were related to her (Shanquella).

Illlegible signature] SuniJehseel


Popoca Milldn Illlegible signature]
Karolina Beatriz Ornelos Gutierrez AEIC
PGJE
Name and signature of the interviewed party Name and grade of the police officer
38
IOfficialseal] IOfficial seal]
PGJE
Baja California State
Attorney General's Office

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.

Illlegible signature] SuniJehseel


Popoca Milldn Illlegible signature]
Karolina Beatriz Ornelos Gutierrez AEIC
PGJE
Name and signature of the interviewed party Name and grade of the police officer
39
IOfficialseal] IOfficial seal]
PGJE
Baja California state
Attorney General's Office

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.

Illlegible signatu re] SuniJehseel


PopocaMillin Illlegiblesignature]
Karolina Beatriz Ornelos Gutierrez AEIC
PGJE
Name and signature of the interviewed party Name and grade of the police officer
40
IOfficialseal] IOfficialseal]
PGJE
Baja California State
Attorney General's Office

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

scared and ltold them not to move her;

Illlegible signature] SuniJehseel


Popoca Milldn Illlegible signature]
Karolina Beatriz Ornelos Gutierrez AEIC
PGJE
Name and signature of the interviewed party Name and grade of the police officer
4t
IOfficialseal] [Official seal]
PGJE
Baja California State
Attorney Gen€ral's Office

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

airway due to trismus; her saturation was low.

Illlegible signature] Suni Jehseel


Popoca Milldn Illlegible signature]
Karolina Beatriz Ornelos Gutierrez AEIC
PGJE
Name and signature of the interviewed party Name and grade of the police officer
42
IOfficial seal] [Official seal]
PGJE
Eaja California State
Attorney General's Office

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

the scene told me. One of the paramedics managed to place an lV

llegible signaturel Suni iehseel


PopocaMilldn Illlegiblesignature]
Karolina Beatriz Ornelos Gutierrez AEIC
PGJ E

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,

and I left the place around 19:30 hours.

Remarks

Illlegible signature] Suni Jehseel


Popoca Milldn Illlegible signature]
Karolina Beatriz Ornelos Gutierrez AEIC/ PGJE
Name and signature of the interviewed party Name and grade of the police officer
lnterview Transcript Page _ of _
EXHIBIT C
NECROPSY
lQfficlal sea ll lofficialseall
PGJE
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
lRubber stamped seall
RECEIVTD Prosecution of Miscellaneous Offenses
llllegiblel
lHandwrittenl
Received
lls/22
lll e8ible signaturel San Jose del Cabo, B.C.S., December 79,2022

Order No.; UEIDD l7l9l2O22


NUC SJC/3063/2022
Re: Additional Report

District Attorney Agent of the Lower Court


Assigned to the Specialized Unit for the lnvestigation and
Prosecution of Miscellaneous Offenses

By hand

the crime of FEMICIDE to the detriment of


I hereby report this about NUC: SJC|3O63|2O22, started for
SHANqUELLA BRENADA ROBINSON, against an unknown defendant:

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.

On December 8 order 7O3/2O22 was sentto the person in charge of the


C2 Bureau of the Control and
Monitoring of the Bureau of Public Security, Municipal Traffic and Preventive Police of the H. XIV Los
Cabos Town Hall, Baja California Sur, annexed herein.

A response to order DGSPPPYTMIC2/28O/2O22 was received from UEUTENANT COMMANDER AARON


BAUTISTA ALVAREZ, in charge of the C2 Bureau of the Control and Monitoring of the Bureau of Public
Security, Municipal Traffic and Preventive Police of the H. XIV Los Cabos Town Hall, Baja California Sur,
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

Lic. SuniJeseel Popoca Millan


Criminal investigation agent assigned to the Specialized Unit for
the lnvestigation and Prosecution of Miscellaneous Offenses
By hand:

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.

MO1MF-F0-001 Rev 0 Page 1of4


Palo Verde e/Palo de Arco, Col. Viva las Veredas C.P 23425 San lose del Cebo, Baja California Sur
Tel. (62411G494S0 Email: periciales@pgiebcs.gob.mx
IOfiicialseal] GOVERNMENT OF THE STATE OF BAJA CALIFORNIA SUR [Official seal]
STATE ATTORNEY GENERATS OFFICE PG.IE
State of Baja California Sur
Attorney General's Office
DIRECTORATE OF FORENSIC SERVICES
DEPARTMENT OF LEGAL AND FORENSIC MEDICINE
RE: NECROPSY REPORT
Page: SJC222048
File: UEI)D/559 /2022
NUC: SJc/3063/2022

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.

B4O1MF-F0{01 Rev.o PaEe 2 of 4


Palo Verde e/Palo de Arco, Col. Viva las Veredas C.P. 23425 san Jose del Cabo, Baja Califomia Sur
10-49450
Tel. (624) Email: periciales@pgjebcs.gob.mx
Iofficialseal] GOVERNMENT OF THE STATE OF BAJA CALIFORNIA SUR lofficialseall
PGJE
STATE ATTORNEY GENERATS OFFICE
State of Eaja California Sur
Attorney General's Office
DIRECTORATE OF FORENSIC SERVICES
DEPARTMENT OF LEGAL AND FORENSIC MEDICINE
RE: NECROPSY REPORT
Paget SJC222o48
File: UEIDD/559 /2022
NUC: SJC/3063/2022
INTERNAL EXAMINATION, OPENING OF CAVITIES
The cavities were opened with the mixed technique and this was found:
Head: The frontal region ofthe scalp and muscles show a 12 cm. hematoma.
Skull: No info.
1. Cranial cavity: No info.
Brain weight: 1,200 grams. Brain matter: Edematous, slightly congestive. Cortex: No relevant info. Central nervous
system: Ventricles: Edematous, hemorrhages. Cerebellum: Edematous. Brain stem: Edematous. Medulla
oblongata: Normal.
Neck: The left lateral neck shows a 7 X2 cm. infiltrate, with atlas and medullary dislocation.
Thorax
1. Lungs: Congestive, basal edematous hemorrhagic.
Cardiovascular system: Heart: No info. Pericardium: No info.
Abdomen: No info. Digestive system: No info. Esophagus: No info. Stomach: No alterations. Liver: Size: Normal.
Color: Red. Gall bladder: Size: 10 cm. Consistency: Normal. Color: Greenish. Pancreas: Size: 16 cm. Consistency:
Normal. Spleen: 12 cm. lntestines: Small: No info. Large intestine: No info. Genitourinary system: No info. Right
kidney: No info. Left kidney: No info.
Pelvis: Bladder: No info.
Upper extremities: A two cm. contusion in the anatomic snuffbox. Lower extremities: ln the left big toe, a one
cm. skin excoriation. Backbone: No info. Osteomuscular system: No info. Genitalia: No info. There is a 20 cm. area
from the vulval region down to each thigh.
Photography: Yes. Video: No. Evidence taken: Yes. What type: Organic. Samples taken: Yes. Blood sample for
clinical test.
The evidence or samples found were sent to:
[Rubber_stamped seal]
Chemistry toxicology, evidence room.
[lllegible]
NorEs, coMMENTs AND spEcrAL ANALysts:
We can say that the autopsy findings:

1) Toxicology report: Waiting for chemistry lab results.

BIBtIOGRAPHICAL NOTES: Qu jroz Cuaron, Forensic Medicine.


INDIVIDUALIZATION FINDINGS External: No
lnternal: No

8401MF-FG001 Rev 0 Page 3 of 4


Palo Verde e/Palo de Arco, Col. Viva las Veredas C.P. 23425 San Jose del Cabo, Baja California SLrr
10-49450
Tel- {524) Email: periciales@p8jebcs gob mx
lOfficialseall GOVERNMENT OF THE STATE OF BAJA CALIFORNIA SUR lofficialseall
PGJE
STATE ATTORNEY GENERATS OFFICE
State of Baja California Sur
Attorney Generalt Office
DIRECTORATE OF FORENSIC SERVICES
DEPARTMENT OF LEGAL AND FORENSIC MEDICINE
RE: NECROPSY REPORT
Page: SJC222048
tile: UETDD /559 /2022
NUc: SJC/3A63 /2022

coNcLUstoNS

We can say, based on the aforesaid and the findings, that:


The cause(s) of death of whom in life was called: ROBINSON SHANqUELLA BRENADA

7. WA|: ATUS AND MEDULURY DISLOCATION.


2. Type or manner of death: Violent.
3. Pre-existing pathology: Unknown.
4. Time of death: Between 17-20 hours when the necropsy was performed.
5. Signs of survival: Yes. The cadaver shows signs of torture: No.
6. Determination if the injuries are post-mortem: No, we found defibrillator injuries consistent with
resuscitation efforts this injury is in the xiphoid appendix.
7. End of the necropsy: 11:00 hours
8. The cadaver was identified: Yes.

lRubber stamped seall


llllegiblel Sincerely
Illlegible signature]
Dr. Rene Adalberto Galvan Oseguera
Expert Medical Examiner IRubber-stamped seal]
Illlegib e]
SSA: 632734 DG? 79278

Death certificate: Yes ?20057239


Dellvery of death certificate: Yes
Attachments: Set of photos.

B401MF-F0-0O1 Rev. 0 Page 4 of 4


Palo Verde e/Palo de Arco, Col. Viva las Veredas C.P 23425 San Jose del cabo, Baja california Sur
Tel. (624) 10-49450 Email: periciales@pgjebcs Bob.mx
!llegiblel
88
lofficialseall GOVERNMENT OF THE STATE OF BAJA CALIFORNIA SUR
PGIE
State of Eaja California Sur STATE ATTORNEY GENERATS OFFICE
Attorney General's Office BUREAU OF FORENSIC SERVICES
FIETD FORENSICS
Reference No.
Delivery-Receipt of Evidence ec/3063/2022/NUc

Page or Claim Delivery-Receipt Place Time and Date of Delivery-Receipt


5JC 22 SEMEFOl San Jose del Cabo 10/29 /2022
2046 20:50 hou rs

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.

lRubber stamped seall


llllesiblel

2. Packaging. (Note the conditions of the packaging. when any show alteration, deterioration or any other
anomaly, specify it.)

Delivery Person Receiver


Lic. Eduardo Trinidad Juarez Illlegible]
PGJE Criminal Expert
fllegible signaturel

Full Name, institution, position and signature Full Name, institution, position and signature

Annexed delivery-receipt continuation:Yes I No E

l Servicio M6dico Forense, Forensic Medical Service


Page _ of _
fllegiblel
89
{Officialsea l GOVERNMENT OF THE STATE OF BAJA CALIFORNIA SUR
PGIE
State of Eaja California Sur STATE ATTORNEY GENERAYS OFFICE
Attorney General's Office BUREAU OF FORENSIC SERVICES
FIETD FORENSICS
Reference No.
Delivery-Receipt of Evidence sJc/3063/2022

Page or Claim Delivery-Receipt place Time and Date of Delivery-Receipt


sJc 22 Evidence room San Jose del Cabo Colonia Las Veredas Oct 30, Illl b lel
2046 11:31 hours

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

Delivery Person Receiver


Lic. Eduardo Trinidad Juarez Illlegible signatu re]
PGJE Criminal Expert Karen Andrea Castro 0lleeiblel
Illlegible signature] Evidence Room Assistant

Full Name, institution, position and signature Full Name, institution, position and signature

Annexed delivery-receipt continuation:Yes E No E


Page 1of 1
EXHIBIT D
J
#

/j

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