Latinos for Trump v. Sessions

Filing 1

COMPLAINT AND APPLICATION FOR INJUNCTIVE RELIEF ( Filing fee $ 402 receipt number 0542-14386818). No Summons requested at this time, filed by Latinos for Trump. (Attachments: #1 Exhibit 1 - List of State Governors and Secretaries of State, #2 Exhibit 2 - Cain Declaration 20210118, #3 Exhibit 3 - Global Risk Analysis: Special Report, #4 Exhibit 4-1, #5 Exhibit 4-2, #6 Exhibit 4-3, #7 Exhibit 4-4, #8 Exhibit 4-5, #9 Exhibit 4-6, #10 Exhibit 4-7, #11 Exhibit 4-8, #12 Exhibit 4-9, #13 Exhibit 4-10, #14 Exhibit 4-11, #15 Exhibit 4-12, #16 Exhibit 4-13, #17 Exhibit 4-14, #18 Exhibit 4-15, #19 Exhibit 4-16, #20 Exhibit 4-17, #21 Exhibit 4-18, #22 Exhibit 4-19, #23 Exhibit 4-20, #24 Exhibit 4-21, #25 Exhibit 4-22, #26 Exhibit 4-23, #27 Exhibit 4-24, #28 Exhibit 4-25)(Davis, Paul)

While in Congress, David Valadao made millions from his business -- but Valadao was repeatedly sued for fraud
and failing to pay over ten million in debts. Valadao’s business failed to pay taxes and filed for bankruptcy -sticking taxpayers, workers, and small businesses with a thirteen million dollar bill. Worse, after a worker’s arm
was cut off at Valadao’s business -- due to a dangerous piece of Valadao’s machinery -- the state investigated and
fined Valadao’s business for failing to protect workers and a jury ruled Valadao’s business was to blame.
As A Member Of Congress, Valadao Disclosed Receiving Between $6 Million And $30 Million In Income
From Valadao Dairy. [Clerk of the House of Representatives, accessed 10/17/19]
Report
2012

David Valadao Income From Valadao Dairy
Amount Low
Amount High
$1,000,001
$5,000,000

2013

$1,000,001

$5,000,000

2014

$1,000,001

$5,000,000

2015 (Amended)

$1,000,001

$5,000,000

2016

$1,000,001

$5,000,000

2017

$1,000,001

$5,000,000

2019 (Termination)
Total

N/A
N/A
$6,000,006
$30,000,000
[Clerk of the House of Representatives, accessed 10/17/19]

Description
Partnership / Farm
Income
Partnership / Farm
Income
Partnership / Farm
Income
Partnership / Farm
Income
Partnership / Farm
Income
Partnership / Farm
Income

As A Member Of Congress, Valadao Disclosed Receiving At Least $15 Million In Income From Triple V
Dairy. [Clerk of the House of Representatives, accessed 10/17/19]
Report
2012

David Valadao Income From Triple V Dairy
Amount Low
Amount High
$1,000,001
$5,000,000

2013

$1,000,001

$5,000,000

2014

$1,000,001

$5,000,000

2015 (Amended)

$5,000,000

$5,000,000+

2016

$5,000,000

$5,000,000+

2017

$5,000,000

$5,000,000+

2019 (Termination)
Total

N/A
$18,000,003

N/A
$30,000,000+

Description
Partnership / Farm
Income
Partnership / Farm
Income
Partnership / Farm
Income
Partnership / Farm
Income
Partnership / Farm
Income
Partnership / Farm
Income

2017: In His Annual Personal Financial Disclosure Report, Valadao Disclosed Being A Partner At Valadao
Dairy And Triple V Dairy. [Clerk of the House of Representatives, filed 6/12/18]

[Clerk of the House of Representatives, filed 6/12/18]
November 2017: Valadao’s Triple V Dairy Allegedly Failed To Pay Two Loans From Rabobank Valued At
$8.3 Million. “A dairy owned by Hanford Rep. David Valadao and his family appears headed for the auction block,
as creditors have taken control of the day-to-day operations and have begun selling off cattle and equipment to pay
back more than $8 million in unpaid loans. In November, Rabobank sued Triple V Dairy in Fresno County
Superior Court, alleging two loans totaling about $8.3 million had gone unpaid. The lawsuit names Triple V,
located east of Corcoran; the Republican congressman; five of his family members; two other businesses, Lone Star
Dairy and Two Star Dairy; and 50 unnamed defendants. Court documents dated March 28 show that both sides
agreed that Rabobank would take control of Triple V Dairy until its sale can be negotiated. Rabobank appointed
John Van Curen, president of Old West Ranch Company in Fresno, as its agent to handle the day-to-day affairs at
Triple V.” [Fresno Bee, 6/11/18]
Lawley’s Filed A Lawsuit Alleging Triple V Cattle Failed To Pay For $1 Million In Animal Products.
“California agricultural bank Rabobank sued Triple V in November for breaking its contract, alleging the farm
defaulted on $8.3 million in loans for heifers and feed. And Stockton cattle farm supply company Lawley’s said in
a lawsuit filed last month that Triple V had failed to pay for an additional $1 million in animal nutrition and
immunizer products that the farm bought on credit.” [Mercury News, 3/12/18]
Lawley’s Filed 11 Complaints Against Valadao, Including Breach Of Contract, Fraud, Intentional
Misrepresentation, And Negligent Misrepresentation. [San Joaquin County Superior Court, Case # STK-CVUDC-2018-1580, filed 2/9/18]

[San Joaquin County Superior Court, Case # STK-CV-UDC-2018-1580, filed 2/9/18]
Land O’ Lakes Alleged Triple V Dairy Owed $792,636 For “Milk-Replacer Products” And Other Unpaid
Debts. [United States District Court Eastern District of California, Case # 1:18-cv-00460, filed 4/3/18 (Page 4)]

[United States District Court Eastern District of California, Case # 1:18-cv-00460, filed 4/3/18 (Page 4)]
2016: Valadao And Triple V Dairy Were Named In A $6,018 Tax Lien In Tulare County. [Tulare County Tax
Collector, 9/26/16]

[Tulare County Tax Collector, 9/26/16]
In His Bankruptcy Filing, Valadao Listed Owing The Internal Revenue Service $11,000 For Payroll Taxes
Relating To Unpaid “Triple V Payroll Taxes.” [United States Bankruptcy Court for the Eastern District of
California, Case #19-10542, Voluntary Petition for Individuals Filing for Bankruptcy, filed 2/15/19 (Page 3)]

[United States Bankruptcy Court for the Eastern District of California, Case #19-10542, Voluntary Petition for
Individuals Filing for Bankruptcy, filed 2/15/19 (Page 3)]

Valadao Filed For Chapter 7 Bankruptcy Protection For Their Dairy And Cattle Businesses. “Citing business
debts totaling more than $13 million, former Rep. David Valadao and his wife have filed for bankruptcy protection
for their dairy and cattle businesses. The couple filed last week for Chapter 7 protection with the U.S. Bankruptcy
Court for the Eastern District of California in Fresno for their related businesses, Triple V Dairy, Triple V Cattle
and Valadao Dairy in the Hanford and Tulare areas.” [The Business Journal, 3/1/19]
Chapter 7 Bankruptcy Seeks To Rid Debtors Of Personally Liability For Their Debts. “The objective
of both Chapter 7 and Chapter 13 bankruptcy is to obtain a ‘discharge’ of debts. If the bankruptcy court
discharges your debts in bankruptcy, it means that you will be no longer be held personally liable for these
debts. Most consumer debt, including medical bills and credit card bills, is dischargeable. Certain debts,
however, are non-dischargeable, meaning they cannot be wiped out through bankruptcy. These are debts
that Congress has decided should not be able to be discharged for public policy reasons.” [Justia, accessed
6/15/20]
Valadao’s Bankruptcy Listed Over $13 Million In Liabilities Owed To The IRS, Workers At Triple V Dairy,
And Businesses. [Valadao Voluntary Petition for Individuals Filing for Bankruptcy, filed 2/15/19]
Creditor

Valadao Liabilities
Amount

Kings Federal Credit Union
California Attorney General
California Department of Tax
Employment Development
Department
Franchise Tax Board
Internal Revenue Service
Kings County Tax Collector
Securities & Exchange Commission
State Compensation Insurance Fund
United States Attorney
United States Department of Justice
AAA Quality Services, Inc.
Animal Health International
Automated Dairy Systems
AZ Auto Parts

$
-

Baker Manock & Jensen
Best Weigh Scale Co., Inc.
Bre Ella Farms, Inc.
Calva Products, LLC
Cardmember Service
Central California Implement
Chrysler Capital
Chrysler Capital
Colson Auto Parts
Costa Spraying, Inc.
Crop Production Services
CRV USA Holdings, Inc.
Daniel Padilla on behalf of himself
and others similarly situated 2554
Waukena Dr. Tulare, CA 93274

$
$
$
$
$
$
$
$
$

$
$
$
$
$

$

25,000.00

11,000.00

1,395.35
171,357.00
35,559.72
3,759.15
3,475.20
78,728.00
876,530.00
8,272.50
8,736.00
22,015.65
3,249.25
25,716.00
23,489.60
325,000.00

Notes
Claim secured with 2018 Chevrolet
Traverse 45000
(Blank)
(Blank)
(Blank)
(Blank)
Triple V Payroll Taxes
(Blank)
(Blank)
(Blank)
(Blank)
(Blank)
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
For notice purposes – attorneys for
Rabobank
Partnership Debt - Triple V
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
For Notice Purposes - Stipulated
judgement in wage and hour
lawsuit re Triple V Dairy

Danny Garcia
Delray Tire
Diesel & Pump Injector

$
$
$

47,200.00
5,480.16
4,928.00

Edward and April Valadao

-

Fishman, Larsen, & Callister
Frank's Automotive Inc.
G&G Cattle LLP
Gabriel & Sons Silage
Gary Honeycutt, Receiver
Goshen West Ranch
Griswold, La Salle, et al.
Hydraulic Controls
Imperial Western Products, Inc.
Innovative Ag Services
JC Lansowne, Inc

$
$
$
$
$
$
$
$

433.15
5,586.00
2,000.00
104,409.35

John Van Curen, Receiver
Johnson Calf Pens

$
$

13,119.10

Jose Dimas and Mary Jane Valadao
Kahn Soares & Conway

$
$

-

Kahn Soares & Conway
Kings Dairy Supply
Kings Dairy Supply
Kubota
Laird Manufacturing
Lampe Chrysler Dodge
Land O' Lakes
Law Offices of Bradley A. Silva

$
$
57,439.07
$
100,180.69
$
$
5,179.97
$
Unknown
$
-

Law Offices of Santos Gomez

$

-

Lawley's Inc
Lawrence Tractor

$
$

993,757.00
6,401.41

Leslene A Simoes
Linder Equipment
Manuel F. Godinho
Marty Lyons Breeding Services

$
$
$
$

4,570.96
6,203.67
4,500.00

McCormick, Barstow, et al.
Mid Valley Cotton Growers, Inc
Mid Valley Pipe & Supply
Miguesl Dairy Service
Morris Levin & Son
Myersward Tractor
Netto Ag
Overland Stockyard
Praxair Distributing Inc

$
$
18,092.00
$
17,923.72
$
12,778.32
$
14,931.33
$
1,184.22
$
63,542.73
$ 1,338,041.00
$
607.98

13,126.32
10,000.00
5,904.00
5,053.00

Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
For notice purposes – general
partner/Triple V
Attorneys for Triple V Recorder –
for notice purposes
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
For notice purposes
Partnership Debt - Triple V Dairy
For notice purposes
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
For Notice purposes - Triple V
Receiver
Partnership Debt - Triple V Dairy
For Notice Purposes - General
Partner/Triple V
For Notice Purposes
Attorney for Overland Stockyard for notice purposes
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Party to lawsuit
For notice purposes
For notice purposes - Attorneys for
Daniel Padilla
Party to lawsuit - Partnership debt Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy /
Dairy landord
Partnership Debt - Triple V Dairy
(Blank)
Partnership Debt - Triple V Dairy
For Notice Purposes - Western
Milling, LLC
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy
Partnership Debt - Triple V Dairy

Party to lawsuit - Partnership Debt Rabobank, N.A.
$ 8,335,443.00
Triple V Dairy
Raimondo & Associates
$
For Notice Purposes
RC Farms
$
11,865.00
Partnership Debt - Triple V Dairy
Refugio's Wedling & Repair
$
10,484.00
Partnership Debt - Triple V Dairy
Robinson Calf Ranch
$
16,074.20
Partnership Debt - Triple V Dairy
Rodarakis & Sousa
$
For Notice Purposes - Lawley's
Roman Electric, Inc
$
332.00
Partnership Debt - Triple V Dairy
Saetzman Auto & Electric
$
1,903.11
Partnership Debt - Triple V Dairy
Sallyport Commercial Finance,
LLC
$
16,232.29
Partnership Debt - Triple V Dairy
Saul Tafoya
$
9,072.00
Partnership Debt - Triple V Dairy
Sousa & Company
$
For Notice Purposes
Stanislaus Farm Supply
$
23,885.40
Partnership Debt - Triple V Dairy
Stoel Rives LLp
$
Attorneys for Land O' Lakes
TF Tire & Service
$
13,896.74
Partnership Debt - Triple V Dairy
TJI Trucking
$
120,128.00
Partnership Debt - Triple V Dairy
Tulare County Roll-Off
$
2,519.21
Partnership Debt - Triple V Dairy
Tulare Dairy Herd Improvement
Assoc
$
727.82
Partnership Debt - Triple V Dairy
Tule Trash Co
$
1,413.64
Partnership Debt - Triple V Dairy
US Farm Systems
$
1,606.91
Partnership Debt - Triple V Dairy
US Trustee's Office
For Notice Purposes
Valadao Dairy
$
4,684.80
Partnership Debt - Triple V Dairy
Valley Agriculture Software Inc
$
6,433.00
Partnership Debt - Triple V Dairy
Veterinary Services, Inc
$
536,670.24
Partnership Debt - Triple V Dairy
Water Well Solutions
$
16,635.88
Partnership Debt - Triple V Dairy
West Tulare Ag Holdings LLC
$
Partnership Debt - Triple V Dairy
Western Equipment Finance, Inc
$
Partnership Debt - Triple V Dairy
Western Milling
Unknown
Partnership Debt - Triple V Dairy
Willitts Pump
$
29,355.00
Partnership Debt - Triple V Dairy
Wolf, Rifkin, Shapiro, Schulman
$
For notice purposes - Lawley's
Wolf, Rifkin, Shapiro, Schulman
$
For notice purposes - Lawley's
WW Generators
$
753.23
Partnership Debt - Triple V Dairy
TOTALS:
$ 13,645,972.04
[Valadao Voluntary Petition for Individuals Filing for Bankruptcy, filed 2/15/19]
2017: In His Annual Personal Financial Disclosure Report, Valadao Disclosed Being A Partner At Valadao
Dairy. [Clerk of the House of Representatives, filed 6/12/18]
CalOSHA Fined Valadao Dairy $6,450 For Safety Violations Relating To The Incident. “The California
Division of Occupational Safety and Health (CalOSHA) cited and fined Valadao Dairy for safety violations. One
was that ‘the employer did not provide training and instruction for the employee who was injured operating the
waste separator at the dairy.’ The second, more serious violation was for failing to have guardrails around the
elevated platform where Ocampo was standing as he scraped manure solids that had clogged a screen near the
auger. CalOSHA initially proposed to fine the dairy $13,275 for the violations; the penalty was later negotiated
down to $6,450, which was paid in May 2017.” [Fresno Bee, 2/11/20]
Valadao Dairy Was Found To Be Responsible For 80 Percent Of The Accident That Resulted In An
Employee Losing His Right Arm Below The Elbow. “Former Rep. David Valadao’s family dairy is asking a
California appeals court to reconsider part of a recent jury verdict that held the farm mostly responsible for a 2016
accident that severed an employee’s hand. His dairy’s worker’s compensation insurance carrier had been trying to

limit its potential financial losses from an incident in which employee Carlos Martinez Ocampo’s arm was caught
in an auger and cut off below the right elbow. A Kings County jury in October found that Valadao Dairy bore the
greatest share of responsibility for the incident, assigning 80 percent of fault to the dairy, while the manufacturer of
the equipment, Tulare-based U.S. Farm Systems, was deemed 20 percent responsible.” [Fresno Bee, 2/11/20]