Gloria Trevi's Cross-Complaint (Dec. 27, 2023)

1 BROWN RUDNICK LLP
CAMILLE M. VASQUEZ, #273377

2 [email protected]
LEO J. PRESIADO, #166721
3 [email protected]
SAMUEL A. MONIZ, #313274
4 [email protected]
2211 Michelson Drive, 7th Floor
5 Irvine, California 92612
Telephone: (949) 752-7100
6 Facsimile: (949) 252-1514
7 BROWN RUDNICK LLP

JESSICA N. MEYERS (admitted Pro Hac Vice)
8 [email protected]
7 Times Square
9 New York, New York 10036
Telephone: (212) 209-4800
10 Facsimile: (212) 938-2880
11 Attorneys for Defendant

GLORIA DE LOS ANGELES TREVINO RUIZ
12 aka GLORIA TREVI
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF LOS ANGELES
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16 JANE DOE K.C. 1, an individual; and JANE CASE NO. 22GDCV01128

DOE A.H. 2, an individual,
17 ASSIGNED FOR ALL PURPOSES TO THE
Plaintiffs, HON. RALPH C. HOFER, DEPT. D
18 vs.
DEFENDANT GLORIA TREVI’S CROSS-
19 GLORIA DE LOS ANGELES TREVINO COMPLAINT FOR
RUIZ aka GLORIA TREVI, an individual; (1) SEXUAL ASSAULT;
20 SERGIO GUSTAVO ANDRADE SANCHEZ (2) AIDING AND ABETTING SEXUAL
aka SERGIO ANDRADE, an individual; ASSAULT;
21 MARIA RAQUENEL PORTILLO JIMENEZ (3) SEXUAL BATTERY;
aka MARY BOQUITAS and MARY (4) AIDING AND ABETTING SEXUAL
22 RAQUENEL, an individual; and DOES 4 BATTERY;
through DOE 50, inclusive, (5) BATTERY;
23 (6) AIDING AND ABETTING
Defendants. BATTERY;
24 (7) INTENTIONAL INFLICTION OF
EMOTIONAL DISTRESS;
25 GLORIA DE LOS ANGELES TREVINO (8) NEGLIGENT INFLICTION OF
RUIZ, an individual, EMOTIONAL DISTRESS; AND
26 (9) INDEMNITY
Cross-Complainant,
27 vs. ACTION FILED: December 30, 2022
TRIAL DATE: TBD
28 SERGIO GUSTAVO ANDRADE SANCHEZ
DEFENDANT GLORIA TREVI’S CROSS-COMPLAINT

1 aka SERGIO ANDRADE, an individual;
JANE DOE K.C. 1, an individual; JANE DOE
2 A.H. 2, an individual; JANE ROE J.P. 1, an
individual; CONEXIONES AMERICANAS,
3 S.A. de C.V., a Mexican company, and DOES
1 through 100, inclusive,
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Cross-Defendants.
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6 AND RELATED CROSS-ACTION
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1 Defendant and Cross-Complainant Gloria de Los Angeles Trevino Ruiz (“Cross-
2 Complainant” or “Ms. Trevi”), hereby alleges as follows:
3 INTRODUCTION
4 1. This case has a true predator at its center: Defendant and Cross-Defendant Sergio
5 Gustavo Andrade Sanchez (“Andrade” or “Sergio Andrade”). A successful musician, manager, and
6 producer in the 1970s, 1980s, and 1990s, Andrade helped orchestrate the rise of multiple young
7 musical talents, particularly in Mexico. He was sometimes dubbed “Mr. Midas” for his ability to
8 recognize and promote talented artists – especially young, female artists – and turn them into stars.
9 Andrade, whose brother was a senator, was also well connected with the Mexican business and
10 political elite and occupied a position of significant cultural power and influence. That position
11 allowed him to draw many young girls into his sphere of influence, who gathered around him in the
12 hopes that he would guide, mentor, and launch their careers in entertainment, as he had previously
13 done for others. But once these young girls and women had been drawn into his sphere by dreams
14 of stardom, he subjected them to total control and sadistic abuse – mental, financial, physical, and
15 sexual. Ms. Trevi was one of those young women.
16 2. Ms. Trevi rose from obscurity to become a world-class musical talent, sometimes
17 referred to as the “Mexican Madonna,” in the late 1980s and 1990s. A revolutionary and dazzling
18 performer, she is adored by millions, particularly in Latin America. Unbeknownst to the public,
19 however, when she was offstage, she was little more than a prisoner: controlled, mentally and
20 physically tortured, and effectively enslaved by Andrade. Ms. Trevi was certainly not alone in
21 being abused by Andrade but, because she had risen to such stardom, she was his most valuable
22 asset and was, thus, the one woman he was most determined to control and subjugate.
23 3. Ms. Trevi encountered Andrade and came under his control as a child, in her early
24 teens, when she was first trying to break into the Mexican music industry as a singer and performer.
25 Andrade evidently recognized that he could exploit her undeniable talent for enormous profit. He
26 took charge of her career, which soon took off (riding her coattails to ever greater success himself).
27 But Andrade also recognized Ms. Trevi as an isolated and vulnerable girl who was easy prey to his
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1 manipulation, control, and abuse. He took full advantage, subjecting the rising child superstar that
2 he had taken on to grotesque abuse calculated to break her spirit.
3 4. Ms. Trevi is informed and believes and thereon alleges that there were many other
4 women and girls that Andrade controlled and abused over the years, but Ms. Trevi was his true star
5 – and, thus, the girl he most needed and wanted to dominate and control. To that end, Andrade
6 controlled all aspects of Ms. Trevi’s life, with the assistance of other entities and young women
7 such as Plaintiff and Cross-Defendant Jane Doe A.H. 2 (“Cross-Defendant A.H.”) and Plaintiff and
8 Cross-Defendant Jane Doe K.C. 1 (“Cross-Defendant K.C.,” and collectively, “Plaintiffs”), whom
9 he subjugated and then enlisted to perpetuate his abuse. Ms. Trevi was consistently watched by
10 multiple young women that had been similarly subdued by Andrade to ensure that she stayed in
11 line, never spoke freely to men other than Andrade, and never rebelled against his abuse. She had
12 no control over the money generated from her performances and record sales, which was diverted
13 to Andrade through his company, Cross-Defendant Conexiones Americanas S.A. de C.V.
14 (“Conexiones Americanas”). Instead of living the lifestyle of the rich and famous that one might
15 expect of the “Mexican Madonna,” Ms. Trevi, in private, was often dressed in old rags, sometimes
16 forced to sleep naked for days on a cold bathroom floor. She was generally forbidden from
17 speaking to any men other than Andrade (although she was sometimes allowed and instructed to
18 participate in interviews with men under Andrade’s supervision). Instead, she was surrounded by
19 other young women and girls who, like herself, were controlled by Andrade and did his bidding by
20 watching her and reporting any supposed disobedience or imagined transgression against his
21 authority to Andrade, which would result in sadistic punishments. She was forced into extreme and
22 grueling exercises at Andrade’s command. She was starved at his whim. She was brutally beaten,
23 sometimes to the point of unconsciousness, as “punishment” for made-up transgressions. And she
24 was sexually assaulted by him—raped repeatedly and sometimes brutally. The mental, sexual, and
25 other abuse inflicted by Andrade eventually drove Ms. Trevi to attempt suicide.
26 5. With assistance from others, including without limitation Conexiones Americanas
27 and various young women under his control such as Cross-Defendant K.C. and Cross-Defendant
28 A.H., Andrade successfully hid, for many years, the fact that he had gathered around him a group
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1 of young women that he controlled, physically and mentally abused, and raped. Eventually, he was
2 discovered and finally convicted in Mexico and imprisoned on charges of rape, corruption of
3 minors, and kidnapping. Ms. Trevi is informed and believes and thereon alleges that Andrade has
4 long-since been released from prison and is living free in Mexico – and has access, once again, to
5 young girls.
6 6. Over time, Ms. Trevi has painstakingly rebuilt her life and career. She has a family
7 and continues to be recognized as a major musical talent and performer. Her success is undeniable
8 and impressive. Unfortunately, her success has also made her a target for those with motive to
9 destroy her and her career. False rumors, orchestrated by T.V. Azteca, S.A. de C.V., Patricia
10 Chapoy, Cross-Defendant A.H. and others, have long circulated and been spurred by salacious and
11 irresponsible reports in certain media, that Ms. Trevi participated in the horrors perpetrated by her
12 abuser. Since 2009, Ms. Trevi has been prosecuting a defamation lawsuit against T.V. Azteca,
13 S.A., de C.V., Patricia Chapoy and others in Texas for instigating these false rumors.1 The
14 Complaint filed by Plaintiffs to commence the above-captioned action seeks to perpetuate and take
15 advantage of that false narrative, by knowingly and wrongfully attributing blame to Ms. Trevi for
16 wrongs done by Andrade.
17 7. Ms. Trevi brings this Cross-Complaint to seek justice against Andrade for
18 committing sexual assault, pursuant, inter alia, to California Code of Civil Procedure § 340.16(e).
19 By this Cross-Complaint, Ms. Trevi seeks to hold Andrade accountable for his vicious acts of abuse
20 against her. In addition, to the extent that Ms. Trevi is deemed liable in any amount for any wrongs
21 committed by Andrade (or anyone else) in this action – which she denies – Ms. Trevi is entitled to
22 indemnity from Andrade and the other Cross-Defendants named herein, all of whom are
23 responsible, in whole or in part, for any harm complained of by Plaintiffs in this action.
24 8. Ms. Trevi brings this Cross-Complaint with great sadness. For many years, she has
25 remained silent about the horrific abuse she endured at Andrade’s hands, both because she did not
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Gloria De Los Angeles Trevino Ruiz, et al v. Azteca America, et al, Cause No. C-1027-09-C, pending in the
28 139th District Court, Hidalgo County, Texas.
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1 wish to relive the awful experiences, and because she wished to protect her children while they
2 were underage. But her children are now grown, and false attacks against Ms. Trevi persist in
3 blaming her for the acts of the very man who inflicted horrific abuse on her. The time has now
4 come to set the record straight and to hold Andrade accountable for his actions.
5 PARTIES
6 9. Ms. Trevi is an individual over the age of eighteen and currently resides in the State
7 of Texas.
8 10. Ms. Trevi is informed and believes and thereon alleges that Defendant and Cross-
9 Defendant Sergio Andrade is a Mexican citizen over the age of eighteen, who currently resides in
10 Mexico.
11 11. Ms. Trevi is informed and believes and thereon alleges that Cross-Defendant
12 Conexiones Americanas is an entity organized and existing under the laws of Mexico with its
13 principal place of business in Mexico.
14 12. Ms. Trevi is informed and believes and thereon alleges that Cross-Defendant A.H. is
15 a Mexican citizen over the age of eighteen, who currently resides in Mexico. Cross-Defendant
16 A.H. is the individual who commenced this action under the pseudonym Plaintiff Jane Doe A.H. 2.
17 Cross-Defendant A.H. is provisionally named herein under a pseudonym, pending a determination
18 by the Court whether she may be publicly designated as a plaintiff and cross-defendant under her
19 own name.
20 13. Ms. Trevi is informed and believes and thereon alleges that Cross-Defendant K.C. is
21 a Mexican citizen over the age of eighteen, who currently resides in Mexico. Cross-Defendant
22 K.C. is the individual who commenced this action under the pseudonym Plaintiff Jane Doe K.C. 1.
23 Cross-Defendant K.C. is provisionally named herein under a pseudonym, pending a determination
24 by the Court whether she may be publicly designated as a plaintiff and cross-defendant under her
25 own name.
26 14. Ms. Trevi is informed and believes and thereon alleges that Cross-Defendant Jane
27 Roe J.P. 1 (“Roe J.P. 1”) is a Mexican citizen over the age of eighteen, who currently resides in
28 Mexico. Roe J.P. 1 is Cross-Defendant A.H.’s mother. Roe J.P. 1 is provisionally named herein
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1 under a pseudonym, pending a determination by the Court whether she may be publicly designated
2 as a plaintiff and cross-defendant under her own name.
3 15. Ms. Trevi is ignorant of the true names and capacities of Cross-Defendants sued
4 herein as Does 1-100, inclusive, and therefore sues these Does by such fictitious names. Ms. Trevi
5 will amend this Complaint to allege the Does’ true names and capacities when ascertained. Each of
6 the Does is in some manner responsible for some or all of the damages, acts and/or omissions
7 alleged herein. Ms. Trevi is informed and believes and thereon alleges that one or more of the
8 Does assisted Andrade, Conexiones Americanas, and/or the other Cross-Defendants named herein
9 in facilitating and covering up Andrade’s serial abuse and sexual assault of young women,
10 including Ms. Trevi. Ms. Trevi is further informed and believes and thereon alleges that one or
11 more of the Does are officers, directors, employees, or agents of one or more entities that assisted
12 Andrade, Conexiones Americanas, and/or the other Cross-Defendants named herein in facilitating
13 and covering up Andrade’s abuse and sexual assault of young women, including Ms. Trevi.
14 Andrade, Conexiones Americanas, Cross-Defendant A.H., Cross-Defendant K.C., Roe J.P. 1, and
15 Does 1-100 are collectively referred to herein as “Cross-Defendants.” Each of the Cross-
16 Defendants named herein is in some manner legally responsible for the damages, acts, and/or
17 omissions alleged herein.
18 16. At all times relevant, Cross-Defendants were the agents, servants, employees,
19 employers, partners, principals, representatives and/or alter egos of each other and in doing the
20 things alleged herein were acting within the course and scope of their authority as such agents,
21 servants, employees, partners, principals, representatives and/or alter egos with the permission and
22 consent of the remaining defendants.
23 JURISDICTION AND VENUE
24 17. Jurisdiction exists and venue is proper in the State of California, County of Los
25 Angeles pursuant to Code of Civil Procedure §§ 395 and 395.2, because the actions and injury
26 complained of herein occurred, in part, in Los Angeles, California.
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1 GENERAL ALLEGATIONS
2 18. As a child in the 1980s, Ms. Trevi traveled alone from her home in Monterrey to
3 Mexico City, with the goal of breaking into the music industry. At the time, Andrade was already
4 established as a successful producer and was credited with the rise of other young artists. Ms.
5 Trevi is informed and believes and thereon alleges that, at this time, Andrade had already
6 committed acts of sexual and other abuse against young girls with whom he had worked, and had
7 covered up the same with the assistance of various persons and entities in the music industry and
8 otherwise. When Ms. Trevi first met Andrade, he was gathering together five inexperienced young
9 girls to form a new musical group called Boquitas Pintadas, with the stated goal of training and
10 forming them into a successful rock group. Ms. Trevi was one of the final recruits. Boquitas
11 Pintadas also included another teenage girl, Defendant Maria Raquenel Portillo Jimenez (“Mary
12 Boquitas”). Ms. Trevi is informed and believes and thereon alleges that, during this period,
13 Andrade secretly married Mary Boquitas, who, like Ms. Trevi, was an underage girl and easy prey
14 to his influence, manipulation, and abuse.
15 19. Boquitas Pintadas was not a success and soon dissolved. Andrade then became
16 focused on Ms. Trevi. As a much older and established figure with extensive connections, Andrade
17 was able to help advance her career and arrange for her appearance on television and radio. Under
18 Andrade’s direction and supervision, Ms. Trevi began performing and recording. She was an
19 undeniable talent, giving dazzling and revolutionary performances. She soon gained a wide and
20 enthusiastic audience.
21 20. Offstage, however, Andrade continued to exercise pervasive, coercive control over
22 Ms. Trevi. The fact that she was such a success made it that much more important for his
23 domination of her to be complete. His “training” of her was vicious. He required her to engage in
24 extreme forms of exercise, controlled her intake of food, and controlled where and when she slept.
25 As punishments, he would sometimes force her to sleep on a cold bathroom floor. Other times, he
26 would beat her with closed fists and whip her with belts or cables. And both before and after she
27 reached the age of eighteen, he subjected her to sexual abuse. As part of his pattern of controlling
28 Ms. Trevi, Andrade used an entity under his control, Conexiones Americanas, to run the business
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1 side of her career, depriving her of control over the financial fruits of her labors. It was
2 Conexiones Americanas – not Ms. Trevi – that entered into contracts related to her performances
3 and received payments for her work. The revenues from her work were directed to Conexiones
4 Americanas and, indirectly, to Andrade.
5 21. In addition to Mary Boquitas and Ms. Trevi, Andrade accumulated other young
6 women around him as well. Cross-Defendant A.H. came to Andrade as a teenager with her mother,
7 Roe J.P. 1. Ms. Trevi is informed and believes and thereon alleges that Andrade soon became
8 focused on Cross Defendant A.H. and, eventually, with the knowledge and express written consent
9 and permission of her mother, Roe J.P. 1, Andrade married Cross-Defendant A.H. while she was a
10 minor, replacing Mary Boquitas as his wife.
11 22. Andrade exercised extensive control over the young women who were brought into
12 his circle, controlling and abusing them and using them as agents to impose his will on other
13 victims. For instance, it was Cross-Defendant A.H. who suggested to Andrade bringing Cross-
14 Defendant K.C. (among others) into his circle, and it was Cross-Defendant A.H. who introduced
15 Cross-Defendant K.C. to him. Ms. Trevi is informed and believes and thereon alleges that, even
16 while Cross-Defendant A.H. was married to Andrade, she would procure other underage girls for
17 her husband and listen outside the door as he assaulted and abused them and/or would participate in
18 the abuse herself. Further, Ms. Trevi is informed and believes and thereon alleges that Cross-
19 Defendant K.C., in turn, brought other victims to Andrade, including but not limited to her own
20 sisters. Cross-Defendant K.C. assisted Andrade in other ways as well. For instance, Andrade
21 named Cross-Defendant K.C. and her sister as officers or agents of Conexiones Americanas and
22 used them as instruments of his own control over Ms. Trevi and her finances and career. Thus,
23 Cross-Defendant K.C. and her sister were put in positions of authority over Ms. Trevi and the
24 money generated from her wildly successful career and materially assisted Andrade in keeping Ms.
25 Trevi in a state of servitude and submission. As one example of this control, if Ms. Trevi was
26 required to sign a document, Cross-Defendant K.C. and/or her sister would, as adults and at
27 Andrade’s instruction and/or behest, watch Ms. Trevi to compel her to sign it.
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1 23. Andrade traveled with a group of these young women and girls to Los Angeles,
2 California on certain occasions. His abuse and sexual assaults against Ms. Trevi continued in
3 California, as elsewhere. By way of example, on one occasion in California, Andrade decided to
4 punish Ms. Trevi for an imagined transgression by beating her repeatedly with a belt. There was a
5 sadistic game that Andrade would play with such beatings: a preset number of blows had to be
6 endured and accepted by Ms. Trevi in silence. If Ms. Trevi were to cry out, gasp, or make any
7 other sign of distress, Andrade would treat that as a new punishable offense, and the beating would
8 start all over again from the beginning. During the course of the beating in question, Ms. Trevi
9 passed out. She regained consciousness on the ground, to find Andrade on top of her, sexually
10 assaulting her.
11 24. Andrade, assisted by one or more entities, including without limitation Conexiones
12 Americanas, went to great lengths to cover up his sexual assaults and pattern of horrific abuse,
13 including covering up incidents of abuse that occurred prior to his even meeting Ms. Trevi, as well
14 as acts of abuse against Ms. Trevi and others that preceded the incidents described herein. For
15 instance, Ms. Trevi is informed and believes and thereon alleges that Andrade, Conexiones
16 Americanas, and/or other entities under Andrade’s control made one or more payments to Cross-
17 Defendant A.H. and/or her mother, Roe J.P. 1., to buy their silence and maintain the secrecy of his
18 pervasive abuse of young women. As another example, Andrade impregnated dozens of young
19 women and girls and then, with the assistance of others, forced, coerced, or otherwise pressured
20 them into abortions. Those abortions were motivated, in whole or in part, to maintain the secrecy
21 of his sexual abuse. Ms. Trevi is informed and believes that these forced abortions were directed
22 and facilitated by Andrade with the assistance and funding of other persons and entities, including
23 without limitation Conexiones Americanas and its officers and agents.
24 25. Ms. Trevi herself was the victim of such coverup abortions. For instance, at one
25 point in the 1990s, while in Mexico, Ms. Trevi discovered that she was pregnant by Andrade as a
26 result of his ongoing sexual abuse. Andrade ordered Ms. Trevi to cross the border into the United
27 States where she could covertly terminate the pregnancy. Ms. Trevi was reluctant to do so. To
28 ensure that Ms. Trevi followed through in terminating the pregnancy in accordance with his
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1 command, Andrade sent Cross-Defendant K.C. and Mary Boquitas to escort her into the United
2 States to watch her and prevent any disobedience on her part. The night before Ms. Trevi
3 underwent the abortion, Cross-Defendant K.C., who was taller and stronger than Ms. Trevi, slept in
4 Ms. Trevi’s room by the door to ensure that Ms. Trevi did not attempt to escape. Ms. Trevi is
5 informed and believes and thereon alleges that Cross-Defendant K.C. did so on instructions from
6 Andrade and in her capacity as an agent of Andrade and Conexiones Americanas.
7 FIRST CAUSE OF ACTION
8 (Sexual Assault Against Andrade)
9 26. Ms. Trevi repeats and incorporates by this reference the foregoing paragraphs as
10 though set forth in full.
11 27. For many years, Andrade exercised pervasive control over Ms. Trevi’s life,
12 subjecting her to prolonged mental and physical abuse. Andrade used that abusive control – and
13 the vulnerable mental state it induced in Ms. Trevi – to commit multiple acts of sexual abuse and
14 assault against her, before and after her eighteenth birthday, and inside and outside of the State of
15 California. Those acts of abuse include, without limitation, the incident in California alleged
16 above, when Andrade beat Ms. Trevi until she lost consciousness and then sexually assaulted her.
17 28. The pattern of conduct alleged herein by Andrade constitutes sexual assault within
18 the meaning of, inter alia, California Code of Civil Procedure § 340.16(b)(1), because, for
19 example, Andrade touched Ms. Trevi in a sexual manner and without consent or through duress,
20 and engaged in sexual intercourse with her while she was unconscious and/or through duress and
21 without valid consent.
22 29. Andrade went to great lengths to cover up his abuse and sexual assaults of Ms.
23 Trevi, as well as his prior abuse and sexual assaults of other young women. Andrade used various
24 methods to accomplish this, including without limitation the use of fear, threats, and intimidation
25 against multiple young women and girls, including Ms. Trevi; the payment of hush money; and the
26 arrangement of numerous forced abortions for the women and girls under his control, including Ms.
27 Trevi. Andrade was materially assisted in these assaults and coverups by, inter alia, Cross-
28 Defendant K.C. and Conexiones Americanas. Ms. Trevi is informed and believes and thereon
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1 alleges that Conexiones Americanas provided assistance and funding for coverup activities, and
2 further engaged in coercive activities and enforced silence by and through its agents, including
3 without limitation Cross-Defendant K.C. and her sister, who, among other conduct, monitored and
4 spied on Ms. Trevi to ensure her ongoing servitude and submission to Andrade’s will. Ms. Trevi is
5 further informed and believes and thereon alleges that other entities similarly under Mr. Andrade’s
6 influence or control assisted him in covering up prior incidents of sexual assault and abuse.
7 30. Ms. Trevi is informed and believes and thereon alleges that, at all times relevant,
8 Conexiones Americanas was Andrade’s alter ego, and that Conexiones Americanas and its agents,
9 including without limitation Cross-Defendant K.C., conspired, cooperated, and materially assisted
10 him in perpetuating the systemic control and sexual and other abuse of Ms. Trevi.
11 31. Ms. Trevi is informed and believes and thereon alleges that Does 1-100 include
12 other entities and persons in positions of power with whom Andrade had business or personal
13 relationships, who were aware of his systematic abuse of young women and protected him and
14 prevented it from becoming publicly known.
15 32. As a result of the acts complained of herein, Ms. Trevi suffered and is entitled to an
16 award of damages in an amount subject to proof but in excess of the jurisdictional minimum of this
17 Court, including but not limited to physical pain and emotional distress.
18 33. The acts complained of herein were done with malice, oppression, and fraud, such
19 that Ms. Trevi is entitled to an award of exemplary damages.
20 34. Ms. Trevi brings this Cross-Complaint timely pursuant to California Code of Civil
21 Procedure § 340.16(e), which revives claims for damages for adult sexual assault and related torts.
22 SECOND CAUSE OF ACTION
23 (Aiding And Abetting Sexual Assault Against Conexiones Americanas,

24 Cross-Defendant K.C., and Does 1-100)
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3 California. Those acts of abuse include without limitation the instance alleged above in which
4 Andrade beat Ms. Trevi until she lost consciousness and then sexually assaulted her.
5 37. The pattern of conduct alleged herein by Andrade constitutes sexual assault within
6 the meaning, inter alia, of California Code of Civil Procedure § 340.16(b)(1), because, for
7 example, Andrade touched Ms. Trevi in a sexual manner and without consent or through duress,
8 and engaged in sexual intercourse with her while she was unconscious and/or through duress and
9 without valid consent.
15 Trevi. Andrade was materially assisted in these assaults and coverups by, inter alia, Cross-
16 Defendant K.C. and Conexiones Americanas, and other persons and entities. Ms. Trevi is informed
17 and believes and thereon alleges that Conexiones Americanas provided assistance and funding for
18 coverup activities, and further engaged in coercive activities and enforced silence by and through
19 its agents, including without limitation Cross-Defendant K.C. and her sister, who, among other
20 conduct, monitored and spied on Ms. Trevi to ensure her ongoing servitude and submission to
21 Andrade’s will.
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6 42. Conexiones Americanas and Cross-Defendant K.C. knew that Andrade was
7 routinely engaged in the abuse and control of Ms. Trevi, and that his abusive conduct toward her
8 included sexual assault.
9 43. Conexiones Americanas and Cross-Defendant K.C. gave substantial assistance or
10 encouragement to Andrade, including by assisting him in controlling Ms. Trevi, keeping her in a
11 state of financial and other servitude, and covering up Andrade’s abuse.
12 44. The conduct of Conexiones Americanas and Cross-Defendant K.C. was a substantial
13 factor in causing Ms. Trevi harm.
18 THIRD CAUSE OF ACTION
19 (Sexual Battery Against Andrade)

26 California, including without limitation the instance alleged above in which Andrade beat Ms.
27 Trevi until she lost consciousness and then sexually assaulted her.
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1 49. Andrade’s conduct alleged herein constitutes sexual battery within the meaning,
2 inter alia, of Code of Civil Procedure § 340.16 and other statutes referenced therein, including
3 without limitation California Penal Code § 243.4 and California Civil Code § 1708.5. Andrade
4 intended to cause offensive and/or harmful sexual contacts with intimate parts of Ms. Trevi’s body
5 without Ms. Trevi’s consent, and did cause such harmful and/or offensive contacts.
6 50. Ms. Trevi did not consent to such physical contact and was not in a position to give
7 valid consent. Indeed, due to the pervasive abuse and control exerted by Andrade, Ms. Trevi was
8 entirely subject to the whims of Andrade and unable to give valid consent.
14 Trevi. Andrade was materially assisted in these assaults and coverups by, inter alia, Conexiones
15 Americanas. Ms. Trevi is informed and believes and thereon alleges that Conexiones Americanas
16 provided assistance and funding for coverup activities, and further engaged in coercive activities
17 and enforced silence by and through its agents, including without limitation Cross-Defendant K.C.
18 and her sister, who, among other conduct, monitored and spied on Ms. Trevi to ensure her ongoing
19 servitude and submission to Andrade’s will.
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8 FOURTH CAUSE OF ACTION
9 (Aiding and Abetting Sexual Battery Against Conexiones Americanas,

17 California, including without limitation the instance alleged above in which Andrade beat Ms.
19 59. Andrade’s conduct alleged herein constitutes sexual battery within the meaning,
20 inter alia, of California Civil Code § 1708.5. Andrade intended to cause offensive and/or harmful
21 sexual contacts with intimate parts of Ms. Trevi’s body without Ms. Trevi’s consent, and did cause
22 such harmful and/or offensive contacts.
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7 and her sister who, among other conduct, monitored and spied on Ms. Trevi to ensure her ongoing
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5 FIFTH CAUSE OF ACTION
6 (Battery Against Andrade)
13 California, including without limitation the instance alleged above in which Andrade first beat Ms.
14 Trevi until she lost consciousness and then sexually assaulted her. As part of this pattern of abuse
15 and control, Andrade frequently used physical violence against Ms. Trevi.
16 72. In doing the acts complained of above, Andrade made physical contact with Ms.
17 Trevi with the intent to cause physical and mental harm.
21 74. Ms. Trevi was harmed by the physical contact described above, and other similar
22 conduct by Andrade.
23 75. A reasonable person in Ms. Trevi’s position would have found the physical contact
24 inflicted by Andrade offensive.
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6 and her sister, who, among other conduct, monitored and spied on Ms. Trevi to ensure her ongoing
19 80. The acts complained of herein were done with malice, oppression and fraud, such
23 SIXTH CAUSE OF ACTION
24 (Aiding and Abetting Battery Against Conexiones Americanas,

28 / / /
19
5 California, including, without limitation, the instance alleged above in which Andrade first beat
6 Ms. Trevi until she lost consciousness and then sexually assaulted her. As part of this pattern of
7 abuse and control, Andrade frequently used physical violence against Ms. Trevi.
8 84. In doing the acts complained of above, Andrade made physical contact with Ms.
9 Trevi with the intent to cause physical and mental harm.
13 86. Ms. Trevi was harmed by the physical contact described above, and other similar
14 conduct by Andrade.
15 87. A reasonable person in Ms. Trevi’s position would have found the physical contact
16 inflicted by Andrade offensive.
20 against multiple young women and girls (including Ms. Trevi); the payment of hush money; and
21 the arrangement of numerous forced abortions for the women and girls under his control. Andrade
22 was materially assisted in these assaults and coverups by, inter alia, Conexiones Americanas. Ms.
23 Trevi is informed and believes and thereon alleges that Conexiones Americanas provided
24 assistance and funding for coverup activities, and further engaged in coercive activities and
25 enforced silence by and through its agents, including without limitation Cross-Defendant K.C. and
26 her sister who, among other conduct, monitored and spied on Ms. Trevi to ensure her ongoing
28 / / /
20
1 89. Ms. Trevi is informed and believes and thereon alleges that at all times relevant,
24 SEVENTH CAUSE OF ACTION
25 (Intentional And/Or Negligent Infliction of Emotional Distress Against Andrade,

26 Conexiones Americanas, Cross-Defendant K.C., and Does 1-100)
21
5 California, including without limitation the instance alleged above in which Andrade first beat Ms.
7 99. Andrade’s conduct described herein was extreme and outrageous.
8 100. Andrade and the other Cross-Defendants named herein committed the acts described
9 above with the intent to cause emotional distress, or acted with reckless disregard or negligence as
10 to the probability that it would cause emotional distress. Ms. Trevi is informed and believes and
11 thereon alleges that emotional distress was in fact a primary purpose of Andrade’s conduct – by
12 abusing and causing great mental anguish to the young women and girls under his control,
13 including Ms. Trevi, he was able to keep them under his control and continue to abuse them.
15 Trevi, as well as his prior abuse and sexual assaults of other young women, including without
16 limitation through the use of fear, threats, and intimidation against multiple young women and girls
17 (including without limitation Ms. Trevi), the payment of hush money, and the arrangement of
18 numerous forced abortions for the women and girls under his control. Andrade was materially
19 assisted in these assaults and in the coverups by, inter alia, Conexiones Americanas and other
20 entities or persons. Ms. Trevi is informed and believes and thereon alleges that Conexiones
21 Americanas provided funding for coverup activities, and further engaged in coercive activities by
22 and through its agents, including without limitation Cross-Defendant K.C.
23 102. Ms. Trevi is informed and believes and thereon alleges that at all times relevant
24 Conexiones Americanas was Andrade’s alter ego, and that it and its agents, including without
25 limitation Cross-Defendant K.C., conspired, cooperated, and materially assisted him in
26 perpetuating the systemic control and abuse of Ms. Trevi that included, without limitation,
27 Andrade’s sexual assaults of her.
28 / / /
22
5 104. The conduct alleged herein was extreme and outrageous.
6 105. As a result of the conduct alleged herein, Ms. Trevi suffered emotional distress.
7 106. The conduct by Andrade alleged herein, with the assistance of Conexiones
8 Americanas, Cross-Defendant K.C., and her sister and Does 1-100, was a substantial factor in
9 causing Ms. Trevi emotional distress.
17 EIGHTH CAUSE OF ACTION
18 (Indemnity And Contribution Against Andrade and Does 1-100)

21 111. On or about December 30, 2022, Plaintiffs commenced the above-captioned action
22 seeking damages against Andrade, Ms. Trevi, and Mary Boquitas for abuse they allege they
23 suffered either primarily or solely at Andrade’s hands. Both Plaintiffs allege that Ms. Trevi was in
24 some manner responsible for introducing them to Andrade and/or for some aspects of abuse they
25 suffered at Andrade’s hands. Ms. Trevi denies that she introduced either of them to Andrade and
26 further denies that she is responsible in any manner for any acts by Andrade that caused either
27 Cross-Defendant K.C. or Cross-Defendant A.H. any damages. Ms. Trevi is a survivor of abuse, not
28 a perpetrator, and denies that she owes any liability to either of them.
23
1 112. To the extent that Ms. Trevi is found at trial to have any legal responsibility for any
2 damages to either Cross-Defendant K.C. or Cross-Defendant A.H., such liability is required to be
3 reduced or eliminated by the liability of Andrade, who was responsible for any harm suffered by
4 either of them for any abuse he inflicted. Any damages for such harm should equitably be paid by
5 Andrade alone.
6 113. Accordingly, in the event of any finding of responsibility against her in this action,
7 Ms. Trevi will be entitled to a judgment of indemnity in her favor and against Andrade and Does 1
8 through 100 for all or part of such amount.
9 NINTH CAUSE OF ACTION
10 (Indemnity And Contribution Against Cross-Defendant A.H.,

18 suffered at Andrade’s hands. Ms. Trevi vigorously denies that she introduced either of them to
19 Andrade and further denies that she is responsible in any manner for any acts by Andrade that
20 caused either Cross-Defendant K.C. or Cross-Defendant A.H. any damages. Ms. Trevi further
21 denies that she owes any liability to either of them.
23 damages to Cross-Defendant K.C., such liability is required to be reduced or eliminated by the
24 liability of Cross-Defendant A.H. To the extent that anyone other than Andrade is deemed
25 responsible for abuse he caused and inflicted, Cross-Defendant A.H. must be deemed to share a
26 portion of the blame. Cross-Defendant A.H. introduced Cross-Defendant K.C. to Andrade and
27 arranged for Cross-Defendant K.C. to join the group that was subjugated by Andrade, encouraging
28 and abetting Andrade in adding Cross-Defendant K.C. to those suffering his abuse. Ms. Trevi is
24
1 also informed and believes and thereon alleges that Cross-Defendant A.H. coordinated,
2 participated, and/or otherwise assisted her husband Andrade in any acts of abuse committed against
3 Cross-Defendant K.C., including, on information and belief, via participating in sexual conduct
4 with Cross-Defendant K.C. herself. If Ms. Trevi is held liable in any amount for Cross-Defendant
5 K.C.’s alleged damages, such liability should be reduced or eliminated by Cross-Defendant A.H.’s
6 liability which should equitably be borne by Cross-Defendant A.H.
8 damages to Cross-Defendant A.H., such liability is required to be reduced or eliminated by the
9 liability of Cross-Defendant K.C. To the extent that anyone other than Andrade is deemed
10 responsible for abuse he caused and inflicted, Cross-Defendant K.C. must be deemed to share a
11 portion of the blame. Cross-Defendant K.C. introduced several underaged women to Andrade and
12 arranged for them to join the group that was subjugated by Andrade. Ms. Trevi is also informed and
13 believes and thereon alleges that Cross-Defendant K.C. coordinated, participated, and/or otherwise
14 assisted Andrade in any acts of abuse committed against Cross-Defendant A.H. Ms. Trevi is
15 informed and believes and thereon alleges that Cross-Defendant K.C. participated directly in sexual
16 conduct by Andrade involving Cross-Defendant A.H. If Ms. Trevi is held liable in any amount for
17 Cross-Defendant A.H.’s alleged damages, such liability should be reduced or eliminated by Cross-
18 Defendant K.C.’s liability which should equitably be borne by Cross-Defendant K.C.
20 Ms. Trevi will be entitled to a judgment of indemnity in her favor and against Cross-Defendants
21 A.H., K.C., and Does 1 through 100 for all or part of such amount.
22 TENTH CAUSE OF ACTION
23 (Indemnity Against Roe J.P. 1 and Does 1-100)

25
2 suffered at Andrade’s hands. Ms. Trevi vigorously denies that she introduced either of them to
3 Andrade and further denies that she is responsible in any manner for any acts by Andrade that
4 caused either Cross-Defendant K.C. or Cross-Defendant A.H. any damages. Ms. Trevi further
5 denies that she owes any liability to either of them.
7 damages to Cross-Defendant A.H., such liability is required to be reduced or eliminated by the
8 liability of Roe J.P. 1. To the extent that anyone other than Andrade is deemed responsible for
9 abuse he caused and inflicted on Cross-Defendant A.H., Roe J.P. 1 must be deemed to share a
10 portion of the blame. She was Cross-Defendant A.H.’s mother, and consented to, ratified, and
11 authorized Andrade’s sexual conduct with her minor daughter. Ms. Trevi is informed and believes
12 and thereon alleges that Roe J.P. 1 was on notice of Andrade’s conduct, but nonetheless approved
13 Cross-Defendant A.H.’s participation, including participation in California, allowing Cross-
14 Defendant A.H. to travel to California under Andrade’s supervision. Roe J.P. 1 also traveled to
15 California while Cross-Defendant A.H. was present there. Ms. Trevi is informed and believes and
16 thereon alleges that Roe J.P. 1 was on notice and believed that Andrade was engaged in sexual
17 conduct with her minor daughter in California, but nonetheless left her daughter there with Andrade
18 without taking reasonable steps as a parent to protect her. Indeed, Roe J.P. 1 ratified Andrade’s
19 past sexual conduct with her daughter, and approved such further conduct, by consenting to a
20 marriage between Cross-Defendant A.H. and Andrade while Cross-Defendants A.H. was a minor.
21 122. Ms. Trevi is informed and believes and thereon alleges that Roe J.P. 1 acted
22 negligently and/or intentionally, in allowing Cross-Defendant A.H. to marry and engage in sexual
23 conduct with Andrade. As a parent, Roe J.P. 1 had a clear duty of care to Cross-Defendant A.H.,
24 and is responsible, in part, for any harm alleged to have occurred to Cross-Defendant A.H. If Ms.
25 Trevi is held liable in any amount for Cross-Defendant A.H.’s alleged damages, such liability
26 should not be borne by Ms. Trevi alone, and should be reduced or eliminated by Roe J.P. 1’s
27 liability.
28 / / /
26
2 Ms. Trevi will be entitled to a judgment of indemnity in her favor and against Roe J.P. 1 for all or
3 part of such amount.
4 PRAYER FOR RELIEF
5 WHEREFORE, Ms. Trevi prays for judgment in her favor as follows:
6 ON THE FIRST CAUSE OF ACTION:
7 1. For compensatory damages according to proof, in an amount in excess of the
8 jurisdictional minimum of this Court;
9 2. For punitive damages;
10 ON THE SECOND CAUSE OF ACTION:


14 ON THE THIRD CAUSE OF ACTION:


18 ON THE FOURTH CAUSE OF ACTION:


22 ON THE FIFTH CAUSE OF ACTION:


26 ON THE SIXTH CAUSE OF ACTION:

27
2 ON THE SEVENTH CAUSE OF ACTION:
6 ON THE EIGHTH CAUSE OF ACTION:
7 15. For a judgment of indemnity and contribution in the event that Ms. Trevi is found
8 liable for any amount in this action, up to and including the full amount of any such liability;
9 ON THE NINTH CAUSE OF ACTION:
12 ON THE TENTH CAUSE OF ACTION:
15 ON ALL CAUSES OF ACTION:
16 18. For attorneys’ fees, to the extent permitted by law;

17 19. For costs; and
18 20. For such other and further relief as the Court deems just and proper.
19
20 DATED: December 27, 2023 BROWN RUDNICK LLP

21
22 By:
CAMILLE M. VASQUEZ
23
In Association With
24 RAYMOND L. THOMAS
RAY THOMAS, PC
25
Attorneys for Defendant
26 GLORIA DE LOS ANGELES TREVINO RUIZ
aka GLORIA TREVI
27
28
28
PROOF OF SERVICE
1
2 STATE OF CALIFORNIA,
3 COUNTY OF ORANGE
4 At the time of service, I was over 18 years of age and not a party to this action. I am
employed in the County of Orange, State of California. My business address is 2211 Michelson
5 Drive, Seventh Floor, Irvine, CA 92612.
6 On December 27, 2023, I served true copies of the following document(s) described as
DEFENDANT GLORIA TREVI’S CROSS-COMPLAINT FOR (1) SEXUAL ASSAULT;
7 (2) AIDING AND ABETTING SEXUAL ASSAULT; (3) SEXUAL BATTERY; (4) AIDING
AND ABETTING SEXUAL BATTERY; (5) BATTERY; (6) AIDING AND ABETTING
8 BATTERY; (7) INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS; (8)
NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS; AND (9) INDEMNITY on the
9 interested parties in this action as follows:
10 SEE ATTACHED SERVICE LIST

11 BY ELECTRONIC TRANSMISSION: I caused a copy of the document(s) to be sent
from One Legal’s e-service system to the persons at the e-mail addresses listed in the Service List.
12
I declare under penalty of perjury under the laws of the United States of America that the
13 foregoing is true and correct and that I am employed in the office of a member of the bar of this
Court at whose direction the service was made.
14
Executed on December 27, 2023, at Irvine, California.
15
16
17 CASEY SUDA
18
19
20
21
22
23
24
25
26
27
28
SERVICE LIST
1 JANE DOE K.C. 1, ET AL. VS GLORIA DE LOS ANGELES, ET AL
TREVINO RUIZ, ETC., ET AL.
2 CASE NO. 22GDCV01128
3
Karen Barth Menzies Attorney for Plaintiffs
4 KBM Law Corp. JANE DOE K.C. 1 and JANE DOE A.H. 2
6701 Center Drive West, Suite 1400
5 Los Angeles, CA, 90045
Telephone: (310) 363-0030
6 Facsimile: (310) 861-0168
[email protected]
7 [email protected]
8 Ari Wilkenfeld Attorneys for Plaintiffs
Laura Nagel JANE DOE K.C. 1 and JANE DOE A.H. 2
9 Caroline Whitlock
Alan Lescht and Associates, P.C.
10 1825 K Street, NW, Suite 750
Washington, DC 20006
11 Telephone: (202) 315-1736
Facsimile: (202) 463-6067
12 [email protected]
[email protected]
14 Raymond L. Thomas Attorney for Defendant
Ray Thomas, PC GLORIA DE LOS ANGELES TREVINO
15 4900-B N. 10th Street RUIZ aka GLORIA TREVI
McAllen, TX 78504
16 Telephone: (956) 632-5033
[email protected]
18 Maria Raquenel Portillo Jimenez Defendant
5008 Chesebro Road, Suite 100
19 Agoura Hills, CA 91301
Telephone: (818) 533-6571
20 Facsimile: (818) 450-0600
[email protected]
22
23
24
25
26
27
28

Gloria Trevi's Cross-Complaint (Dec. 27, 2023)

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1 BROWN RUDNICK LLP

CAMILLE M. VASQUEZ, #273377

7 BROWN RUDNICK LLP

11 Attorneys for Defendant

16 JANE DOE K.C. 1, an individual; and JANE CASE NO. 22GDCV01128

DEFENDANT GLORIA TREVI’S CROSS-COMPLAINT

6 AND RELATED CROSS-ACTION

2 Complainant” or “Ms. Trevi”), hereby alleges as follows:

15 sexual. Ms. Trevi was one of those young women.

2 he had taken on to grotesque abuse calculated to break her spirit.

13 to Andrade through his company, Cross-Defendant Conexiones Americanas S.A. de C.V.

26 5. With assistance from others, including without limitation Conexiones Americanas

16 wrongs done by Andrade.

13 principal place of business in Mexico.

17 Cross-Defendant A.H. is provisionally named herein under a pseudonym, pending a determination

23 Cross-Defendant K.C. is provisionally named herein under a pseudonym, pending a determination

2 as a plaintiff and cross-defendant under her own name.

17 omissions alleged herein.

22 consent of the remaining defendants.

23 JURISDICTION AND VENUE

26 complained of herein occurred, in part, in Los Angeles, California.

14 to his influence, manipulation, and abuse.

4 Americanas and, indirectly, to Andrade.

10 minor, replacing Mary Boquitas as his wife.

3 California, as elsewhere. By way of example, on one occasion in California, Andrade decided to

23 without limitation Conexiones Americanas and its officers and agents.

6 Andrade and in her capacity as an agent of Andrade and Conexiones Americanas.

7 FIRST CAUSE OF ACTION

8 (Sexual Assault Against Andrade)

10 though set forth in full.

21 without valid consent.

14 prevented it from becoming publicly known.

19 that Ms. Trevi is entitled to an award of exemplary damages.

22 SECOND CAUSE OF ACTION

23 (Aiding And Abetting Sexual Assault Against Conexiones Americanas,

9 without valid consent.

2 prevented it from becoming publicly known.

8 included sexual assault.

9 43. Conexiones Americanas and Cross-Defendant K.C. gave substantial assistance or

11 state of financial and other servitude, and covering up Andrade’s abuse.

13 factor in causing Ms. Trevi harm.

15 that Ms. Trevi is entitled to an award of exemplary damages.

18 THIRD CAUSE OF ACTION

19 (Sexual Battery Against Andrade)

19 servitude and submission to Andrade’s will.

27 prevented it from becoming publicly known.

5 that Ms. Trevi is entitled to an award of exemplary damages.

8 FOURTH CAUSE OF ACTION

9 (Aiding and Abetting Sexual Battery Against Conexiones Americanas,

10 Cross-Defendant K.C., and Does 1-100)

22 such harmful and/or offensive contacts.

8 servitude and submission to Andrade’s will.

16 prevented it from becoming publicly known.

19 included sexual assault.

20 65. Conexiones Americanas and Cross-Defendant K.C. gave substantial assistance or

22 state of financial and other servitude, and covering up Andrade’s abuse.

24 factor in causing Ms. Trevi harm.

2 that Ms. Trevi is entitled to an award of exemplary damages.

5 FIFTH CAUSE OF ACTION

6 (Battery Against Andrade)