Ramon Ontiveros Medina's Complaint Affidavit for the State of Texas v. Samuel Martínez Roque, Case No. 20250C06999

COMPLAINT AFFIDAVIT
EL PASO COUNTY, TEXAS
THE STATE OF TEXAS
COUNTY OF EL PASO

COURT NO. 2
Filing Agency: El Paso Police Department
Offense Report #: 25-044174
Date of offense: 10/10/2024–02/13/2025
Time of offense: 1134 and 1600 hours
DEFENDANT Name: MARTINEZ ROQUE, SAMUEL EDUARDO
DEFENDANT date of birth: [REDACTED]
Offense: Harassment
Offense Code# 13160012

The undersigned affiant, being employed by the El Paso Police Department, (the “department”), El Paso, Texas, as a peace officer, and being duly sworn, on oath makes the following statements and accusations, to the best knowledge and belief of the department on the date of the forgoing supplement report, (“the report”).


1. It is the belief of the affiant, and affiant hereby charges and accuses, that the subject named in the report, MARTINEZ ROQUE, SAMUEL EDUARDO committed the offense Harassment, named in the report. The report was compiled from the department’s investigation of charged offense.

Sec. 42.07. HARASSMENT
(a) A person commits an offense if, with intent to harass, annoy, alarm, abuse, torment, or embarrass another, the person:
(7) sends repeated electronic communications in a manner reasonably likely to harass, annoy, alarm, abuse, torment, embarrass, or offend another.

2. Affiant has probable cause for the said beliefs stated herein by reason of the following facts, to wit:

P/C:
Detective J. Sanchez #1967 was assigned this case for investigation from the address of 441 Huerta St. The El Paso Police Report was completed and documented on 02-13-2025.

Detective Sanchez made contact with the Complaining Witness (Ramon Ontiveros) and obtained a written sworn statement. C/W stated he is the owner of Floor KO LLC and the DEFENDANT is an ex-employee who he terminated from employment a few days before the incidents began.

C/W advised the DEFENDANT worked as a sales representative for the company in 2022. C/W stated he began noticing problems with the DEFENDANT’s job performance and the DEFENDANT began appearing paranoid.

C/W reported that the DEFENDANT began telling him that he was “being watched and spied on” by unknown people, then accusing the C/W of being responsible for doing this. C/W advised he tried working things out with the DEFENDANT but this continued and the C/W had to let the DEFENDANT go from the job. The C/W stated that after he was terminated, the DEFENDANT posted in a “WhatsApp” post requesting the C/W provide a confession admitting he (C/W) was responsible for “spying” on him so that the DEFENDANT could apply for a visa to show he was the victim of a crime and be able to stay in the United States. C/W advised the DEFENDANT that he would not confess to anything he did not do.

C/W advised that was when the DEFENDANT began a social media rant against him. C/W posted on several social media platforms, using internet names, defaming the C/W and his business. C/W advised it effected his business as messages had been sent directly to his clients, causing his clients to stop doing business with the C/W and other clients questioning the legitimacy of the posts that were posted on social media. In one instance, the DEFENDANT posted that the C/W was responsible for human trafficking which caused a visit to the residence of the C/W by HSI agents.

C/W has provided copies of the posts and other information indicating that the DEFENDANT has threatened to cause harm to the C/W or his family members and the DEFENDANT has continued to send out social media posts defaming the business and his name. C/W feels threatened and harassed by the DEFENDANT and advised prosecution was desired.

Detective Sanchez attached the provided messages and documents provided by the C/W to this report and also submitted in to evidence copied in to a DVD-r.

3. Affiant has read the foregoing and knows that it is true and correct to the best of my knowledge.

This offense occurred in the County of El Paso, Texas against the peace and dignity of the State.

[Affiant signature]

Sworn to and subscribed before me, on this the 20th day of Oct, 2025.

[Notary signature and stamp]

Jennifer Irene Escobedo
NOTARY PUBLIC
In and for the State of Texas
My commission expires 07-29-2029

Magistrate
El Paso County, Texas
[EOB]