The attorney summarizes the document in the following 3 sentences:
The document outlines issues with two investigations into claims of sexual harassment and a toxic work environment perpetuated by a former city manager. Both investigations were flawed as they did not interview the claimants and appeared biased. While the claims were found to have merit, the claimants faced retaliation and further trauma due to the mishandling of the investigations.
One Dream officials were sued for an alleged 3 billion peso scam involving their multi-level marketing scheme that promised high returns within a short period from investments as small as 888 pesos. Over 300 victims from different areas filed complaints with the Department of Justice, claiming they collectively lost over 12 million pesos after One Dream stopped paying out returns in July 2015 as promised. One Dream had no permit for selling investment products and its stated purpose was for trading goods, not operating an investment scheme.
Rethinking Originality in Copyright Law and Exploring the Potential for a Glo...Manoj Isuru Kotigala
This document provides an overview and analysis of originality as a requirement for copyright protection under the laws of different jurisdictions. It discusses the role of originality, the idea-expression dichotomy, and the different tests used to determine originality (e.g. skill/labour/judgment, author's own intellectual creation, minimum creativity). The document also explores the need for harmonization and possibility of a global threshold of originality, given international treaties advocating for uniformity. It analyzes challenges to adopting a single global test, such as accounting for cultural variations. The document concludes by advocating for the "author's own intellectual creation" test as the proper standard.
This document provides an overview of reputation management and social commerce. It discusses how consumers increasingly rely on online reviews when making purchase decisions. It then outlines four rules for addressing negative reviews: 1) respect the wisdom of the masses, 2) do not post fake reviews, 3) do not incentivize reviews, and 4) do not penalize negative reviews. The document also discusses related legal issues around topics like non-disparagement clauses, deceptive advertising, and the liability of review sites. It concludes with practice pointers for monitoring online content and being proactive about an individual or business's online reputation.
SM Chamber of Commerce TechTalk: 5 Rules of Reputation ManagementInternet Law Center
This document provides five rules of reputation management on the internet according to Bennet Kelley, founder of the Internet Law Center. The rules are: 1) The internet protects copyrights more than people. 2) What you don't know can hurt you so be careful about information online. 3) Be careful of cyber threats and report credible threats. 4) Think before acting to avoid negative streisand effects. 5) Address negative content through positive engagement and search engine optimization. The document also outlines Kelley's background and practice areas of internet law.
NOTARIZED MAY 10 2022 NY DMV COMMISSIONER AND REGIONAL KILLER BOYDEN GRAY US...ssuser8b1714
VERIFIED CRIMINAL COMPLAINT, ANSWER AND COUNTERCLAIM, DMV ALLEGED COMMISSIONER, MARK SCHROEDER AND REGIONAL KILLER BOYDEN GRAY, NEW ORGANIZED FRAUD HATE CRIMES, BETRAY THE CONSTITUTION, AND MURDER BY PROXY PROGRAMMINGS, USING REGIONAL KILLER BOYDEN GRAY’S ATTACHED, NAME ALIGNED REPEATED UNCONSTITUTIONAL DRIVER LICENSE SUSPENSIONS, THREATS, SCHEMES AND CRIMES. THIS IS ALSO AN ANSWER AND COUNTERCLAIM TO ADDITIONAL FRIVOLOUS AND DEADLY DMV CLAIMS, CRIMINAL SENILE POLICE WITH GUNS SET UPS, USING A REGIONAL KILLER BOYDEN GRAY, INVISIBLE AUTHORITY, UNAUTHORIZED, NO AFFIDAVIT ANYWHERE, ATTACHED, UNSIGNED, NYS COUNTERFEIT TAX WARRANT, AS AUTHORITY TO ENFORCE HIS CRIMINAL POLICE AND CIVILIAN, PLOTTED INDUCED HOSPITALIZED, PREPAID HOSPITAL KILLINGS, MURDER BY PROXY CRIMES, VIA THE CRIMINAL USE OF DMV FOR KNOWINGLY, FALSIFIED, GOOD-STANDING DRIVER LICENSE SUSPENSIONS. THIS IS REGIONAL KILLER BOYDEN GRAY’S REPLICATED ATTEMPTED MURDER BY PROXY PROGRAMMING. HE HAS BEEN PROGRAMMING THE KILLING OF HEALTHY CHILDREN AND ADULTS FOR OVER 50 YEARS WITH NO PENALTIES. PLEASE SEE THE REFERENCE SECTION. THE SYSTEM CREATED AN 80-YEAR-OLD, COVID 19 HEALTHCARE, NAME ALIGNED, SENILE, REGIONAL KILLER WHO NEEDS THE DEATH PENALTY, IN ORDER TO STOP KILLING EUGENIC PREY, HE CREATES. SEE EXHIBITS 3-8 FOR PROOF OF ANSWER, US MAIL RECEIPTS RECEIVED BY DMV AND THE RECEIPT FOR DMV EVIDENCE UPLOAD.
West Point ID Theft and FCRA Presentation updatedAdam Singer
The document discusses identity theft, specifically as it relates to members of the military. It provides statistics on identity theft complaints within the military, noting that the majority come from the Army and Navy. It also shares that the most common types of identity theft reported by the military involve government documents/benefits fraud and credit card fraud. The document then gives an overview of steps someone can take if they believe they are a victim of identity theft, such as placing fraud alerts on credit reports and disputing unauthorized charges or accounts.
One Dream officials were sued for an alleged 3 billion peso scam involving their multi-level marketing scheme that promised high returns within a short period from investments as small as 888 pesos. Over 300 victims from different areas filed complaints with the Department of Justice, claiming they collectively lost over 12 million pesos after One Dream stopped paying out returns in July 2015 as promised. One Dream had no permit for selling investment products and its stated purpose was for trading goods, not operating an investment scheme.
Rethinking Originality in Copyright Law and Exploring the Potential for a Glo...Manoj Isuru Kotigala
This document provides an overview and analysis of originality as a requirement for copyright protection under the laws of different jurisdictions. It discusses the role of originality, the idea-expression dichotomy, and the different tests used to determine originality (e.g. skill/labour/judgment, author's own intellectual creation, minimum creativity). The document also explores the need for harmonization and possibility of a global threshold of originality, given international treaties advocating for uniformity. It analyzes challenges to adopting a single global test, such as accounting for cultural variations. The document concludes by advocating for the "author's own intellectual creation" test as the proper standard.
This document provides an overview of reputation management and social commerce. It discusses how consumers increasingly rely on online reviews when making purchase decisions. It then outlines four rules for addressing negative reviews: 1) respect the wisdom of the masses, 2) do not post fake reviews, 3) do not incentivize reviews, and 4) do not penalize negative reviews. The document also discusses related legal issues around topics like non-disparagement clauses, deceptive advertising, and the liability of review sites. It concludes with practice pointers for monitoring online content and being proactive about an individual or business's online reputation.
SM Chamber of Commerce TechTalk: 5 Rules of Reputation ManagementInternet Law Center
This document provides five rules of reputation management on the internet according to Bennet Kelley, founder of the Internet Law Center. The rules are: 1) The internet protects copyrights more than people. 2) What you don't know can hurt you so be careful about information online. 3) Be careful of cyber threats and report credible threats. 4) Think before acting to avoid negative streisand effects. 5) Address negative content through positive engagement and search engine optimization. The document also outlines Kelley's background and practice areas of internet law.
NOTARIZED MAY 10 2022 NY DMV COMMISSIONER AND REGIONAL KILLER BOYDEN GRAY US...ssuser8b1714
VERIFIED CRIMINAL COMPLAINT, ANSWER AND COUNTERCLAIM, DMV ALLEGED COMMISSIONER, MARK SCHROEDER AND REGIONAL KILLER BOYDEN GRAY, NEW ORGANIZED FRAUD HATE CRIMES, BETRAY THE CONSTITUTION, AND MURDER BY PROXY PROGRAMMINGS, USING REGIONAL KILLER BOYDEN GRAY’S ATTACHED, NAME ALIGNED REPEATED UNCONSTITUTIONAL DRIVER LICENSE SUSPENSIONS, THREATS, SCHEMES AND CRIMES. THIS IS ALSO AN ANSWER AND COUNTERCLAIM TO ADDITIONAL FRIVOLOUS AND DEADLY DMV CLAIMS, CRIMINAL SENILE POLICE WITH GUNS SET UPS, USING A REGIONAL KILLER BOYDEN GRAY, INVISIBLE AUTHORITY, UNAUTHORIZED, NO AFFIDAVIT ANYWHERE, ATTACHED, UNSIGNED, NYS COUNTERFEIT TAX WARRANT, AS AUTHORITY TO ENFORCE HIS CRIMINAL POLICE AND CIVILIAN, PLOTTED INDUCED HOSPITALIZED, PREPAID HOSPITAL KILLINGS, MURDER BY PROXY CRIMES, VIA THE CRIMINAL USE OF DMV FOR KNOWINGLY, FALSIFIED, GOOD-STANDING DRIVER LICENSE SUSPENSIONS. THIS IS REGIONAL KILLER BOYDEN GRAY’S REPLICATED ATTEMPTED MURDER BY PROXY PROGRAMMING. HE HAS BEEN PROGRAMMING THE KILLING OF HEALTHY CHILDREN AND ADULTS FOR OVER 50 YEARS WITH NO PENALTIES. PLEASE SEE THE REFERENCE SECTION. THE SYSTEM CREATED AN 80-YEAR-OLD, COVID 19 HEALTHCARE, NAME ALIGNED, SENILE, REGIONAL KILLER WHO NEEDS THE DEATH PENALTY, IN ORDER TO STOP KILLING EUGENIC PREY, HE CREATES. SEE EXHIBITS 3-8 FOR PROOF OF ANSWER, US MAIL RECEIPTS RECEIVED BY DMV AND THE RECEIPT FOR DMV EVIDENCE UPLOAD.
West Point ID Theft and FCRA Presentation updatedAdam Singer
The document discusses identity theft, specifically as it relates to members of the military. It provides statistics on identity theft complaints within the military, noting that the majority come from the Army and Navy. It also shares that the most common types of identity theft reported by the military involve government documents/benefits fraud and credit card fraud. The document then gives an overview of steps someone can take if they believe they are a victim of identity theft, such as placing fraud alerts on credit reports and disputing unauthorized charges or accounts.
Scott Moulton scanning case RE: U.S.D.C. Georgia NMAPDavid Sweigert
This summary provides the essential information from the legal document in 3 sentences:
This order addresses cross motions for summary judgment in a civil case involving claims of defamation, tortious interference with business relations, and violations of consumer protection statutes between two competing computer network companies. The plaintiffs performed security tests on the defendant's computer network without authorization, leading the defendant to make statements to clients alleging security issues, which resulted in the termination of the plaintiff's contract. The court grants summary judgment for both parties, finding that the statements made were opinions and not factual assertions that could be proven false, and therefore not actionable as defamation or unfair trade practices.
This amicus brief argues that the district court erred in granting summary judgment finding the City of New York intentionally discriminated against black and Hispanic applicants for firefighter positions. The brief asserts that the City presented evidence that it conducted proper job analyses, developed valid, race-neutral exams that were job-related in compliance with EEOC guidelines, undertook extensive efforts to recruit minority candidates, and made hiring decisions in a race-blind manner. Given this evidence creating factual issues, the brief argues summary judgment was inappropriate and the finding of intentional discrimination is unsupported and should be reversed. The brief also argues the remedial measures imposed exceeded the district court's authority and that reassignment to a new judge is warranted.
The document provides five rules for online reputation management: 1) monitor mentions of yourself and your business online; 2) social commerce reviews matter for business; 3) address negative reviews but consider the "wisdom of the masses"; 4) avoid overreactions that draw more attention under the Streisand effect; and 5) be aware of potential cyber threats and report credible threats. It also discusses related legal issues like consumer gag agreements, copyright protections for negative reviews, and what constitutes an "internet lawyer".
CASE BRIEF 7.2 Tiffany and Company v. Andrew 2012 W.docxcowinhelen
CASE BRIEF 7.2
Tiffany and Company v. Andrew
2012 WL 5451259 (S.D.N.Y.)
FACTS: Tiffany (plaintiffs) allege that Andrew and others (defendants) sold counterfeit Tiffany
products through several websites hosted in the United States. Andrew accepted payment in U.S.
dollars, used PayPal, Inc. to process customers' credit card transactions, then transferred the sales
proceeds to accounts held by the Bank of China (“BOC”), Industrial and Commercial Bank of
China (“ICBC”), and China Merchants Bank (“CMB”) (“Banks”).
Andrew defaulted on the suit, and Tiffany sought discovery from the Banks by serving subpoenas
seeking the identities of the holders of the accounts into which the proceeds of the counterfeit sales
were transferred and the subsequent disposition of those proceeds. The Banks involved all
maintained branch offices in the Southern District of New York, and the subpoenas were served
on those branch offices.
The Banks responded to the subpoenas by explaining that the information sought was all
maintained in China and that the New York branches of the Banks lacked the ability to access the
requested information. China's internal laws prohibited the disclosure of the information except
under certain conditions. The Banks proposed that the plaintiffs pursue the requested discovery
pursuant to the Hague Convention.
The court concluded that Tiffany should pursue discovery through the Hague Convention. Tiffany
submitted its Hague Convention application to China's Central Authority in November 2010, and
on August 7, 2011, the Ministry of Justice of the People's Republic of China (“MOJ”) responded
by producing some of the documents requested. For each of the Banks, the MOJ produced account
opening documents (including the government identification card of the account holder), written
confirmation of certain transfers into the accounts and a list of transfers out of the accounts. With
respect to CMB, the records indicate that all funds in the account were withdrawn through cash
transactions at either an ATM or through a teller. BOC and CMB each produced documents
concerning a single account; ICBC produced documents for three accounts.
In its cover letter, the MOJ noted that it was not producing all documents requested. Specifically,
the letter stated, “Concerning your request for taking of evidence for the Tiffany case, the Chinese
competent authority holds that some evidence required lacks direct and close connections with the
litigation. As the Chinese government has declared at its accession to the Hague Evidence
Convention that for the request issued for the purpose of the pre-trial discovery of documents only
the request for obtaining discovery of the documents clearly enumerated in the Letters of Request
and of direct and close connection with the subject matter of the litigation will be executed, the
Chinese competent authority has partly executed the requests which it d.
This document discusses privacy issues and data breaches involving personal information. It summarizes several incidents where large corporations and universities mishandled or lost private records of millions of individuals. It argues that companies prioritize profits over privacy, routinely sharing data without permission. It criticizes media for blaming hackers instead of these companies. The author believes more must be done to hold accountable those who compromise privacy and demand legislative reform to better protect individuals' information and privacy.
The 9th Circuit Court declares that the Newport Beach ordinance targeted rehab and sober living centers, and violated federal and state laws that protect the rights of people with disabilities.
1. The document summarizes Ron Korkut's experience as a whistleblower who attempted to expose corruption and was punished by his employer and union for doing so.
2. After being in a hit and run accident, he tried to sue ICBC and bring them to justice for insuring criminally negligent drivers. He was declared a vexatious litigant by a chief justice and denied access to legal services.
3. He was then fired from his job at BCIT for informing coworkers about corruption in the courts. Despite paying union dues, his union mishandled his grievance and refused to properly investigate his claims.
This document discusses various options consumers have for complaining or seeking assistance when they have issues with companies or products. It describes government agencies like the Federal Trade Commission and Consumer Product Safety Commission that handle complaints, though their resources have been reduced. It also discusses nonprofit groups like the Better Business Bureau, local consumer protection offices, and some for-profit websites that will advocate on a consumer's behalf in exchange for fees. The document provides advice on the best routes to take depending on the nature of the complaint and potential limitations different organizations face due to budget cuts.
Sample complaint for rescission of contract in CaliforniaLegalDocsPro
This sample complaint for rescission of contract in California also contains causes of action for fraud, reformation of contract, usury violations, unfair business practices, cancellation of written instruments, declaratory relief, injunctive relief and an account. The sample complaint was used to sue an individual private lender that defrauded an individual and used undue influence to convince them to sign an amended promissory note with an usurious annual interest rate of 18%, and then started non-judicial foreclosure proceedings by claiming an inflated amount due on the notice of default. The sample complaint on which this preview is based is 16 pages and includes brief instructions and a sample verification. The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.
My Day in Court will come. The US Attorney’s Office Has Given Itself a Head S...jamesservices
The document summarizes Tiffany Brown's perspective on the charges against her related to her efforts to help Puerto Rico recover from Hurricane Maria. She states that through no fault of potential jurors, they have been subjected to a persuasion campaign against her by prosecutors undermining due process. She maintains her innocence and looks forward to calling witnesses at trial to demonstrate she acted in good faith. However, she expresses concern that pretrial publicity prejudices the jury pool and amounts to prosecutorial misconduct.
This new publication, Cyber Claims Insight from Aon Benfield’s Cyber Practice Group, empowers readers with the resources and tools they need to understand the cyber landscape, including legal trends, claims and insurance coverage disputes.
This newsletter from the DC Police Union provides updates on several initiatives and issues. It discusses efforts to engage with the community through a crime statistics website and helping underprivileged youth. It also outlines issues around the 97.5% no confidence vote in the police chief, including her dismantling of drug squads and misleading statements. Finally, it provides updates on arbitration proceedings regarding compensation and announces a dues increase to support the legal budget.
Request for Settlement for stalking by Court of MilwaukeeAurorasa Coaching
The black "gang stalker" community, is responsible for estimated 300-400 murders every month. This doesn't factor in forced suicides, and missing people who are not yet declared "dead."
That is because their identities, assets, accounts get stolen, and signal to data brokers that the person is still active/alive.
Request for Settlement for Stalking Circuit Court MilwaukeeAurorasa Coaching
This letter is a formal demand for a $125,000 settlement from the Circuit Court of Milwaukee County regarding alleged stalking and harassment. The letter alleges the Court's involvement in a "mass-murdering black community" referred to as "gang stalkers" along with many other companies and individuals. It also alleges the Court misrepresented employees, accepted fake cases, held hearings with impersonators, and subjected the author to a fraudulent hearing. The letter demands payment by June 15th to avoid a lawsuit and criminal case.
This document is a memorandum submitted to the Gaston County Clerk of Superior Court regarding a public records lawsuit filed by Dan Deitz and Ellen Deitz Tucker against the City of Belmont and its City Manager. The memorandum provides background on the lawsuit, which seeks access to an investigative report into the Belmont Police Department that was compiled by a private firm, ISS Agency. The memorandum argues that the ISS report is not a confidential personnel record exempt from disclosure under the public records law, and requests that the court declare the report a public record subject to disclosure in its entirety or require Defendants to produce public portions of the report.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated August 13, 2014Jason Coombs
The document is a letter from the CEO of Public Startup Company to the SEC criticizing a group of 9 Senators who urged the SEC to withdraw its proposed preemption of state securities regulation for Regulation A+ offerings under Title IV of the JOBS Act. The CEO argues the Senators failed to provide reasonable justification and made factually incorrect claims. The CEO asserts full federal preemption is necessary for the SEC to properly implement Title IV and that states would still be able to prosecute fraud even without prohibitions on unregistered securities. The CEO believes the Senators are harming small businesses and job creation with their opposition to preemption.
RFP for Reno's Community Assistance CenterThis Is Reno
Property appraisals completed in May for downtown Reno’s Community Assistance and Triage Centers (CAC) reveal that repairing the buildings to bring them back into service would cost an estimated $10.1 million—nearly four times the amount previously reported by city staff.
Sparks Fire Dept. investigative report into Timothy Egan dropping a senior ci...This Is Reno
This report by Christopher Darcy of the Fairfax Consulting Group found Sparks Firefighter Timothy Egan instigated an altercation with a senior citizen, lied about it and violated department policies and state laws. Egan claimed he was attacked by Maureen Hvegholm, then 84, in December of 2022 when Hvegholm was feeding cats in an alleyway in Sparks, Nevada.
“Egan was responsible for creating the physical altercation between himself and Hvegholm,” Darcy wrote. “Egan initiated contact by approaching Hvegholm, attempting to take and throw away items she believed were hers. Egan used what officers described as disproportional force by throwing Hvegholm to the ground, causing her to land face first and injuring her forehead.”
Reno Council Member's Petition lawsuit against the City of RenoThis Is Reno
Reno City Council member Jenny Brekhus last month sued the city after a 2,000-page report was released that implicated her as a toxic force at City Hall. Brekhus requested an investigation into the city, particularly City Manager Doug Thornley and the allegations she made against him.
However, the investigator instead determined that Brekhus was the source of hostility, and the investigator could not substantiate her allegations.
“The greater weight of the credible evidence indicates that Councilmember Brekhus has a habit of speaking to individuals in a manner that demeans and belittles them,” Dalton Green, with the Ogletree Deakins law firm, wrote. “In a passive aggressive manner, she calls their competence and, often, their integrity, into question – frequently in the presence of others – such that many are afraid to deal with her.”
In response to the report, Brekhus sued the city in December.
More Related Content
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Scott Moulton scanning case RE: U.S.D.C. Georgia NMAPDavid Sweigert
This summary provides the essential information from the legal document in 3 sentences:
This order addresses cross motions for summary judgment in a civil case involving claims of defamation, tortious interference with business relations, and violations of consumer protection statutes between two competing computer network companies. The plaintiffs performed security tests on the defendant's computer network without authorization, leading the defendant to make statements to clients alleging security issues, which resulted in the termination of the plaintiff's contract. The court grants summary judgment for both parties, finding that the statements made were opinions and not factual assertions that could be proven false, and therefore not actionable as defamation or unfair trade practices.
This amicus brief argues that the district court erred in granting summary judgment finding the City of New York intentionally discriminated against black and Hispanic applicants for firefighter positions. The brief asserts that the City presented evidence that it conducted proper job analyses, developed valid, race-neutral exams that were job-related in compliance with EEOC guidelines, undertook extensive efforts to recruit minority candidates, and made hiring decisions in a race-blind manner. Given this evidence creating factual issues, the brief argues summary judgment was inappropriate and the finding of intentional discrimination is unsupported and should be reversed. The brief also argues the remedial measures imposed exceeded the district court's authority and that reassignment to a new judge is warranted.
The document provides five rules for online reputation management: 1) monitor mentions of yourself and your business online; 2) social commerce reviews matter for business; 3) address negative reviews but consider the "wisdom of the masses"; 4) avoid overreactions that draw more attention under the Streisand effect; and 5) be aware of potential cyber threats and report credible threats. It also discusses related legal issues like consumer gag agreements, copyright protections for negative reviews, and what constitutes an "internet lawyer".
CASE BRIEF 7.2 Tiffany and Company v. Andrew 2012 W.docxcowinhelen
CASE BRIEF 7.2
Tiffany and Company v. Andrew
2012 WL 5451259 (S.D.N.Y.)
FACTS: Tiffany (plaintiffs) allege that Andrew and others (defendants) sold counterfeit Tiffany
products through several websites hosted in the United States. Andrew accepted payment in U.S.
dollars, used PayPal, Inc. to process customers' credit card transactions, then transferred the sales
proceeds to accounts held by the Bank of China (“BOC”), Industrial and Commercial Bank of
China (“ICBC”), and China Merchants Bank (“CMB”) (“Banks”).
Andrew defaulted on the suit, and Tiffany sought discovery from the Banks by serving subpoenas
seeking the identities of the holders of the accounts into which the proceeds of the counterfeit sales
were transferred and the subsequent disposition of those proceeds. The Banks involved all
maintained branch offices in the Southern District of New York, and the subpoenas were served
on those branch offices.
The Banks responded to the subpoenas by explaining that the information sought was all
maintained in China and that the New York branches of the Banks lacked the ability to access the
requested information. China's internal laws prohibited the disclosure of the information except
under certain conditions. The Banks proposed that the plaintiffs pursue the requested discovery
pursuant to the Hague Convention.
The court concluded that Tiffany should pursue discovery through the Hague Convention. Tiffany
submitted its Hague Convention application to China's Central Authority in November 2010, and
on August 7, 2011, the Ministry of Justice of the People's Republic of China (“MOJ”) responded
by producing some of the documents requested. For each of the Banks, the MOJ produced account
opening documents (including the government identification card of the account holder), written
confirmation of certain transfers into the accounts and a list of transfers out of the accounts. With
respect to CMB, the records indicate that all funds in the account were withdrawn through cash
transactions at either an ATM or through a teller. BOC and CMB each produced documents
concerning a single account; ICBC produced documents for three accounts.
In its cover letter, the MOJ noted that it was not producing all documents requested. Specifically,
the letter stated, “Concerning your request for taking of evidence for the Tiffany case, the Chinese
competent authority holds that some evidence required lacks direct and close connections with the
litigation. As the Chinese government has declared at its accession to the Hague Evidence
Convention that for the request issued for the purpose of the pre-trial discovery of documents only
the request for obtaining discovery of the documents clearly enumerated in the Letters of Request
and of direct and close connection with the subject matter of the litigation will be executed, the
Chinese competent authority has partly executed the requests which it d.
This document discusses privacy issues and data breaches involving personal information. It summarizes several incidents where large corporations and universities mishandled or lost private records of millions of individuals. It argues that companies prioritize profits over privacy, routinely sharing data without permission. It criticizes media for blaming hackers instead of these companies. The author believes more must be done to hold accountable those who compromise privacy and demand legislative reform to better protect individuals' information and privacy.
The 9th Circuit Court declares that the Newport Beach ordinance targeted rehab and sober living centers, and violated federal and state laws that protect the rights of people with disabilities.
1. The document summarizes Ron Korkut's experience as a whistleblower who attempted to expose corruption and was punished by his employer and union for doing so.
2. After being in a hit and run accident, he tried to sue ICBC and bring them to justice for insuring criminally negligent drivers. He was declared a vexatious litigant by a chief justice and denied access to legal services.
3. He was then fired from his job at BCIT for informing coworkers about corruption in the courts. Despite paying union dues, his union mishandled his grievance and refused to properly investigate his claims.
This document discusses various options consumers have for complaining or seeking assistance when they have issues with companies or products. It describes government agencies like the Federal Trade Commission and Consumer Product Safety Commission that handle complaints, though their resources have been reduced. It also discusses nonprofit groups like the Better Business Bureau, local consumer protection offices, and some for-profit websites that will advocate on a consumer's behalf in exchange for fees. The document provides advice on the best routes to take depending on the nature of the complaint and potential limitations different organizations face due to budget cuts.
Sample complaint for rescission of contract in CaliforniaLegalDocsPro
This sample complaint for rescission of contract in California also contains causes of action for fraud, reformation of contract, usury violations, unfair business practices, cancellation of written instruments, declaratory relief, injunctive relief and an account. The sample complaint was used to sue an individual private lender that defrauded an individual and used undue influence to convince them to sign an amended promissory note with an usurious annual interest rate of 18%, and then started non-judicial foreclosure proceedings by claiming an inflated amount due on the notice of default. The sample complaint on which this preview is based is 16 pages and includes brief instructions and a sample verification. The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017 and has created over 300 sample legal documents for sale. Note that the author is NOT an attorney and no guarantee or warranty is provided.
My Day in Court will come. The US Attorney’s Office Has Given Itself a Head S...jamesservices
The document summarizes Tiffany Brown's perspective on the charges against her related to her efforts to help Puerto Rico recover from Hurricane Maria. She states that through no fault of potential jurors, they have been subjected to a persuasion campaign against her by prosecutors undermining due process. She maintains her innocence and looks forward to calling witnesses at trial to demonstrate she acted in good faith. However, she expresses concern that pretrial publicity prejudices the jury pool and amounts to prosecutorial misconduct.
This new publication, Cyber Claims Insight from Aon Benfield’s Cyber Practice Group, empowers readers with the resources and tools they need to understand the cyber landscape, including legal trends, claims and insurance coverage disputes.
This newsletter from the DC Police Union provides updates on several initiatives and issues. It discusses efforts to engage with the community through a crime statistics website and helping underprivileged youth. It also outlines issues around the 97.5% no confidence vote in the police chief, including her dismantling of drug squads and misleading statements. Finally, it provides updates on arbitration proceedings regarding compensation and announces a dues increase to support the legal budget.
Request for Settlement for stalking by Court of MilwaukeeAurorasa Coaching
The black "gang stalker" community, is responsible for estimated 300-400 murders every month. This doesn't factor in forced suicides, and missing people who are not yet declared "dead."
That is because their identities, assets, accounts get stolen, and signal to data brokers that the person is still active/alive.
Request for Settlement for Stalking Circuit Court MilwaukeeAurorasa Coaching
This letter is a formal demand for a $125,000 settlement from the Circuit Court of Milwaukee County regarding alleged stalking and harassment. The letter alleges the Court's involvement in a "mass-murdering black community" referred to as "gang stalkers" along with many other companies and individuals. It also alleges the Court misrepresented employees, accepted fake cases, held hearings with impersonators, and subjected the author to a fraudulent hearing. The letter demands payment by June 15th to avoid a lawsuit and criminal case.
This document is a memorandum submitted to the Gaston County Clerk of Superior Court regarding a public records lawsuit filed by Dan Deitz and Ellen Deitz Tucker against the City of Belmont and its City Manager. The memorandum provides background on the lawsuit, which seeks access to an investigative report into the Belmont Police Department that was compiled by a private firm, ISS Agency. The memorandum argues that the ISS report is not a confidential personnel record exempt from disclosure under the public records law, and requests that the court declare the report a public record subject to disclosure in its entirety or require Defendants to produce public portions of the report.
JOBS Act Rulemaking Comments on SEC File Number S7-11-13 Dated August 13, 2014Jason Coombs
The document is a letter from the CEO of Public Startup Company to the SEC criticizing a group of 9 Senators who urged the SEC to withdraw its proposed preemption of state securities regulation for Regulation A+ offerings under Title IV of the JOBS Act. The CEO argues the Senators failed to provide reasonable justification and made factually incorrect claims. The CEO asserts full federal preemption is necessary for the SEC to properly implement Title IV and that states would still be able to prosecute fraud even without prohibitions on unregistered securities. The CEO believes the Senators are harming small businesses and job creation with their opposition to preemption.
Similar to Mark Mausert Rebuttal to City of Reno Investigations (18)
RFP for Reno's Community Assistance CenterThis Is Reno
Property appraisals completed in May for downtown Reno’s Community Assistance and Triage Centers (CAC) reveal that repairing the buildings to bring them back into service would cost an estimated $10.1 million—nearly four times the amount previously reported by city staff.
Sparks Fire Dept. investigative report into Timothy Egan dropping a senior ci...This Is Reno
This report by Christopher Darcy of the Fairfax Consulting Group found Sparks Firefighter Timothy Egan instigated an altercation with a senior citizen, lied about it and violated department policies and state laws. Egan claimed he was attacked by Maureen Hvegholm, then 84, in December of 2022 when Hvegholm was feeding cats in an alleyway in Sparks, Nevada.
“Egan was responsible for creating the physical altercation between himself and Hvegholm,” Darcy wrote. “Egan initiated contact by approaching Hvegholm, attempting to take and throw away items she believed were hers. Egan used what officers described as disproportional force by throwing Hvegholm to the ground, causing her to land face first and injuring her forehead.”
Reno Council Member's Petition lawsuit against the City of RenoThis Is Reno
Reno City Council member Jenny Brekhus last month sued the city after a 2,000-page report was released that implicated her as a toxic force at City Hall. Brekhus requested an investigation into the city, particularly City Manager Doug Thornley and the allegations she made against him.
However, the investigator instead determined that Brekhus was the source of hostility, and the investigator could not substantiate her allegations.
“The greater weight of the credible evidence indicates that Councilmember Brekhus has a habit of speaking to individuals in a manner that demeans and belittles them,” Dalton Green, with the Ogletree Deakins law firm, wrote. “In a passive aggressive manner, she calls their competence and, often, their integrity, into question – frequently in the presence of others – such that many are afraid to deal with her.”
In response to the report, Brekhus sued the city in December.
Washoe County Commissioner Jeanne Herman floats new resolution to overhaul el...This Is Reno
Washoe County Commissioner Jeanne Herman renewed her efforts to change how elections are run in Washoe County this week. According to Washoe County spokesperson Bethany Drysdale, her proposal is also impossible to implement and potentially illegal. The proposal has yet to be reviewed by Washoe County’s District Attorney or the Secretary of State’s office.
Sheriff’s deputy, county investigator sue Reno Police Department, former chiefThis Is Reno
A Washoe County Sheriff’s deputy and an investigator with the district attorney’s office last week filed a civil rights lawsuit against the Reno Police Department and former Police Chief Jason Soto. Also named in the litigation is a retired RPD Sergeant, Paul Sifre, who is alleged to have sexually harassed the two plaintiffs.
Apryl McElroy, a detective with the Washoe County Sheriff’s Office, and Jessica Troup, an investigator with the Washoe County District Attorney’s office (previously with University Police Services), both allege Sifre made sexually explicit comments to them while at a conference in Las Vegas. Rather than addressing the issue—and what they called longstanding problematic behavior by Sifre—the plaintiffs allege he received a lucrative disability retirement instead.
City of Reno Placemaking Phase I presentationThis Is Reno
The document provides an update on Phase One of the Virginia Street Placemaking Study Implementation Plan in Reno, Nevada. Phase One will include a Façade and Tenant Improvement Program, improvements to the Streetscape Furnishing Zone, upgrades to Locomotion Plaza 2.0, and the development of a new ROW Plaza. The Reno City Council is requested to approve the next steps and authorize a $365,000 agreement with an urban design consultant to assist with planning and design of the streetscape, plaza, and ROW projects.
Dennis Carry Affidavit in Support of Warrant This Is Reno
Former Washoe County Sheriff’s Sergeant Dennis Carry is facing seven felony charges, including bigamy – being married to two different people at the same time.
Carry is also accused of burglary, forgery, surreptitious intrusion of privacy, giving false evidence and perjury.
The case goes back to 2019 when Reno police started investigating Carry. He is alleged to have broken into the Washoe County courthouse to modify married records in an attempt to cover up his dual marriages.
The Reno Police Department and City of Reno said this document is 100% confidential, and Washoe County District Court Judge Kathleen Drakulich agreed, even though This Is Reno obtained the unreacted affidavit from Reno Justice Court. The Nevada Supreme Court June 2023 ordered Drakulich to reconsider her decision.
Reno Council member Devon Reese's ethics violationsThis Is Reno
Reno City Council member Devon Reese must comply with a handful of orders handed down by the Nevada Ethics Commission this month after cause was found in a complaint filed last year alleging he violated a handful of state ethics laws.
The complaint, filed in September 2022, alleges Reese did not disclose business relationships with several employee union groups, and he did not recuse himself from contract negotiations with those groups or votes to approve those contracts.
Reese works as an attorney for the Hutchison and Steffen law firm.
The commission’s review panel determined that two of the five violations noted in the complaint were valid.
As a result, Reese has to participate in ethics training, develop a process to disclose and abstain from council activities related to his office’s clients, and submit Reno City Council meeting minutes referencing issues or clients related to the law firm for the next two years.
If Reese doesn’t meet these requirements, or has another ethics violation within the next two years, the commission will repeal the deferral agreement and may pursue additional action.
Vegas physician, America's Frontline Doctors sued after Reno man died from ta...This Is Reno
The estate of Jeremy Parker last week sued the anti-vaccination, right-wing group America's Frontline Doctors for alleged wrongful death. Dr. Medina Culver, an osteopathic physician and Instagram influencer based in Henderson, Nevada, is also named in the case. The lawsuit alleges negligence by the group and Culver for the death of Parker last year.
"Based on information provided by America's Frontline Doctors, Mr. Parker became convinced, along with several of his co-workers, that hydroxychloroquine was an effective treatment for COVID-19," the suit alleges. "On or about August 26, 2021, Mr. Parker had a telemedicine visit with Dr. Culver, at which time Dr. Culver prescribed Mr. Parker with hydroxychloroquine and/or ivermectin for COVID-19 treatment or 'preventative therapy.' Dr. Culver never performed a physical examination of Mr. Parker."
According to the suit, Parker developed cold-like symptoms in late January of 2022. His body was found Feb. 3, 2022. The Washoe County coroner listed Parker's cause of death as "sudden in the setting of therapeutic use of hydroxychloroquine."
City of Reno Police Chief Community SurveyThis Is Reno
Low staffing levels and political agendas are two problems within the Reno Police Department. That’s according to concerns identified by community members and RPD employees in two recent surveys conducted as part of a search for the department’s new chief.
The surveys were developed and analyzed by Ralph Andersen, an executive search firm tasked with helping to replace Chief Jason Soto, who is set to retire in January 2023.
The internal department survey included responses from 128 of RPD’s staff – officers, command staff and civilians. It revealed that employees have mixed feelings about the department, with some citing low morale, burnout and staffing shortages.
Viral video of Reno-area Sikhs partying with sex workers in Costa Rica subjec...This Is Reno
Multiple phones were recording video of members of Reno’s Sikh community frolicking in May with sex workers in Costa Rica. But only one person is being sued for sharing video of plaintiffs Ranbir Chhina, Navdeep Singh, Kewal Singh, Opinder Dhillon and Amandeep Singh engaging in “adult entertainment.”
Nic Palmer of the Laub & Laub law firm recently filed a lawsuit against Parminder Walia for sharing videos of the group partying with prostitutes in the Central American country. The plaintiffs are claiming an intrusion of privacy.
“The Plaintiffs are business owners and belong to the Sikh Community, which is a conservative religion,” Palmer wrote. “The Plaintiff [sic] have suffered social and financial consequences due to the Defendants actions of posting the videos online.”
One of the plaintiffs, Kewal Singh Sekhon, was president of Reno’s Sikh Temple. Another was a member, according to a court document in the case that cited an article by Rajan Zed in 2012 published on This Is Reno.
“I sent the videos to the group of ten Sikhs to show that American Sikhs, despite the conservative values of Sikhism, know how to party and have a good time,” Walia said in a sworn statement filed in Washoe County’s Second Judicial District Court.
This Is Reno’s second public records lawsuit against the City of Reno and Ren...This Is Reno
Petitioner Robert Conrad, who operates the news website ThisIsReno.com, has filed a petition for a writ of mandamus against the City of Reno regarding numerous public records requests. The petition alleges that the City has improperly withheld, redacted, and delayed the disclosure of requested records on various police matters. It also claims the City has improperly closed some requests and demanded payment for records not listed in its fee schedule. The petition seeks an order requiring the City to comply with the Nevada Public Records Act and provide timely access to public records.
Joey Gilbert threatens youth soccer league, gets savage responseThis Is Reno
Nevada Governor candidate and far-right conspiracy theorist Joey Gilbert last year threatened to sue the Great Basin Youth Soccer League in an 11-page letter. He demanded the league fire volunteers, accused the league of unlawful behavior by enforcing state mask mandates and said the league violating the Nuremberg Code of Ethics by alleging it was conducting research involving human subjects. The page-and-a-half response, by the League's attorney, Theodore Chrissinger, is savage. "Your letter does not identify your client," Chrissinger wrote. "Your letter does not identify any breach of contract, tort, crime, or other actionable conduct. I am uncertain why you refer to Dr. Mengele, the Nuremberg Code, or medical 'experimentation.' GBYSL has not mandated any medical experimentation." The threat went nowhere.
The document discusses the history of chocolate, describing how it originated from cacao beans grown by the Olmecs and Mayans in Mexico and Central America. It then explains how Spanish conquistadors brought cacao beans back to Europe in the 16th century, where it eventually became popular as a drink among the elite. Over time, chocolate became widely consumed in powder and solid forms across Europe and North America.
Reno Police Audit 2021 (draft version)This Is Reno
The document is a draft report from the Center for Public Safety Management analyzing police operations and data for the Reno Police Department. It provides an overview of the department's organization, staffing, call volume and response times. It examines each division and section, identifying current activities, staffing, workload and recommendations for improvements. Key recommendations include increasing staffing for patrol, investigations and dispatch to meet service demands.
Court awards attorney fees to This Is Reno in public records lawsuit against ...This Is Reno
Washoe County District Court Judge Kathleen Drakulich this week awarded costs and attorney fees to This Is Reno in its public records lawsuit against the Reno Police Department.
Last year, This Is Reno sued RPD for failing to follow Nevada public records laws. Drakulich partially agreed. She said RPD failed to respond to a number of This Is Reno’s public records orders within the time frame required by law – up to seven months in one case.
Drakulich, however, said RPD properly denied the release of documents relevant to open investigations. She also said RPD can continue to redact officer faces from body worn cameras, a practice This Is Reno attempted to challenge.
Body cam redaction policies are inconsistently applied in Nevada. Most other states in the country do not redact officer faces, a point the Reno city attorney said was irrelevant.
In Nevada, some law enforcement entities are redacting officer faces from videos. That includes the back of officer heads, in RPD’s case.
The reason for the redactions, according to the Reno city attorney: The law prohibits the release of an officer’s photograph to the public unless the officer gives permission for the release.
Former employee fires back after being sued by Community Health AllianceThis Is Reno
James Fleming, who is being sued by his former employer, Community Health Alliance, fired back at the health nonprofit in court filings last week.
He denies wrongdoing and accuses CHA of interfering with the federal investigation into Fleming’s allegations that CHA committed fraud.
Fleming responded to the complaint Feb. 4 after CHA applied for a temporary protective order seeking to prevent Fleming from talking about CHA negatively.
CHA also filed an amended complaint that removed most mentions of Reno City Council member, also CHA’s CEO, Oscar Delgado.
Community Health Alliance's amended lawsuit against its former employeeThis Is Reno
James Fleming, who is being sued by his former employer, the Community Health Alliance fired back at the health nonprofit in court filings last week.
He denies wrongdoing and accuses CHA of interfering with the federal investigation into Fleming’s allegations that CHA committed fraud.
Fleming filed a response to CHA's complaint Feb. 4 after CHA applied for a temporary protective order seeking to prevent Fleming from talking about CHA negatively. CHA also filed an amended complaint that removed most mentions of Reno city council member, also CHA’s CEO, Oscar Delago.
Community Health Alliance in Reno sues former employee (original complaint)This Is Reno
Community Health Alliance executives filed a lawsuit last week in district court demanding a former employee stop speaking negatively of the non-profit health provider. CHA also filed a temporary protective order against the employee to prevent him from divulging what they said is confidential information.
Jim Fleming, the employee, said he is preparing to fight the claims and has received assistance from the ACLU of Nevada.
Fleming, CHA’s former statistician, has publicly alleged CHA CEO Oscar Delgado, also a Reno City Council member, was knowledgeable about and allowed fraud and the misuse of grant funds.
Fleming posts detailed allegations against CHA and its executives on Facebook, LinkedIn and his Medium account.
“Data show that Community Health Alliance severely underperformed in its contractual duties relative to the funds it received from the state of Nevada,” Fleming recently wrote on Facebook. “Even worse, in an attempt to demonstrate costs that would justify continued state contracts at their current levels, CHA deliberately falsified employment records. These employee records were used to bolster the full-time equivalent (FTE) tally, and therefore the costs, that were dedicated to the program in 2020.”
The U.S. Department of Health and Human Services Office of Inspector General is investigating Fleming’s claim he filed last year. He filed the complaint with the federal agency saying he was fired by CHA in retaliation after he raised concerns about the nonprofit’s practices.
Jennifer Schaus and Associates hosts a complimentary webinar series on The FAR in 2024. Join the webinars on Wednesdays and Fridays at noon, eastern.
Recordings are on YouTube and the company website.
https://www.youtube.com/@jenniferschaus/videos
Food safety, prepare for the unexpected - So what can be done in order to be ready to address food safety, food Consumers, food producers and manufacturers, food transporters, food businesses, food retailers can ...
UN WOD 2024 will take us on a journey of discovery through the ocean's vastness, tapping into the wisdom and expertise of global policy-makers, scientists, managers, thought leaders, and artists to awaken new depths of understanding, compassion, collaboration and commitment for the ocean and all it sustains. The program will expand our perspectives and appreciation for our blue planet, build new foundations for our relationship to the ocean, and ignite a wave of action toward necessary change.
This report explores the significance of border towns and spaces for strengthening responses to young people on the move. In particular it explores the linkages of young people to local service centres with the aim of further developing service, protection, and support strategies for migrant children in border areas across the region. The report is based on a small-scale fieldwork study in the border towns of Chipata and Katete in Zambia conducted in July 2023. Border towns and spaces provide a rich source of information about issues related to the informal or irregular movement of young people across borders, including smuggling and trafficking. They can help build a picture of the nature and scope of the type of movement young migrants undertake and also the forms of protection available to them. Border towns and spaces also provide a lens through which we can better understand the vulnerabilities of young people on the move and, critically, the strategies they use to navigate challenges and access support.
The findings in this report highlight some of the key factors shaping the experiences and vulnerabilities of young people on the move – particularly their proximity to border spaces and how this affects the risks that they face. The report describes strategies that young people on the move employ to remain below the radar of visibility to state and non-state actors due to fear of arrest, detention, and deportation while also trying to keep themselves safe and access support in border towns. These strategies of (in)visibility provide a way to protect themselves yet at the same time also heighten some of the risks young people face as their vulnerabilities are not always recognised by those who could offer support.
In this report we show that the realities and challenges of life and migration in this region and in Zambia need to be better understood for support to be strengthened and tuned to meet the specific needs of young people on the move. This includes understanding the role of state and non-state stakeholders, the impact of laws and policies and, critically, the experiences of the young people themselves. We provide recommendations for immediate action, recommendations for programming to support young people on the move in the two towns that would reduce risk for young people in this area, and recommendations for longer term policy advocacy.
United Nations World Oceans Day 2024; June 8th " Awaken new dephts".Christina Parmionova
The program will expand our perspectives and appreciation for our blue planet, build new foundations for our relationship to the ocean, and ignite a wave of action toward necessary change.
Jennifer Schaus and Associates hosts a complimentary webinar series on The FAR in 2024. Join the webinars on Wednesdays and Fridays at noon, eastern.
Recordings are on YouTube and the company website.
https://www.youtube.com/@jenniferschaus/videos
Mark Mausert Rebuttal to City of Reno Investigations
1. NEWS RELEASE
Mark Mausert
930 Evans Ave
Reno, NV 89512
775.786.5477
mark@markmausertlaw.com
FOR IMMEDIATE RELEASE
Exorbitantly expensive cover-up further traumatizes claimants,
who potentially saved the City millions
Mark Mausert, attorney for claimants, official statement:
“The Reports found the original claims meritorious and outlined the toxic environment,
notwithstanding the failure to interview my clients. Both investigations have cost the City
taxpayers an exorbitant amount of money and neither were effective due to their incomplete
and biased nature. Insufficient evidence, as found by Judge Wall, did NOT exonerate Clinger
of sexual harassment. To the contrary, Judge Wall documented extraordinary misconduct.”
Reno, Nevada (January 11, 2017) – Pursuant to the right of fair reply, recognized by the Nevada Rules of
Professional Conduct, I am replying to the release of the heavily redacted reports by the City of Reno. The public
deserves to have a thorough understanding of the allegations against former City Manager Andrew Clinger, and the
manner in which the work environment was polluted, and remains polluted. The missteps have and will continue to
financially burden the Reno taxpayers. The original claims were reported by three highly accomplished, professional
and intelligent women with the intent to protect the City and expose cronyism, misconduct, and unethical behaviors
involving Clinger. These employees had an obligation to report.
This is not the first time Clinger has been accused of sexual misconduct. In 2011, the City Council hired Clinger, who
was the former state budget director under Governor Jim Gibbons. Clinger was hired notwithstanding the fact his
conduct prompted an employee to accuse him of retaliating against her, after she complained of his alleged
improper, sexually-oriented conduct on State premises. This accusation was not a consideration in either of the City
of Reno’s Reports. The allegations against Clinger, based on his conduct while a State employee, should have been
thoroughly investigated.
City Attorney Karl Hall appears to have trivialized the complaints. Quotes like, “it is a witch hunt of disgruntled
employees” and “it was only a touching of a leg,” demonstrate bias. The bias likely explains the restrictions Hall
allegedly placed on the first and second investigations. That is, Hall appears to have compromised the independence
of both Ms. Mercado and Judge Wall. Hall was recorded saying he deliberately did not tell the City Council of the
complaints, even though City policy requires the immediate supervisor be notified. The City’s refusal to interview the
claimants resulted in a biased and inconclusive second Report at significantly higher expense, while increasing the
City’s liability. The first Report was biased and inconclusive courtesy of a deliberate refusal to investigate the bulk of
the complaints, i.e., those sounding in ostracism and other forms of retaliatory hostility. My clients were repeatedly
told those allegations were “beyond the scope” of the inquiry. The botched first investigation necessitated a second,
which was attended by the same problems. At every turn, the City Attorney has undertaken ill-informed actions which
served to morph what should have been internal complaints into much more formal allegations, which will necessitate
litigation. This approach has traumatized my clients. They still have a hard time believing they have been forced into
an adversarial relationship with a City they love.
Although Clinger denies disseminating the “Hot Crazy Matrix” video to his executive staff, he did not intervene to cure
its dissemination, despite its highly inappropriate nature. Instead, Clinger is accused of borrowing language from the
video and referring to Jane Doe as his “Unicorn” – a sexualized and misogynistic reference to a women who is
2. attractive and only somewhat crazy. Judge Wall contends this had no negative effect on City staff, but the claimants
viewed this as a clear example of the sexualized culture Clinger created. Clearly, they were adversely affected and
offended.
Clinger admits he instructed members of his executive staff to use applications which exploded, or destroyed
encrypted text messages. Clinger sought to excuse this extraordinary behavior with a telling admission. He claims he
did not cause the apps to be installed to facilitate sexual messages, but rather to defeat public records requests so
you, the public, would not know what he was doing. This is no better a rationale. Not only does this subvert public
records requests, it constituted an unethical, unprofessional and very dangerous approach to record-keeping – the
antithesis of what a City Manager should do. This systemic spoliation of evidence could cost the city millions in other
lawsuits. It still may. The claimants contend the real reason is Clinger wished to destroy sexual messages. Clinger’s
excuse, at least insofar as the City’s financial exposure is concerned, is worse than the scenario posited by my
clients. Any skilled lawyer involved in litigation against the City may seize on this deliberate spoliation of evidence
and use it as a basis for sanctions against the City, e.g., a directed verdict which could cost the City millions.
Clinger’s conduct is probative of a marked propensity for outright dishonesty, the type of dishonesty which the law
punishes harshly.
Clinger’s retaliatory behavior and statements such as, “payback is a bitch,” “I will find out who they are and I will fire
them,” and “they are liars,” evidence a retaliatory mindset. These outrageous statements are probative of a fear-
based culture. The results from the annual all city employee survey demonstrate a majority of the employees did not
trust the City Manager and the Assistant City Managers. The findings of consultant Dave Childs’ focus groups of
almost 80 employees evidence widespread fear, intimidation, dysfunction, cronyism, and favoritism. These results
corroborate the women’s allegations, but were excluded from both investigations.
The City did not require Clinger to take administrative leave until he voluntarily left weeks into the first investigation.
Judge Wall’s report concludes “Hall couldn’t recall if he told Clinger the names of the complainants, but believes he
might have done so to warn Clinger not to retaliate against them.” The claimants were forced to continue working
under Clinger during the very time he was caustically threatening revenge, placing the City even more at risk for
litigation. Most of the claims of retaliatory hostility, reported by the claimants as early as July 12, have not been
investigated in spite of the City knowing the specifics and having a legal obligation to do so. The inference is
disturbing. The City Attorney may have failed to interview my clients, not because of a legitimate evidentiary concern
as to how the interviews would be used, but because the City Attorney believed the allegations to be accurate and
did not want a thorough investigation. No doubt Mr. Hall will deny, but the inference will remain.
Judge Wall noted he could not make contextual conclusions without interviewing the claimants. Nonetheless, he did
draw conclusions favorable to Clinger with insufficient evidence. Insufficient evidence is not the same as innocence
or exoneration, and $225,000 is a steep price for an investigation. Further, Clinger succeeded in distracting Judge
Wall with a conspiracy theory that turned the investigation into a question of motives rather than merit. This may have
been an effort by Clinger to distract from his behavior and invalidate the claimants’ allegations. In doing so, Clinger
appears to have co-opted the City’s investigation for the purpose of “payback.” Clinger’s admissions regarding
routine and calculated destruction of evidence are incriminatory and mutually exclusive to exoneration.
The claimants followed and trusted the City’s process—twice. My clients lodged complaints not for personal gain, or
with an eye to becoming litigants. They complained because they wished to protect their City from misconduct. If they
had not been possessed of the courage to come forward, the problems created by Mr. Clinger, and some of those
closely associated with him, would have continued to fester. My clients thought they would be protected if they
complained. The Mayor demanded any and all harassment or inappropriate behaviors be reported and expressly told
my clients they would be protected. My clients believed, and still believe, this assurance was provided in good faith.
They complied and were rewarded with disregard for City policy, breached confidentiality, retaliation, and two heavily
flawed investigations.
3. The second report found the original claims meritorious and outlined the toxic environment my clients experienced, in
spite of my clients not being interviewed. Both investigations have cost the City taxpayers an exorbitant amount of
money and neither was effective due to their incomplete and biased nature. The claimants were treated like
criminals, forcing them to seek outside legal representation, not for financial gain, but rather for protection against a
rigged system.
My clients courageously opposed unethical, actionable, and very dangerous conduct. As a direct result, the practice
of routinely destroying evidence was curtailed. My clients probably saved Reno tens of millions of dollars. My clients
stopped what was arguably a conspiracy – which would have resulted in one Court after another imposing sanctions
on the City. Instead of extending thanks and a “job well done”, the City allowed Clinger to vilify my clients, botched
two investigations, questioned their motives, and indulged in speculation as to whether they are part of a conspiracy
– after paying Clinger almost a quarter of a million dollars on his way out.
If the City Attorney cannot muster the good grace to say “thanks”, you should. This community owes these
courageous and talented women a deep debt of gratitude.
To provide context to the information above a detailed letter addressing points at length is attached.
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