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."
This Is Reno’s second public records lawsuit against the City of Reno and Ren...This Is Reno
This Is Reno is suing the city of Reno and Reno Police Department for failing to follow the Nevada Public Records Act. The suit alleges continued violations of state records law, including failing to follow mandated deadlines and not providing reasonable estimates as to when records will be made public. Examples include the city closing records requests without ever providing records and making requesters wait more than a year for records, including body cam footage. It’s the second lawsuit filed by the news media outlet against the city.
Traci Davis Lawsuit Against Washoe County School District Filed in District C...This Is Reno
The promised lawsuit by past Superintendent Traci Davis against the Washoe County School District was filed today in district court. Attorney Bill Peterson filed the suit on Davis' behalf. The suit alleges misconduct by school board trustees and school district administrators.
Lawsuit against WCSD alleges breach of contract, lying to courtThis Is Reno
The Washoe County School District was hit again with another lawsuit from a former employee. The suit, filed Friday, alleges that the District’s attorney lied to a judge and violated the Nevada Public Records Act. It also claims that administrators conspired to oust former Superintendent Traci Davis and fired an administrator in violation of a settlement agreement.
This Is Reno’s second public records lawsuit against the City of Reno and Ren...This Is Reno
This Is Reno is suing the city of Reno and Reno Police Department for failing to follow the Nevada Public Records Act. The suit alleges continued violations of state records law, including failing to follow mandated deadlines and not providing reasonable estimates as to when records will be made public. Examples include the city closing records requests without ever providing records and making requesters wait more than a year for records, including body cam footage. It’s the second lawsuit filed by the news media outlet against the city.
Traci Davis Lawsuit Against Washoe County School District Filed in District C...This Is Reno
The promised lawsuit by past Superintendent Traci Davis against the Washoe County School District was filed today in district court. Attorney Bill Peterson filed the suit on Davis' behalf. The suit alleges misconduct by school board trustees and school district administrators.
Lawsuit against WCSD alleges breach of contract, lying to courtThis Is Reno
The Washoe County School District was hit again with another lawsuit from a former employee. The suit, filed Friday, alleges that the District’s attorney lied to a judge and violated the Nevada Public Records Act. It also claims that administrators conspired to oust former Superintendent Traci Davis and fired an administrator in violation of a settlement agreement.
Sample California motion to compel further responses to special interrogatoriesLegalDocsPro
This sample California motion to compel further responses to special interrogatories is made pursuant to Code of Civil Procedure Section 2030.300 and is used when a party has served special interrogatories but the responses received are evasive or incomplete, or the objections are without merit or are too general. The sample could easily be modified to apply to form interrogatories as well. The sample on which this preview is based is 30 pages and includes a memorandum of points and authorities with citations to case law and statutory authority, a separate statement as required by Rule of Court 3.1345, a sample declaration and a proof of service by mail.
Sample trial brief for California civil caseLegalDocsPro
This sample trial brief for a California civil case is used by a party in a California litigation case. The sample can be modified and used in most California litigation cases, it also includes a memorandum of points and authorities with citiations to case law and statutory authority and a proof of service by mail. This is a preview of the sample sold by LegalDocsPro.
Sample motion to vacate judgment under Rule 60(b)(3) in United States Distric...LegalDocsPro
This sample motion to vacate a judgment in United States District Court is filed pursuant to Federal Rule of Civil Procedure 60(b)(3) on the grounds of fraud, misrepresentation, or other misconduct of an adverse party which prevented the moving party from fairly presenting their case. The sample on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail. The author is a freelance paralegal who has worked in California and Federal litigation since 1995.
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.
Sample motion to vacate default under Rule 55(c) in United States District CourtLegalDocsPro
This sample motion to vacate a default under Rule 55(c) in United States District Court is used when a default has been entered but no judgment. The sample motion is used by a defendant to request that the Court vacate an entry of default against them for good cause. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and freelance 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.
Sample California motion for change of venue LegalDocsPro
This sample motion for change of venue for California is used when a defendant wants the Court to transfer the venue to their county of residence. The sample contains a memorandum of points and authorities with citations to case law and statutory authority. This is a preview of the sample motion sold by LegalDocsPro.
Sample trial exhibit list for CaliforniaLegalDocsPro
This sample trial exhibit list for California is used when a party wishes to list all of the exhibits that they plan to use at the trial of this action.
Sample demand for physical examination in californiaLegalDocsPro
This sample demand for physical examination in California is used by a defendant that has been sued by a plaintiff in a personal injury case. The demand is served under the provisions of Code of Civil Procedure section 2032.220. The sample contains brief instructions and can be easily modified. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample motion to dismiss adversary complaint under rule12(b)(6)LegalDocsPro
This sample motion to dismiss an adversary complaint for fraud is made under Rule 12(b)(6) on the grounds that the complaint does not state a claim for relief, in the alternative the motion also requests a more definite statement. The sample contains a memorandum of points and authorities with citations to case law and statutory authority. This is a preview of the sample motion sold by LegalDocsPro.
Sample California meet and confer letter LegalDocsPro
This sample meet and confer letter for California is used when a party has not received any responses to their discovery requests and wants to meet and confer with the other party before filing any motion to compel. The sample can be modified for use in many situations.
Sample motion to dismiss for improper venue under Rule 12(b)(3)LegalDocsPro
This sample motion to dismiss for improper venue under Rule 12(b)(3) in United States District Court contends that the complaint should be dismissed for improper venue as the Defendant is not a resident of, and does not conduct business in, the judicial district, and therefore venue is improper. The sample motion on which this preview is based is 9 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 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.
Motion to Disqualify Judge Christopher M. KeatingRich Bergeron
Judge Christopher Meade Keating is a big fan of lawyers. He used to be one of the most powerful lawyers in the state. He bamboozled the judicial selection officials by pretending to be all about integrity. He's shown nothing but a willingness to ignore multiple examples of dishonesty employed by attorneys in my probate case. This motion seeks to stop him before he does any more damage. Listen to the last hearing in this case here: https://www.dropbox.com/s/rt75a50qjknummt/Laconia_CC_CR2_20221227-1040_01d919dfa50722d0%5B1%5D.mp3?dl=0
Sample California motion to compel further responses to special interrogatoriesLegalDocsPro
This sample California motion to compel further responses to special interrogatories is made pursuant to Code of Civil Procedure Section 2030.300 and is used when a party has served special interrogatories but the responses received are evasive or incomplete, or the objections are without merit or are too general. The sample could easily be modified to apply to form interrogatories as well. The sample on which this preview is based is 30 pages and includes a memorandum of points and authorities with citations to case law and statutory authority, a separate statement as required by Rule of Court 3.1345, a sample declaration and a proof of service by mail.
Sample trial brief for California civil caseLegalDocsPro
This sample trial brief for a California civil case is used by a party in a California litigation case. The sample can be modified and used in most California litigation cases, it also includes a memorandum of points and authorities with citiations to case law and statutory authority and a proof of service by mail. This is a preview of the sample sold by LegalDocsPro.
Sample motion to vacate judgment under Rule 60(b)(3) in United States Distric...LegalDocsPro
This sample motion to vacate a judgment in United States District Court is filed pursuant to Federal Rule of Civil Procedure 60(b)(3) on the grounds of fraud, misrepresentation, or other misconduct of an adverse party which prevented the moving party from fairly presenting their case. The sample on which this preview is based is 11 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service by mail. The author is a freelance paralegal who has worked in California and Federal litigation since 1995.
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.
Sample motion to vacate default under Rule 55(c) in United States District CourtLegalDocsPro
This sample motion to vacate a default under Rule 55(c) in United States District Court is used when a default has been entered but no judgment. The sample motion is used by a defendant to request that the Court vacate an entry of default against them for good cause. The sample on which this preview is based is 10 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and freelance 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.
Sample California motion for change of venue LegalDocsPro
This sample motion for change of venue for California is used when a defendant wants the Court to transfer the venue to their county of residence. The sample contains a memorandum of points and authorities with citations to case law and statutory authority. This is a preview of the sample motion sold by LegalDocsPro.
Sample trial exhibit list for CaliforniaLegalDocsPro
This sample trial exhibit list for California is used when a party wishes to list all of the exhibits that they plan to use at the trial of this action.
Sample demand for physical examination in californiaLegalDocsPro
This sample demand for physical examination in California is used by a defendant that has been sued by a plaintiff in a personal injury case. The demand is served under the provisions of Code of Civil Procedure section 2032.220. The sample contains brief instructions and can be easily modified. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995. Note that the author is NOT an attorney and no guarantee or warranty is provided.
Sample motion to dismiss adversary complaint under rule12(b)(6)LegalDocsPro
This sample motion to dismiss an adversary complaint for fraud is made under Rule 12(b)(6) on the grounds that the complaint does not state a claim for relief, in the alternative the motion also requests a more definite statement. The sample contains a memorandum of points and authorities with citations to case law and statutory authority. This is a preview of the sample motion sold by LegalDocsPro.
Sample California meet and confer letter LegalDocsPro
This sample meet and confer letter for California is used when a party has not received any responses to their discovery requests and wants to meet and confer with the other party before filing any motion to compel. The sample can be modified for use in many situations.
Sample motion to dismiss for improper venue under Rule 12(b)(3)LegalDocsPro
This sample motion to dismiss for improper venue under Rule 12(b)(3) in United States District Court contends that the complaint should be dismissed for improper venue as the Defendant is not a resident of, and does not conduct business in, the judicial district, and therefore venue is improper. The sample motion on which this preview is based is 9 pages and includes brief instructions, a memorandum of points and authorities with citations to case law and statutory authority, sample declaration and proof of service. The author is an entrepreneur and freelance paralegal that has worked in California and Federal litigation since 1995 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.
Motion to Disqualify Judge Christopher M. KeatingRich Bergeron
Judge Christopher Meade Keating is a big fan of lawyers. He used to be one of the most powerful lawyers in the state. He bamboozled the judicial selection officials by pretending to be all about integrity. He's shown nothing but a willingness to ignore multiple examples of dishonesty employed by attorneys in my probate case. This motion seeks to stop him before he does any more damage. Listen to the last hearing in this case here: https://www.dropbox.com/s/rt75a50qjknummt/Laconia_CC_CR2_20221227-1040_01d919dfa50722d0%5B1%5D.mp3?dl=0
Temuryan et al vs jensen, wead, Cosway 2ACArmen Temurian
Armen Temuryan sues Glen Jensen, Brent Jensen, Douglas Wead, Cosway, et al. for Breech of Contract, etc.
Read All About It Before You Join an MLM with these people Involved. The Truth does set you free. It IS Knowledge which will help you make correct decisions and eliminate Loss, Hurt and protect those you will be responsible for bringing into engagement after you are recruited into the next MLM business with these characters I am suing. INTEGRITY is always doing what is right even if you had to forfeit millions. Never Compromise. Never. Never fear you will incur loss if you are always Integral. It Always happens, What you will Deposit in the North, you will ALWAYS withdraw in the South. This is Integrity. Your name will always remain GOLD. More valuable then then most valuable commodity - money, is TRUST.
Armen Temuryan
Stephen Slevin vs. Board of County Commissioners - Lawsuit Against Jail for M...Umesh Heendeniya
Stephen Slevin (59) left in solitary confinement (by jail director Chris Barela and former medical director Dr. Daniel Zemek) in the Dona Ana County, New Mexico jail for 2 years gets $15.5 million lawsuit settlement.
The tax payers are on the hook for $9.5 million while the county's liability insurance carriers will pay $6 million.
Defendant Erin Foster's answer to Plaintiff Bret Wade's complaint in 1:17-cv-01371-GLR in the U.S. District Court for the District of Maryland, filed on June 20, 2017.
Similar to Vegas physician, America's Frontline Doctors sued after Reno man died from taking hydroxychloroquine (20)
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.
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.
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.
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.
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.
Civil rights lawsuit filed against Truckee Meadows Community CollegeThis Is Reno
The attempt to fire longtime college math professor Lars Jensen by Truckee Meadows Community College administrators failed last year. This week, Jensen filed a lawsuit against five TMCC administrators and Nevada System of Higher Education Chancellor Melody Rose.
Prior to filing the lawsuit, and after a committee of TMCC employees recommended President Karin Hilgersom not fire him, Jensen’s attempt at a mediation was rebuffed, he said in December.
“After having agreed to mediation on Dec 9 on my EEOC complaint against TMCC for retaliation and discrimination, TMCC has suddenly cancelled mediation and declined to reschedule before the mediation deadline on Jan 31,” he told This Is Reno last month.
An email from the U.S. Equal Employment Opportunity Commission shows TMCC “decided not to participate in a mediation session before 31 January 2022,” a federal mediator wrote. Jensen filed the EEOC complaint in August, and said the federal agency scheduled a mediation session for Dec. 9, 2021.
“I received an email from the employer stating that it was cancelling the mediation session, scheduled for Thursday 9 December 2021,” the mediator wrote. “This is very unfortunate; particularly because this charge has been at the Alternative Dispute Resolution Unit since 30 August 2021, and I am only able to retain it until 31 January 2022.”
Jensen, in December, said litigation was the next step. Three attorneys representing him filed the lawsuit this week on his behalf.
He has been supported by free-speech and professors’ rights organizations, which have issued statements protesting his treatment at TMCC.
Gunderson law firm's independent invegestigation: Washoe County School DistrictThis Is Reno
A copy of the investigation looking into who knew about former School Board Trustee Jacqueline Calvert's residency change prior to her resignation from the Washoe County School Board.
The American Association of University Professors, Nevada Faculty Alliance (NFA), the Academic Freedom Alliance and Foundation for Individual Rights in Education each issued letters of concern over the move by Truckee Meadow Community College administrators to fire math Professor Lars Jensen.
More than 10 faculty from each Nevada System of Higher Education institution wrote the NFA letter.
“His termination would be a violation of his academic freedom and his rights as an academic faculty member and would constitute a travesty of justice,” the faculty members wrote. “In addition, it would very likely lead to successful litigation against TMCC.
“The State Board of the Nevada Faculty Alliance has previously criticized the TMCC administration for a campus climate of retribution and fear,” they added. “The contrived termination case against Professor Jensen, who is passionate about his students and about upholding academic standards, is another and extreme example of retaliation against an outspoken faculty member.”
In 2020, the Ministry of Home Affairs established a committee led by Prof. (Dr.) Ranbir Singh, former Vice Chancellor of National Law University (NLU), Delhi. This committee was tasked with reviewing the three codes of criminal law. The primary objective of the committee was to propose comprehensive reforms to the country’s criminal laws in a manner that is both principled and effective.
The committee’s focus was on ensuring the safety and security of individuals, communities, and the nation as a whole. Throughout its deliberations, the committee aimed to uphold constitutional values such as justice, dignity, and the intrinsic value of each individual. Their goal was to recommend amendments to the criminal laws that align with these values and priorities.
Subsequently, in February, the committee successfully submitted its recommendations regarding amendments to the criminal law. These recommendations are intended to serve as a foundation for enhancing the current legal framework, promoting safety and security, and upholding the constitutional principles of justice, dignity, and the inherent worth of every individual.
Matthew Professional CV experienced Government LiaisonMattGardner52
As an experienced Government Liaison, I have demonstrated expertise in Corporate Governance. My skill set includes senior-level management in Contract Management, Legal Support, and Diplomatic Relations. I have also gained proficiency as a Corporate Liaison, utilizing my strong background in accounting, finance, and legal, with a Bachelor's degree (B.A.) from California State University. My Administrative Skills further strengthen my ability to contribute to the growth and success of any organization.
Guide on the use of Artificial Intelligence-based tools by lawyers and law fi...Massimo Talia
This guide aims to provide information on how lawyers will be able to use the opportunities provided by AI tools and how such tools could help the business processes of small firms. Its objective is to provide lawyers with some background to understand what they can and cannot realistically expect from these products. This guide aims to give a reference point for small law practices in the EU
against which they can evaluate those classes of AI applications that are probably the most relevant for them.
Lifting the Corporate Veil. Power Point Presentationseri bangash
"Lifting the Corporate Veil" is a legal concept that refers to the judicial act of disregarding the separate legal personality of a corporation or limited liability company (LLC). Normally, a corporation is considered a legal entity separate from its shareholders or members, meaning that the personal assets of shareholders or members are protected from the liabilities of the corporation. However, there are certain situations where courts may decide to "pierce" or "lift" the corporate veil, holding shareholders or members personally liable for the debts or actions of the corporation.
Here are some common scenarios in which courts might lift the corporate veil:
Fraud or Illegality: If shareholders or members use the corporate structure to perpetrate fraud, evade legal obligations, or engage in illegal activities, courts may disregard the corporate entity and hold those individuals personally liable.
Undercapitalization: If a corporation is formed with insufficient capital to conduct its intended business and meet its foreseeable liabilities, and this lack of capitalization results in harm to creditors or other parties, courts may lift the corporate veil to hold shareholders or members liable.
Failure to Observe Corporate Formalities: Corporations and LLCs are required to observe certain formalities, such as holding regular meetings, maintaining separate financial records, and avoiding commingling of personal and corporate assets. If these formalities are not observed and the corporate structure is used as a mere façade, courts may disregard the corporate entity.
Alter Ego: If there is such a unity of interest and ownership between the corporation and its shareholders or members that the separate personalities of the corporation and the individuals no longer exist, courts may treat the corporation as the alter ego of its owners and hold them personally liable.
Group Enterprises: In some cases, where multiple corporations are closely related or form part of a single economic unit, courts may pierce the corporate veil to achieve equity, particularly if one corporation's actions harm creditors or other stakeholders and the corporate structure is being used to shield culpable parties from liability.
Synopsis On Annual General Meeting/Extra Ordinary General Meeting With Ordinary And Special Businesses And Ordinary And Special Resolutions with Companies (Postal Ballot) Regulations, 2018
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Vegas physician, America's Frontline Doctors sued after Reno man died from taking hydroxychloroquine
1. LUKE A. BUSBY, ESQ.
SBN 10319
316 California Ave.
Reno, Nevada 89509
775-453-0112
luke@lukeandrewbusbyltd.com
Attorney for the Plaintiffs
IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA,
IN AND FOR THE COUNTY OF WASHOE
* * *
ESTATE OF JEREMY PARKER, by and through
its Special Administrator JELENA HATFIELD,
JELENA HATFIELD, individually; TP, a minor, by
and through her parent and natural guardian
JELENA HATFIELD; GP, a minor, by and through
his parent and natural guardian JELENA
HATFIELD, and LP, a minor, by and through his
parent and natural guardian JELENA HATFIELD,
v.
MEDINA CULVER, D.O, individually, FREE
SPEECH FOUNDATION, INC. D/B/A/
AMERICA’S FRONTLINE DOCTORS, a foreign
nonprofit corporation, DOES I through X,
inclusive; and ROE CORPORATIONS I through
X, inclusive,
__________________________________________/
CASE NO:
DEPT NO:
Arbitration Exemption:
Medical Malpractice;
NAR 3(A) acton in
excess of $50,000
COMPLAINT
COME NOW, ESTATE OF JEREMY PARKER, by and through its Special
Administrator JELENA HATFIELD, JELENA HATFIELD, individually, TP, a minor, by
and through her parent and natural guardian JELENA HATFIELD; GP, a minor, by
and through his parent and natural guardian JELENA HATFIELD, LP, a minor, by and
through his parent and natural guardian JELENA HATFIELD (the “Plaintiffs”) by and
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F I L E D
Electronically
CV23-00219
2023-02-03 11:41:35 AM
Alicia L. Lerud
Clerk of the Court
Transaction # 9491383 : yviloria
2. through the undersigned counsel, and hereby brings this action against MEDINA
CULVER, D.O., FREE SPEECH FOUNDATION, INC. D/B/A/ AMERICA’S FRONTLINE
DOCTORS, a foreign nonprofit corporation, DOE individuals 1-10 (inclusive), and
ROE corporations 1-10 (inclusive) (hereinafter, jointly and severally, also referred to
as, “Defendants” for damages to and for wrongful death resulting from the ingestion
of improperly prescribed hydroxychloroquine.
JURISDICTION
1. This Court has jurisdiction over this matter pursuant to Nev. Const. art.
VI, § 6, as this Court has original jurisdiction in all cases not assigned to the justices’
courts. This Court has subject matter jurisdiction over this matter pursuant to NRS
4.370, as the matter in controversy exceeds $15,000, exclusive of attorney’s fees,
interest, and costs.
2. This action is instituted for damages, attorneys’ fees, costs of suit and
pre-judgment interest pursuant to NRS 41.085 and 41.100.
3. Venue is properly in the above-captioned Court because: (a) the
Plaintiffs are located in and the Defendants do business in Washoe County; (b) the
transactions related to the same occurred in Washoe County; (c) the events and
omissions giving rise to the claims for relief detailed herein below occurred in
Washoe County; (d) it has personal jurisdiction over the Plaintiffs in this action; and
(e) it has personal jurisdiction over the Defendants.
PARTIES
4. That at all times relevant hereto decedent Jeremy Parker was a resident
of Washoe County, Nevada.
5. That at all times mentioned herein, Plaintiff Jelena Hatfield was and is a
resident of Washoe County, Nevada, and the wife of decedent Jeremy Parker.
Jelena is the Special Administrator of the Estate of Jeremy Parker pursuant to an
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3. Order Appointing Special Administrator issued by this Court in Docket No.
PR23-00071 on February 3, 2023.
6. TP, a minor aged 17, by and through her parent and natural guardian
JELENA HATFIELD was and is a resident of Washoe County, Nevada, and the
daughter of decedent Jeremy Parker.
7. GP, a minor aged 14, by and through his parent and natural guardian
JELENA HATFIELD was and is a resident of Washoe County, Nevada, and the son
of decedent Jeremy Parker.
8. LP, a minor aged 8, by and through his parent and natural guardian
JELENA HATFIELD was and is a resident of Washoe County, Nevada, and the son
of decedent Jeremy Parker.
9. That Plaintiffs are informed and believe and thereupon allege that at all
times mentioned herein, MEDINA CULVER, D.O. (hereinafter “Dr. Culver”), is a
resident of Nevada and was and is a doctor of osteopathic medicine licensed to
practice in the State of Nevada. The particular county in which Dr. Culver resides is
unknown to the Plaintiff.
10. That Plaintiffs are informed and believe and thereupon allege that at all
times mentioned herein, FREE SPEECH FOUNDATION, INC. D/B/A/ AMERICA’S
FRONTLINE DOCTORS (hereinafter “America’s Frontline Doctors”), is a foreign
nonprofit corporation with its principal place of business in Nevada located in
Washoe County.
11. The true names and capacities, whether individual, corporate,
associate, or otherwise, Defendants Roe Corporations I through X are unknown to
Plaintiffs, who therefore sue said Defendants by such fictitious names. Plaintiffs are
informed and believe and thereon allege that each of the Defendants designated
herein as a Roe Corporation is negligently responsible in some manner for the
events and happenings herein referred to and negligently caused injury and
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4. damages proximately thereby to Plaintiffs as herein alleged. Plaintiffs will ask leave
of court to amend this Complaint to insert the true names and capacities of said
Roe Corporation Defendants when the same have been ascertained by Plaintiffs,
together with the appropriate charging allegations, and to join such Defendants to
this action.
12. Plaintiffs reserve the right to amend and supplement this Complaint as
to claims and the true names, official capacities and/or degree of involvement of
said Defendants.
13. At all times herein mentioned, each Defendant was the co-conspirator,
agent, servant, employee, assignee and/or joint venturer of each of the other
Defendants and was acting within the course and scope of said conspiracy, agency,
employment, assignment and/or joint venture and with the permission and consent
of each of the other Defendants. Plaintiffs are informed and believe, and thereon
allege, that Defendants,and each of them, at all material times relevant to this
Complaint, performed the acts alleged herein. Plaintiffs are informed and believe,
and thereon allege, that at all times mentioned herein, Defendants, and each of
them, including without limitation those.
14. Defendants herein sued as DOES or ROES, were acting in concert or
participation with each other, or were joint participants and collaborators in the acts
complained of, or were the agents or employees of the others in doing the acts
complained of herein, each and all of them acting within the course and scope of
said agency and/or employment by the others, each and all of them acting in
concert one with the other and all together.
15. Attached to this Complaint as Exhibit 1 is the Declaration of Dr.
Bannister, provided per NRS 41A.071, and are attached as if fully rewritten herein.
///
///
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5. ALLEGATIONS OF FACT
16. Jeremy Parker died on February 3, 2022. He left behind a wife who is
disabled, and three minor children, “TP” age 17, “GP” age 14, and “LP” age 8. He
also left behind many other family members and friends. He was 52 years old. His
death was caused by the negligence of Dr. Culver and by falsehoods spread by
America’s Frontline Doctors.
17. 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.
18. America’s Frontline Doctors promoted falsehoods about the COVID-19
pandemic and COVID-19 vaccines.
19. America’s Frontline Doctors made false claims about COVID-19
vaccines efficacy and safety, and promoted paid telehealth consultations with
"AFLDS-trained" physicians that would prescribe medications claimed to be
COVID-19 treatments.
20. On June 15, 2020, the U.S. Food & Drug Administration (FDA) revoked
an Emergency Use Authorization for hydroxychloroquine. The FDA concluded, “it is
no longer reasonable to believe that oral formulations of HCQ and CQ may be
effective in treating COVID-19, nor is it reasonable to believe that the known and
potential benefits of these products outweigh their known and potential risks.”
21. On March 24, 2020, Nevada Governor Steve Sissolak signed an
emergency regulation promulgated by the Nevada State Board of Pharmacy that
prohibited the prescribing and dispensing of hydroxychloroquine for a COVID-19
diagnosis.
22. Believing what he had heard from America’s Frontline Doctors, in early
to mid-August of 2021, Mr. Parker reached out to America’s Frontline Doctors
seeking a prescription for hydroxychloroquine in case he contracted COVID-19.
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6. 23. On or around August 26, 2021, Mr. Parker was connected with Dr.
Culver through America’s Frontline Doctors.
24. 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.”
25. Soon thereafter, Mr. Parker received a prescription for
hydroxychloroquine 200 mg from “Ravkoo,” in the mail, which was arranged by
America’s Frontline Doctors.
26. Dr. Culver never performed a physical examination of Mr. Parker.
27. In late January of 2022, Mr. Parker began to have cold-like symptoms.
On the night of February 1st and 2nd, 2022, Mr. Parker spent the night with a family
friend, Ron Pevny, at Mr. Pevny’s home on Royal Drive in Reno, Nevada. At around
12 p.m. on February 1, 2022, Mr. Parker called Jelena and informed her that he was
feeling ill with cold symptoms and that he would be staying the night at Mr. Pevny’s
house, and that he was afraid that he had COVID-19. On February 2, 2022, at
around 9 p.m. Mr. Parker called and spoke to his children, but not to Jelena Hatfield.
28. On the morning of February 3, 2022, Mr. Parker’s body was discovered
by Mr. Pevny.
29. An autopsy was performed on Mr. Parker by the Washoe County
Coroner’s office. A copy of the Certificate of Death of Mr. Parker is attached hereto
as Exhibit 2. Therein, the coroner concluded that Mr. Parker’s immediate cause of
death was “Sudden Death In The Setting of Therapeutic Use of
Hydroxychloroquine.”
30. According to the Declaration of R. Bruce Bannister, D.O. attached
hereto as Exhibit 1, Dr. Culver breached the standard of care by prescribing
hydroxychloroquine to Mr. Parker because “[a] physical examination was not
performed, diagnostic tests, most importantly an electrocardiogram, were not
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7. performed to evaluate Mr. Parker’s cardiac rhythm, to ensure that the
hydroxychloroquine could be safely prescribed.”
31. According to the Declaration of Dr. Bannister, to a reasonable degree of
medical probability, ingestion of hydroxychloroquine prescribed by Dr. Culver
caused Mr. Parker’s death.
CLAIMS FOR RELIEF
FIRST CAUSE OF ACTION
WRONGFUL DEATH
32. Plaintiffs hereby re-allege those allegations contained herein and
incorporate same by reference as though fully set forth herein.
33. Mr. Parker passed away on February 3, 2022, as a direct and proximate
result of the negligence of Defendants.
34. As a direct and proximate result of Defendants’ actions and/or
omissions as herein alleged, Plaintiffs have incurred expenses expenses incidental
thereto, funeral expenses, all to their damage in a sum according to proof at trial and
request all damages available pursuant to NRS 41.085.
35. Defendants, and each of them, had a duty to care for and treat their
patients in a reasonable, prudent and appropriate manner.
36. Defendants, and each of them, breached said duty and, as a proximate
result thereof, decedent died.
37. Plaintiffs have attached the Declaration of R. Bruce Bannister, D.O.
hereto as Exhibit 1 (attached in full as if fully rewritten herein). Dr. Bannister testifies
about the standard of care that Defendants had, that Defendants fell below the
standard of care and that such breach, to a reasonable degree of medical
probability, was the cause of the death of Dr. Parker.
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8. 38. As a direct and proximate result of Defendants’ actions and/or
omissions, Plaintiff Estate of Mr. Parker has suffered special damages, including
economic loss in an amount in excess of Fifteen Thousand Dollars ($15,000.00).
39. As a further proximate result of Defendants’ actions and/or omissions,
Plaintiffs have suffered general damages including, but not limited to loss of
consortium, society, love, support and companionship, emotional distress and pain
and suffering as a result of the untimely death of Mr. Parker in an amount in excess
of Fifteen Thousand Dollars ($15,000.00).
40. The actions above constitute wrongful death by Defendants against
decedent and, as such, Plaintiffs hereby respectfully request all damages available
to them, individually, pursuant to NRS 41.085, NRS 41.100, NRS 41A et seq. and/or
any other available statutory and/or common law remedies.
41. Plaintiffs have been required to retain the services of an attorney to
prosecute this action, and Plaintiffs are therefore entitled to attorney's fees and
costs of suit.
SECOND CAUSE OF ACTION
PROFESSIONAL NEGLIGENCE
42. Plaintiffs hereby re-allege those allegations contained herein and
incorporate same by reference as though fully set forth herein.
43. Defendants Dr. Culver is a physician and/or provider of health care as
set forth in NRS 41A.017.
44. Defendants owed Plaintiff a duty to use the care and skill ordinarily
exercised by physicians under like or similar circumstances, and to use reasonable
diligence and best judgment in the exercise of skill and the application of learning in
an effort to accomplish the purpose for which they were employed.
45. At all times mentioned herein, Defendants knew, or in the exercise of
reasonable care, should have known, that the providing of medical care and
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9. treatment was of such a nature that if not properly given, is likely to injure the person
to whom it is given.
46. That Defendants fell below the standard of care by improperly
prescribing hydroxychloroquine to Mr. Parker.
47. Plaintiffs have attached the Declaration of R. Bruce Bannister, D.O.
hereto as Exhibit 1 (attached in full as if fully rewritten herein). Dr. Bannister testifies
about the standard of care that Defendants had, that Defendants fell below the
standard of care and that such breach, to a reasonable degree of medical
probability, was the cause of the death of Dr. Parker.
48. As a direct and proximate result of Defendants’ actions and/or
omissions as herein alleged, Mr. Parker died.
49. As a direct and proximate result of the negligent actions, omissions and
breaches of duty of Defendants and each one of them as described herein, Plaintiffs
suffered general and special damages in an amount in excess of $15,000.00.
50. It has become necessary for Plaintiffs to retain the services of an
attorney to prosecute this action, and Plaintiffs are therefore entitled to attorney's
fees and costs of suit.
THIRD CAUSE OF ACTION
EXEMPLARY DAMAGES
51. Plaintiffs hereby re-allege those allegations contained herein and
incorporate same by reference as though fully set forth herein.
52. The Defendants acted with knowledge of the probable harmful
consequences of the wrongful act and a willful and deliberate failure to act to avoid
those consequences of the probable harmful consequences of prescribing
hydroxychloroquine to Mr. Parker.
53. The Defendants conduct was malicious and oppressive and showed a
conscious disregard of Mr. Parker’s rights protected under law;
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10. 54. As such, the Plaintiffs seek an award of exemplary and punitive
damages against the Defendants.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for judgment against Defendants, and each of
them, jointly and severally, as set forth below:
1. For general damages in excess of Fifteen Thousand Dollars
($15,000.00);
2. For special damages, as set hereinabove, in excess of Fifteen Thousand
Dollars ($15,000.00);
3. For exemplary damages;
4. For attorney’s fees and costs;
5. For pre-judgment and post-judgment interest; and
6. For such other and further relief as the Court deems just and proper.
NRS 239B.030(4) AFFIRMATION
Pursuant to NRS 239B.030 the undersigned hereby affirms that this
document does not contain the social security number of any person.
DATED this Feb 3, 2023
By: /s/ Luke Busby, Esq.___________
LUKE A. BUSBY, ESQ.
Nevada Bar No. 10319
316 California Ave.
Reno, Nevada 89509
775-453-0112
luke@lukeandrewbusbyltd.com
Attorneys for the Petitioner
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