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`IN THE SUPREME COURT OF THE STATE OF NEVADA
`
`Case No. 88997
`
`IN RE: DISCIPLINE OF
`
`LESLIE MARK STOVALL,
`
`NEVADA BAR NO. 2566
`
`)
`)
`)
`)
`)
`)
`)
`
`Electronically Filed
`Mar 24 2025 11:36 PM
`Elizabeth A. Brown
`Clerk of Supreme Court
`
`VOLUME V
`
`RECORD OF DISCIPLINARY PROCEEDINGS,
`PLEADINGS AND TRANSCRIPT OF HEARING
`
`Daniel M. Hooge, Esq.
`Bar No. 10620
`
`
`State Bar of Nevada
`3100 W. Charleston Blvd., Ste. 100
`Las Vegas, NV 89102
`
`Counsel for the State Bar of Nevada
`
`Mark Leslie Stovall, Esq.
`Bar No. 2566
`2301 Palomino Lane
`Las Vegas, NV 89107
`Respondent pro se
`
`Docket 88997 Document 2025-13399
`
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`2
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`3
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`4
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`5
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`6
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`7
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`8
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`9
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`10
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`11
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`13
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`20
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`IN THE SUPREME COURT OF THE STATE OF NEVADA
`
`Case No. 88997
`
`IN RE: DISCIPLINE OF
`
`LESLIE MARK STOVALL,
`
`NEVADA BAR NO. 2566
`
`)
`)
`)
`)
`)
`)
`)
`
`Electronically Filed
`Mar 24 2025 11:36 PM
`Elizabeth A. Brown
`Clerk of Supreme Court
`
`VOLUME V
`
`RECORD OF DISCIPLINARY PROCEEDINGS,
`PLEADINGS AND TRANSCRIPT OF HEARING
`
`Daniel M. Hooge, Esq.
`Bar No. 10620
`
`
`State Bar of Nevada
`3100 W. Charleston Blvd., Ste. 100
`Las Vegas, NV 89102
`
`Counsel for the State Bar of Nevada
`
`Mark Leslie Stovall, Esq.
`Bar No. 2566
`2301 Palomino Lane
`Las Vegas, NV 89107
`Respondent pro se
`
`Docket 88997 Document 2025-13399
`
`
`
` Description
`
`Transcript of Proceedings &
`Exhibits
`Held on May 15, 2024
`State Bar Exhibit 1
`
`State Bar Exhibit 2
`
`State Bar Exhibit 3
`
`State Bar Exhibit 4
`
`State Bar Exhibit 5
`
`State Bar Exhibit 6
`
`State Bar Exhibit 7
`
`Page
`Nos.
`1813-1831
`
`
`1832-1895
`
`1896-1934
`
`1935-1976
`
`1977-1981
`
`1982-2002
`
`2003-2016
`
`2017-2191
`
`Vol.
`No.
`V
`
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`State Bar Exhibit 8
`
`2192-2194
`
`V
`
`State Bar Exhibit 9
`
`2195-2277
`
`V
`
`
`
`1
`
`Recommendation
`
`Public
`
`Public
`
`Public
`
`Public
`
`Public
`
`Public
`
`Public
`
`SRCR 3(4)(f) and
`(h)- ROA 2017-2137
`seal because
`document contains
`privileged and
`confidential/private
`information.
`SRCR 3(4)(f) and
`(h)- seal because
`document is
`permeated with
`references to
`privileged and
`confidential/private
`information.
`
`SRCR 3(4)(f) and
`(h)- seal because
`document contains
`privileged and
`
`
`
` Description
`
`Page
`Nos.
`
`State Bar Exhibit 10
`
`2278
`
`Vol.
`No.
`
`V
`
`State Bar Exhibit 11
`
`2279-2310
`
`V
`
`State Bar Exhibit 12
`
`State Bar Exhibit 13
`
`State Bar Exhibit 14
`
`State Bar Exhibit 15
`
`2311-2344
`
`2345-2346
`
`2347
`
`2348-2669
`
`V
`
`V
`
`V
`
`V
`
`State Bar Exhibit 16
`
`2670-2673
`
`V
`
`
`
`2
`
`Recommendation
`
`confidential/private
`information.
`SRCR 3(4)(f) and
`(h)- seal because
`document is
`permeated with
`references to
`privileged and
`confidential/private
`information.
`SRCR 3(4)(b), (f),
`and (h)– redact ROA
`2283:16-25, 2284:1-
`7, 2284:10-2285:4,
`2285:6-16, 2285:19-
`25, 2288:11-15,
`2289:23-2290:19,
`2297:12-2298:4
`Public
`
`Public
`
`Public
`
`
`SRCR 3(4)(b), (f),
`and (h)- redact ROA
`2359:18-24, 2359:27-
`2360:21, 2360:23-
`2361:5, 2361:7-14,
`2363:28-2364:4,
`2365:12-2366:8,
`2373:2-22
`
`SRCR 3(4)(h)- redact
`file number on ROA
`2672 and 2673
`
`
`
` Description
`
`State Bar Exhibit 17
`
`Page
`Nos.
`2674-2691
`
`Vol.
`No.
`V
`
`State Bar Exhibit 18
`
`2692-3299
`
`V
`
`State Bar Exhibit 19
`
`State Bar Exhibit 20
`
`3300-3326
`
`3327-3342
`
`Respondent’s Exhibit A
`
`3343
`
`Respondent’s Exhibit B-
`Notice
`of
`Voluntary
`Dismissal- 5/9/2019
`Respondent’s Exhibit C-
`Federal Court Complaint
`
`3344-3346
`
`3347-3377
`
`Respondent’s Exhibit D- R’s
`Motion
`to Dismiss M’s
`Complaint - 6/14/2019
`Respondent’s Exhibit E
`
`Respondent’s Exhibit F- R’s
`Motion to Seal the Record-
`8/6/19
`
`
`
`3378-3434
`
`3435-3443
`
`3444-3497
`
`3
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`Recommendation
`
`SRCR 34)(b), (f), and
`(h)- seal because
`document contains
`privileged and
`confidential/private
`information.
`SRCR 34)(b), (f), and
`(h)- seal because
`document contains
`privileged and
`confidential/private
`information.
`Public
`
`Public
`
`Omitted
`
`Public
`
`SRCR 3(4)(b), (f),
`and (h)-– redact ROA
`3351:18-24, 3351:27-
`3352:21, 3352:23-
`3353:5, 3353:7-14,
`3355:28-3356:4,
`3357:12-3358:8,
`3365:2-22
`SRCR 3(4)(a)- USDC
`ECF 13- sealed
`
`Public
`
`Already redacted-
`Public
`
`
`
` Description
`
`Respondent’s Exhibit G- R’s
`Motio to Compel Arbitration
`and Stay Proceedings- 8/8/19
`Respondent’s Exhibit H- R’
`Motion to Dismiss Complaint-
`8/16/19
`Respondent’s Exhibit I- M’s
`Opposition to R’s Motion to
`Dismiss - 9/20/2019.
`Respondent’s Exhibit J- M’s
`Opposition to R’s Motion to
`Compel
`Arbitration
`-
`9/23/2019
`Respondent’s Exhibit K-
`Errata to M’s Opposition to
`R’s Motion
`to Compel
`Arbitration - 9/24/2019
`Respondent’s Exhibit L- R’
`Reply in support of Motion to
`Compel Arbitration and Stay
`of Proceedings or alternatively
`to Seal R’s Motion to Dismiss
`Complaint or
`to Compel
`Arbitration and Seal
`the
`Instant Motion and related
`Briefs and Notice of
`in
`cameria Submission
`Respondent’s Exhibit M- R’s
`Reply
`in Support of
`the
`Motion to Compel Arbitration
`and Stay Proceedings
`-
`10/14/2019
`Respondent’s Exhibit N- R’s
`Reply in support of Motion to
`Dismiss
`Respondent’s Exhibit O- R’s
`Motion to Strike and Maintain
`
`
`
`Page
`Nos.
`3498-3513
`
`3514-3551
`
`3552-3556
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`3357-3579
`
`3580-3826
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`3827-3837
`
`3838-3853
`
`3854-3866
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`3867-3879
`
`4
`
`Vol.
`No.
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`Recommendation
`
`Already redacted-
`Public
`
`Already redacted-
`Public
`
`SRCR 3(4)(a)- USDC
`ECF 41- sealed
`
`SRCR 3(4)(a)- USDC
`ECF 43- sealed
`
`SRCR 3(4)(a)- USDC
`ECF 44- sealed
`
`Already redacted-
`Public
`
`SRCR 3(4)(a)- USDC
`ECF 51- sealed
`
`Already redacted-
`Public
`
`Public
`
`
`
` Description
`
`Inadmissible
`Seal
`Under
`Documents attached to M’s
`Opposition
`to Motion
`to
`Compel Arbitration
`Respondent’s Exhibit P- M’s
`Opposition
`to Ronaldo's
`Motion to Strike Documents
`and to Seal - 11/27/2019
`Respondent’s Exhibit Q-
`Stipulation and Order
`to
`Extend Time for Filing Reply
`in support of R’s Motion to
`Strike, et al.
`Respondent’s Exhibit R- R’s
`Reply in support of Motion to
`Compel Arbitration and Stay
`Proceedings
`Respondent’s Exhibit S- R’s
`Errata to Reply in support of
`Motion to Compel Arbitration
`and Stay Proceedings
`Respondent’s Exhibit T-
`Magistrate
`Report
`and
`Recommendation
`Respondent’s Exhibit U- M’s
`Objection to the Magistrate
`Judge's
`Report
`and
`Recommendation- 3/3/2020
`Respondent’s Exhibit V –
`Defendant Cristiano
`Ronaldo’s Response to
`Plaintiff’s Objections to
`Magistrate’s Findings and
`Recommendations- 3/17/2020
`Respondent’s Exhibit W -
`Order- 9/30/20
`
`Page
`Nos.
`
`Vol.
`No.
`
`Recommendation
`
`3880-4064
`
`4065-4066
`
`4067-4091
`
`4092-4093
`
`4094-4102
`
`4103-4123
`
`4124-4139
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`SRCR 3(4)(a)- USDC
`ECF 61- sealed
`
`Public
`
`Public
`
`Public
`
`Public
`
`SRCR 3(4)(a)- USDC
`ECF 70- sealed
`
`Public
`
`4140-4167
`
`V
`
`Public
`
`
`
`5
`
`
`
` Description
`
`Respondent’s Exhibit X -
`Order- 12/2/2020
`Respondent’s Exhibit Y
`
`-
`Respondent’s Exhibit Z
`Defendant
`Cristiano
`Ronaldo’s Motion
`for
`Protective Order Governing
`Confidentiality of Documents-
`4/2/21
`Respondent’s Exhibit AA
`
`Respondent’s Exhibit BB
`
`Respondent’s Exhibit CC
`
`Respondent’s Exhibit DD-
`UNREDACTED – R’s Motion
`for
`Protective
`Order
`Governing Confidentiality of
`Documents - 4/2/2021.
`Respondent’s Exhibit EE-
`Order- 4/28/2021
`Respondent’s Exhibit FF-
`proposed
`Order
`for
`Confidentiality and Protective
`Order
`Respondent’s Exhibit GG- R’s
`Second
`Supplemental
`Disclosure of Witnesses and
`Documents - 4/30/2021
`Respondent’s Exhibit HH- R’s
`Emergency Motion for Case
`Terminating Sanctions and to
`Disqualify Respondent with
`Exhibits- 5/27/2021
`
`
`
`Page
`Nos.
`4168-4170
`
`4171-4175
`
`4176-4256
`
`4257
`
`4258
`
`4259
`
`4260-4341
`
`4342-4345
`
`4346-4351
`
`4352-5568
`
`5569-6804
`
`6
`
`Vol.
`No.
`V
`
`V
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`V
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`V
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`V
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`V
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`V
`
`V
`
`V
`
`V
`
`V
`
`Recommendation
`
`Public
`
`Omitted
`
`Public
`
`Omitted
`
`Omitted
`
`Omitted
`
`SRCR 3(4)(a)- USDC
`ECF 93 Sealed
`
`Public
`
`Public
`
`SRCR 3(4)(f)-
`Medical Records.
`
`SRCR 3(4)(a)- USDC
`ECF 111 Sealed
`
`
`
` Description
`
`Respondent’s Exhibit II- M’s
`First Supplemental Disclosure
`- 6/2/2021
`Respondent’s Exhibit JJ- M’s
`Response to R’s Motion for
`Case Terminating Sanctions -
`7/20/2021
`Respondent’s Exhibit KK-
`M’s Motion for In Camera
`Review of the Football Leak
`Documents
`to Determine
`Whether
`the Crime-Fraud
`Exception Applies - 7/20/2021
`Respondent’s Exhibit LL-
`Exhibits 1-10 in Support of
`M’s Response to R’s Motion
`for Terminal Sanctions and
`M’s Motion for In Camera
`Review of the Football Leak
`documents
`to Determine
`Whether
`the Crime/Fraud
`Exception Applies - 7/20/2021
`Respondent’s Exhibit MM-
`R’s Reply in Support of the
`Emergency Motion for Case
`Terminating Sanctions
`to
`Disqualify
`Stovall
`&
`Associates- 8/13/2021
`Respondent’s Exhibit NN- R’s
`Response to M’s Motion for in
`Camera Review
`of
`the
`Football Leak Documents to
`Determine Whether Crime-
`Fraud Exception Applies-
`8/18/2021
`
`Page
`Nos.
`
`6805-7117
`
`7118-7131
`
`7132-7150
`
`Vol.
`No.
`V
`
`V
`
`V
`
`Recommendation
`
`SRCR 3(4)(a)- USDC
`ECF 123 Sealed
`
`SRCR 3(4)(a)- USDC
`ECF 124 Sealed
`
`
`SRCR 3(4)(a)- USDC
`ECF 140 Sealed
`
`
`7151-7568
`
`V
`
`SRCR 3(4)(a)- USDC
`ECF 140 Sealed
`
`
`7569-7586
`
`V
`
`7587-7599
`
`V
`
`SRCR 3(4)(a)-
`USDC- ECF 140
`Sealed
`
`SRCR 3(4)(a)-
`USDC- ECF 140
`Sealed
`
`
`
`7
`
`
`
` Description
`
`Respondent’s Exhibit OO-
`M’s Reply to R’s Response to
`M’s Motion for In Camera
`Review of the Football Leak
`Documents
`to Determine
`Whether
`the Crime-Fraud
`Exception Applies - 9/7/2021
`Respondent’s Exhibit PP-
`Transcript of Proceedings-
`10/6/2021
`Respondent’s Exhibit QQ-
`Order
`and Report
`and
`Recommendation- 10/6/2021
`Respondent’s Exhibit RR-
`M’s Objection
`to
`the
`Magistrate
`Judge’s
`Recommendation Denying In
`Camera Review -11/5/2021
`Respondent’s Exhibit SS- M’s
`Objection to the Magistrate Judge’s
`Recommendation Granting
`Ronaldo's Motion for Terminal
`Sanctions -11/5/2021
`
`Respondent’s Exhibit TT- M’s
`Motion to Amend Order Sustaining
`in Part Objection and Adopting and
`Modifying in Part Report &
`Recommendation - 11/5/2021
`
`Respondent’s Exhibit UU-
`M’s Exhibits 1-6 in Support of
`Objections n and the Motion to
`Amend Order - 11/5/2021
`Respondent’s Exhibit VV- R’s
`Motion for Protective Order -
`12/1/2021
`
`
`
`Page
`Nos.
`7600-7606
`
`Vol.
`No.
`V
`
`Recommendation
`
`SRCR 3(4)(a)- USDC
`ECF 138 Sealed
`
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`Public
`
`Public
`
`SRCR 3(4)(a)- USDC
`ECF 152 Sealed
`
`
`SRCR 3(4)(a)- USDC
`ECF 153 Sealed
`
`
`SRCR 3(4)(a)- USDC
`ECF 154 Sealed
`
`
`SRCR 3(4)(a)- USDC
`ECF 155 Sealed
`
`
`Public
`
`7607-7675
`
`7676-7698
`
`7699-7713
`
`7714-7738
`
`
`
`7760-7828
`
`7829-7873
`
`8
`
`
`
` Description
`
`Respondent’s Exhibit WW-
`R’s Response
`to M’s
`Objection
`to Magistrate
`Judge’s
`Recommendation
`Denying In Camera Review-
`12/3/2021
`Respondent’s Exhibit XX- R’s
`Response to M’s Objection to
`report and Recommendation
`Granting R’s Motion
`to
`Terminal
`Sanctions
`-
`12/3/2021
`Respondent’s Exhibit YY-
`M’s Response to R’s Motion
`for
`Protective Order
`-
`12/14/2021
`Respondent’s Exhibit ZZ- R’s
`Limited Reply
`to M’s
`Response to R’s Motion for
`Protective Order - 12/21/2021
`Respondent’s Exhibit AAA-
`Stipulation to Extend time to
`File M’s Reply to Opposition
`to Motion to Amend Order -
`12/29/2021
`Respondent’s Exhibit BBB- M’s
`Reply to Opposition to Motion to
`Amend Order - 12/29/2021
`Respondent’s Exhibit CCC-
`New York Times Company’s
`Motion to Intervene - 12/28/21
`Respondent’s Exhibit DDD-
`Response to Las Vega Metro’s
`Notice Regarding Criminal
`Investigative File- 1/11/2022
`Respondent’s Exhibit EEE-
`M’s Reply to New York Times
`
`
`
`Page
`Nos.
`7874-7883
`
`Vol.
`No.
`V
`
`Recommendation
`
`Public
`
`7884-7897
`
`V
`
`SRCR 3(4)(a)- USDC
`ECF 153 Sealed
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`V
`
`7898-7949
`
`7950-7957
`
`7958-7959
`
`7960-7972
`
`7973-8038
`
`8039-8065
`
`8066-8071
`
`9
`
`Public
`
`Public
`
`Public
`
`SRCR 3(4)(a)- USDC
`ECF 174 Sealed
`
`SRCR 3(4)(h)- redact
`file number on
`ROA8024
`Public
`
`SRCR 3(4)(a)- USDC
`ECF 185 Sealed
`
`
`
` Description
`
`Opposition for Preliminary -
`2/8/2022
`Respondent’s Exhibit FFF-
`M’s Joinder in New York
`Times’ Motion to Intervene -
`2/8/2022
`Respondent’s Exhibit GGG-
`M’s Joinder in New York
`Times’ Response to Metro
`Notice Regarding Criminal
`Investigative File - 2/8/2022
`Respondent’s Exhibit HHH-
`R’ Response to LVMPD’s
`Notice
`regarding Criminal
`Investigative File- 2/8/2022
`Respondent’s Exhibit III- R’s
`Opposition
`to New York
`Times Company’s Motion to
`Intervene and Reply to New
`York
`Times’
`Proposed
`Response in Opposition to
`motion for Protective Order-
`2/8/2022
`JJJ-
`Respondent’s Exhibit
`LVMPD’s Reply in Support of
`Notice Regarding Real Party
`in
`Interest’s,
`LVMPD,
`Criminal Investigative File-
`2/15/2022
`Respondent’s Exhibit KKK-
`New York Times Company’s
`Reply in Support of Motion to
`Intervene- 2/25/2022
`Respondent’s Exhibit LLL-
`Order
`and Report
`and
`Recommendation- 3/11/2022
`
`Page
`Nos.
`
`Vol.
`No.
`
`
`
`Recommendation
`
`8072-8075
`
`8076-8078
`
`8079-8114
`
`8115-8163
`
`V
`
`V
`
`V
`
`V
`
`SRCR 3(4)(a)- USDC
`ECF 186 Sealed
`
`
`SRCR 3(4)(a)- USDC
`ECF 187 Sealed
`
`
`Public
`
`SRCR 3(4)(h)- redact
`file number on ROA
`8137
`
`8164-8183
`
`V
`
`Public
`
`8184-8189
`
`8190-8199
`
`V
`
`V
`
`Public
`
`Public
`
`
`
`10
`
`
`
` Description
`
`Respondent’s Exhibit MMM-
`Order Adopting
`Report
`Recommendation
`and
`Denying Motions to Intervene
`and
`for
`Preliminary
`Injunction- 4/5/2022
`Respondent’s Exhibit NNN-
`Order Overruling Objections,
`Adopting
`Report
`and
`Recommendation, Denying
`Relief on Reconsideration,
`and
`Dismissing
`Case-
`6/10/2022
`Respondent’s Exhibit OOO-
`R’s Motion for Atty Fee and
`Costs Against Respondent
`Respondent’s Exhibit PPP-
`R’s Motion for Leave to File
`Under Seal Exhibit E to R’s
`Motion for Atty Fees and
`Costs Against Respondent-
`6/24/2022
`Respondent’s Exhibit QQQ-
`M’s Notice
`of Appeal-
`7/8/2022
`Respondent’s Exhibit RRR-
`M’s Objection to R’s Bill of
`Costs- 8/10/2022
`Respondent’s Exhibit SSS-
`R’s Response to M’ Objection
`to R’s Bill of Costs- 8/27/2022
`Respondent’s Exhibit TTT-
`R’s Reply to in Support of
`Mtoion for Atty Fees and
`Costs Against Respondent-
`8/27/2022
`
`
`
`Page
`Nos.
`8200-8201
`
`Vol.
`No.
`V
`
`Recommendation
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`Public
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`8202-8245
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`V
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`Public
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`V
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`V
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`V
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`V
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`V
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`V
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`Public
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`Public
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`Public
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`Public
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`Public
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`Public
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`8246-8261
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`8262-8266
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`8267-8269
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`8270-8275
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`8276-8298
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`8286-8298
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`11
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`
`
` Description
`
`Respondent’s Exhibit UUU-
`Order Granting in Part R’s
`Motion for Atty Fees and
`Denying as Moot M’s Motion
`to
`Produce
`Retainer
`Agreement- 2/14/2023
`Respondent’s Exhibit VVV-
`Bill of Costs- 2/6/2023
`Respondent’s Exhibit WWW-
`Clerk’s
`Memorandum-
`2/16/2023
`Respondent’s Exhibit XXX-
`M’s Notice
`of Appeal-
`3/10/2023
`Respondent’s Exhibit YYY-
`M’s Ninth Circuit Opening
`Brief
`Respondent’s Exhibit ZZZ-
`R’s Ninth Circuit Answering
`Brief
`Respondent’s Exhibit AAAA-
`M’s Ninth Circuit Reply Brief
`Respondent’s Exhibit BBBB-
`Ninth
`Circuit
`Filed
`Memorandum Disposition-
`12/21/2023
`Respondent’s Exhibit CCCC-
`M’s Ninth Circuit Petition for
`Rehearing
`En
`Banc-
`12/22/2023
`Respondent’s Exhibit DDDD-
`ZZZZ
`Respondent’s Exhibit
`AAAAA- RRRRR
`Respondent’s Exhibit SSSSS-
`SBN22-00257 State Bar’s
`
`
`
`Recommendation
`
`Public
`
`Public
`
`Public
`
`Public
`
`SRCR 3(4)(a)- Ninth
`Cir. ECF 36- sealed
`
`SRCR 3(4)(a)- Ninth
`Cir. ECF 68- sealed
`
`SRCR 3(4)(a)- Ninth
`Cir. ECF 75- sealed
`Public
`
`Public
`
`Omitted
`
`Omitted
`
`Public
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`Page
`Nos.
`8299-8316
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`Vol.
`No.
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`V
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`V
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`V
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`V
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`V
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`V
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`V
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`V
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`V
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`8317
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`8318-8320
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`8321-8345
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`8346-8407
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`8408-8446
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`8467-8500
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`8501-8506
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`8507-8536
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`8537
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`8538
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`8539-8549
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`12
`
`
`
` Description
`
`Disciplinary Complaint -
`3/16/2023
`Respondent’s Exhibit
`TTTTT- SBN22-00257
`Respondent’s Motion to
`Dismiss - 5/15/2023
`Respondent’s Exhibit
`UUUUU- SBN22-00257
`State Bar’s Opposition to
`Respondent's Motion to
`Dismiss - 5/30/2023
`Respondent’s Exhibit
`VVVVV- SBN22-00257 –
`Respondent’s Reply Brief-
`6/22/2023
`Respondent’s Exhibit
`WWWWW- SBN22-00257 -
`Order Denying Motion to
`Dismiss - 7/11/2023
`Respondent’s Exhibit
`XXXXX- Respondent’s
`Supreme Court of Nevada’s
`Petition for Writ Mandamus
`or Prohibition - 7/27/2023
`Respondent’s Exhibit
`YYYYY- State Bar’s of
`Nevada’s Answer to Petition
`for Writ Mandamus or
`Prohibition - 9/18/2023
`Respondent’s Exhibit ZZZZZ-
`Respondent’s Reply In Support of
`Writ of Mandamus or, Alternatively
`for, Writ of Prohibition - 10/3/2023
`Respondent’s Exhibit AAAAAA-
`Supreme Court of Nevada’s Order
`Denying Petition for Writ
`
`Page
`Nos.
`
`Vol.
`No.
`
`Recommendation
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`8550-8691
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`8692-8753
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`8757-8930
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`8931-8932
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`8933-9263
`
`V
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`V
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`V
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`V
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`V
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`SRCR 3(4)(h)- redact
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`Public
`
`SRCR 3(4)(h)- redact
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`Public
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`Public
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`9264-9299
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`V
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`Public
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`9300-9340
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`9341-9342
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`V
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`V
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`Public
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`Public
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`
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`13
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`
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` Description
`
`Mandamus or Prohibition -
`11/17/2023
`Respondent’s Exhibit BBBBBB-
`Respondent’s Ltr to Sgt. Comiskey
`with Football Leak Docs -
`8/21/2018
`Respondent’s Exhibit CCCCCC-
`Respondent’s Ltr to Sgt. Comiskey
`with Additional Football Leak Docs
`- 9/24/2018
`Respondent’s Exhibit DDDDDD-
`Respondent’s Ltr to SBN with
`Football Leak Docs and CCDC
`Complaint - 10/5/2013
`
`Respondent’s Exhibit EEEEEE-
`State Bar Ltr - More Info Letter to
`Respondent- 10/10/2018
`Respondent’s Exhibit FFFFFF-
`State Bar Ltr - No Further Action
`Letter to Respondent - 11/2/2018
`Respondent’s Exhibit GGGGGG-
`Omitted
`Respondent’s Exhibit HHHHHH-
`Order Granting in part R’s Motion
`for Attorney’s Fees and Denying as
`Moot M’s Motion to Produce
`Retainer Agreement
`Respondent’s Exhibit IIIIII- DKT
`95 – Memorandum in Support of
`Application for Fees
`
`Page
`Nos.
`
`Vol.
`No.
`
`Recommendation
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`9343-9520
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`9521-9604
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`9605-9899
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`9900
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`9901
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`9902
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`9903-9924
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`V
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`V
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`V
`
`V
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`V
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`V
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`V
`
`SRCR 3(4)(h)- redact
`ROA 9433-9466
`
`SRCR 3(4)(h)- seal
`ROA 9521-9604
`
`SRCR 3(4)(h)- redact
`ROA 9606-9729,
`ROA 9784-9863,
`ROA 9864-9867,
`9872:16-25, 9873:1-
`6, 9873:10-9874:4,
`9874:6-16, 9874:19-
`25, 9877:11-15,
`9878:23-9879:19,
`9886:12-9887:4
`Public
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`Public
`
`Omitted
`
`Public
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`9925-9990
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`V
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`Public
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`
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`14
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` Description
`
`Respondent’s Exhibit JJJJJJ- DKT
`98 – Opposition to Motion for Fees
`Respondent’s Exhibit KKKKKK-
`DKT 99 – Reply ISO Application
`for Fees
`Respondent’s Exhibit LLLLLL-
`DKT 100 – Order US Court of
`Appeals
`
`
`Page
`Nos.
`9991-10021
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`10022-
`10040
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`10041-
`10043
`
`Vol.
`No.
`V
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`V
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`V
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`Recommendation
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`Public
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`Public
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`Public
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`
`
`15
`
`
`
`LESLIE MARK STOVALL, ESQ.,
`Nevada Bar No. 2566
`
`Reported by: Deborah Ann Hines, CCR #473, RPR
`
`CERTIFIED
`TRANSCRIPT
`
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`FORMAL HEARING OF LESLIE MARK STOVALL, ESQ.
`
`VOLUME III
`
`Taken at the State Bar of Nevada
`
`3100 W. Charleston Boulevard, Suite 100
`
`Las Vegas, Nevada
`
`On Monday, May 15, 2024
`
`At 3:08 p.m.
`
`702-509-3121
`NEVADA FIRM #069F
`INTEGRITY COURT REPORTING, LLC
`8545 W. WARM SPRINGS ROAD, SUITE A-4405, LAS VEGAS, NV 89113
`ROA Page 1813
`
`STATE BAR OF NEVADA
`
`SOUTHERN NEVADA DISCIPLINARY BOARD
`
`) )
`
`Neeeteteeetee
`
`STATE BAR OF NEVADA,
`
`vs.
`
`Complainant,
`
`Respondent.
`
`Case No.
`) SBN22-00257
`
`ROA Page 1813
`
`
`
`STATE BAR OF NEVADA SOUTHERN NEVADADISCIPLINARY BOARD
`Stovall, Leslie Mark on 05/15/2024
`
`Page 437
`
`Appearances:
`
`Commission Panel:
`
`SANDRA DIGIACOMO, ESQ.
`Panel Chairman
`
`REED WERNER, ESQ.
`Panel Member
`
`VIKKI SEELIG
`Laymember
`
`For the Complainant:
`
`DANIEL HOOGE, ESQ.
`Bar Counsel
`- and -
`BRIAN J. VASEK, ESQ.
`Assistant Bar Counsel
`State Bar of Nevada
`3100 W. Charleston Boulevard
`Suite 100
`Las Vegas, NV 89102
`(702) 382-2200
`
`Observer
`
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`For the Respondent:
`
`LESLIE MARK STOVALL, ESQ.
`Stovall & Associates
`2301 Palomino Lane
`Las Vegas, NV 89107
`(702) 258-3034
`
`Also Present:
`
`TIFFANY BRADLEY
`Hearing Paralegal
`
`RAYNA SCAMARDI
`CHRISTOPHER OUELLETTE
`
`702-509-3121
`NEVADA FIRM #069F
`INTEGRITY COURT REPORTING, LLC
`8545 W. WARM SPRINGS ROAD, SUITE A-4405, LAS VEGAS, NV 89113
`ROA Page 1814
`
`ROA Page 1814
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`
`
`Page 438
`
`eeWNYOFf
`
`nOUl
`
`PROCEEDINGS
`
`Panel Decision
`
`Stovall, Leslie Mark on 05/15/2024
`
`25 STATE BAR OF NEVADA SOUTHERN NEVADADISCIPLINARY BOARD
`
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`702-509-3121
`NEVADA FIRM #069F
`INTEGRITY COURT REPORTING, LLC
`8545 W. WARM SPRINGS ROAD, SUITE A-4405, LAS VEGAS, NV 89113
`ROA Page 1815
`
`ROA Page 1815
`
`
`
`CHAIR DIGIACOMO: Let's go back on the
`
`record in State Bar of Nevada versus Leslie Mark
`
`Page 439
`
`STATE BAR OF NEVADA SOUTHERN NEVADADISCIPLINARY BOARD
`Stovall, Leslie Mark on 05/15/2024
`
`Mr. Stovall never disclosed to Ronaldo's counsel
`
`Stovall, Esquire.
`
`It's a little after 3:00 p.m. on
`
`May 15th, 2024.
`
`The panel has deliberated most of
`
`the day and we have made our decision.
`
`So I'm going
`
`to start by going through the, basically the Verdict
`
`Form that was given to us by defense (sic) counsel.
`
`So first I'm going to discuss the
`
`violations.
`
`The panel found that Mr. Stovall did
`
`violate RPC 4.4(a), which is basically, "In
`
`representing a client, a lawyer shall not...use
`
`methods of obtaining evidence that violate the legal
`
`rights of such a person."
`
`The panel found that
`
`Mr. Stovall did seek out clearly attorney-client
`
`privileged documents and violated the legal rights of
`
`Ronaldo in doing this.
`
`Mr. Stovall admitted to seeking out these
`
`documents and sending an email to, quote/unquote,
`
`John at Football Leaks, and that the email confirmed
`
`that we saw that he requested documents that
`
`unquestionably would be protected by attorney-client
`
`privilege.
`
`The documents on their face are noted as
`
`attorney-client privilege; and,
`
`furthermore,
`
`702-509-3121
`NEVADA FIRM #069F
`INTEGRITY COURT REPORTING, LLC
`8545 W. WARM SPRINGS ROAD, SUITE A-4405, LAS VEGAS, NV 89113
`ROA Page 1816
`
`ROA Page 1816
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`
`
`Page 440
`
`being in possession of these documents until over a
`
`year later into the lawsuit.
`
`Judge Dorsey ruled that the documents were
`
`privileged after considering Mr. Stovall's arguments,
`
`which he again raised in this hearing, and found that
`
`his arguments regarding privilege were "specious" and
`
`"7llogical."
`
`STATE BAR OF NEVADA SOUTHERN NEVADADISCIPLINARY BOARD
`Stovall, Leslie Mark on 05/15/2024
`
`access to, permits access to or causes to be
`
`Judge Dorsey's order,
`
`the panel found from
`
`looking through all the exhibits, was supported by
`
`the record. And that the record of the federal court
`
`case and the exhibits did not support Mr. Stovall's
`
`version of events that he proffered during this
`
`hearing.
`
`Furthermore,
`
`the 9th circuit affirmed Judge
`
`Dorsey's order on appeal by Mr. Stovall.
`
`We also found that Mr. Stovall violated RPC
`
`8.4(b), which is, "Committing a criminal act that
`
`reflects adversely on the lawyer's honesty,
`
`trustworthiness or fitness as a lawyer in other
`
`respects."
`
`We found that Mr. Stovall did violate NRS
`
`205.4765, which states, quote, a person who
`
`knowingly, willfully and without authorization, D,
`
`discloses; E, uses; H,
`
`takes; I, retains possession
`
`of; J, copies; or K, obtains or attempts to obtain
`
`702-509-3121
`NEVADA FIRM #069F
`INTEGRITY COURT REPORTING, LLC
`8545 W. WARM SPRINGS ROAD, SUITE A-4405, LAS VEGAS, NV 89113
`ROA Page 1817
`
`ROA Page 1817
`
`
`
`Page 441
`
`accessed; data, a program or any supporting documents
`
`which exist inside or outside a computer, system or
`
`network is guilty of a misdemeanor.
`
`We found Mr. Stovall did violate the
`
`statute.
`
`He went to a questionable source to obtain
`
`attorney-client privileged documents after he was
`
`unable to obtain them from what he said a legitimate
`
`source in Miss Mayorga's former attorney or the Der
`
`Speigel German newspaper.
`
`It was known that Football Leaks was
`
`STATE BAR OF NEVADA SOUTHERN NEVADA DISCIPLINARY BOARD
`Stovall, Leslie Mark on 05/15/2024
`
`could not be used against a secondary person who
`
`attempting to expose corruption in football when it
`
`formed, and from the articles that was published it
`
`was clear that the documents the articles were based
`
`upon relied upon attorney-client privileged documents
`
`from Mr. Ronaldo.
`
`Mr. Stovall then kept these documents, he
`
`used them to file a state and federal lawsuit, he
`
`copied them and disclosed them to LVMPD twice so that
`
`they would reopen the criminal investigation.
`
`He
`
`copied and disclosed them to the State Bar of Nevada,
`
`he disclosed them to his client, he filed them as an
`
`exhibit to an opposition in the federal case, and he
`
`disclosed them as discovery in that federal case.
`
`Mr. Stovall did argue that NRS 205.4765
`
`702-509-3121
`NEVADA FIRM #069F
`INTEGRITY COURT REPORTING, LLC
`8545 W. WARM SPRINGS ROAD, SUITE A-4405, LAS VEGAS, NV 89113
`ROA Page 1818
`
`ROA Page 1818
`
`
`
`Page 442
`
`received the stolen documents; however, after a plain
`
`reading of the statute,
`
`the panel disagrees with his
`
`assertion and does find he violated that statute.
`
`The panel further found that Mr. Stovall
`
`violated RPC 8.4(d), which is "engaging in conduct
`
`that is prejudicial to the administration of
`
`justice." Again Mr. Stovall purposely sought out and
`
`obtained attorney-client privileged documents.
`
`The
`
`attorney-client privilege is the oldest privilege in
`
`the practice of law and it's also the most
`
`important
`
`for the practice of law.
`
`It is so important that for
`
`clients to feel that they can fully disclose
`
`everything to their attorney so that informed
`
`decisions can be made by counsel advising their
`
`clients regarding legal issues and/or litigation.
`
`Mr. Stovall's disregarding his ethical
`
`STATE BAR OF NEVADA SOUTHERN NEVADA DISCIPLINARY BOARD
`Stovall, Leslie Mark on 05/15/2024
`
`Judge Dorsey found Mr. Stovall acted in bad
`
`obligations and all the legal boundaries -- excuse
`
`me, Mr. Stovall disregarded his legal -- his ethical
`
`obligations and all legal boundaries with his
`
`actions.
`
`Even after the federal court deemed that
`
`the documents were privileged under the
`
`attorney-client privilege, Judge Dorsey's order found
`
`that he continued to use them in violation of her
`
`order and his ethical duties.
`
`702-509-3121
`NEVADA FIRM #069F
`INTEGRITY COURT REPORTING, LLC
`8545 W. WARM SPRINGS ROAD, SUITE A-4405, LAS VEGAS, NV 89113
`ROA Page 1819
`
`ROA Page 1819
`
`
`
`Page 443
`
`faith because he procured and used privileged
`
`information to prosecute his case, and his client's
`
`case was dismissed with prejudice because of his
`
`actions. Quoting from Judge Dorsey's order, she
`
`stated that Stovall, quote, was in a position to
`
`intuit the privileged nature of the documents when he
`
`explicitly asked a shady source for documents
`
`containing prior defense counsel's purloined
`
`STATE BAR OF NEVADA SOUTHERN NEVADADISCIPLINARY BOARD
`Stovall, Leslie Mark on 05/15/2024
`
`The panel further finds that Mr. Stovall's
`
`communications.
`
`To adopt Stovall's interpretation of
`
`the privilege-log requirements would create a
`
`perverse incentive for unscrupulous attorneys or
`
`litigants to seek privileged documents outside of the
`
`discovery process in the hopes that the privileged --
`
`excuse me,
`
`the privilege-asserting party doesn't
`
`create a privilege log and thus waives privilege,
`
`allowing the documents to be used in court. This
`
`"gotcha" result cannot be the intent of these
`
`procedures rules. And again,
`
`furthermore,
`
`the 9th
`
`circuit affirmed Judge Dorsey's decision.
`
`Despite Mr. Stovall's arguments,
`
`this panel
`
`had no evidence before it in all of these exhibits
`
`and binders to question or relitigate the factual
`
`findings of the federal judge when those findings
`
`were upheld by the 9th circuit on appeal.
`
`702-509-3121
`NEVADA FIRM #069F
`INTEGRITY COURT REPORTING, LLC
`8545 W. WARM SPRINGS ROAD, SUITE A-4405, LAS VEGAS, NV 89113
`ROA Page 1820
`
`ROA Page 1820
`
`
`
`Page 444
`
`conduct was intentional. There's no question he
`
`sought out attorney-client privileged information in
`
`his email to Football Leaks.
`
`He also made the
`
`determination whether the documents were privileged
`
`without seeking guidance from the State Bar of Nevada
`
`or a court.
`
`STATE BAR OF NEVADA SOUTHERN NEVADADISCIPLINARY BOARD
`Stovall, Leslie Mark on 05/15/2024
`
`as evidenced by the plaintiff's sworn verification,
`
`He did not disclose the possession of those
`
`documents to Ronaldo or his attorneys immediately,
`
`and waited for over a year to do so in the federal
`
`case.
`
`Judge Dorsey's order found he acted in bad
`
`faith with his continued use of the privileged
`
`documents in the federal case.
`
`Judge Dorsey,
`
`in her order, stated, quote,
`
`he crossed the border of ethical behavior before he
`
`filed his action and his disregard for the rules of
`
`this court has continued unabated, end quote.
`
`Judge Dorsey also stated, quote, Stovall
`
`deliberately sought out his adversary's hacked,
`
`internal, privileged communications. Once he
`
`received them, he didn't seek ethical guidance on how
`
`to handle these clearly sensitive documents.
`
`Instead, he gave them to his client, ensuring that
`
`they would contaminate her memory and perception of
`
`events, and he built her complaint on their contents,
`
`702-509-3121
`NEVADA FIRM #069F
`INTEGRITY COURT REPORTING, LLC
`8545 W. WARM SPRINGS ROAD, SUITE A-4405, LAS VEGAS, NV 89113
`ROA Page 1821
`
`ROA Page 1821
`
`
`
`end quote.
`
`Another quote from Judge Dorsey's order,
`
`quote, This course of deliberate conduct is more than
`
`tantamount to bath faith, it is squarely bad faith,
`
`Page 445
`
`STATE BAR OF NEVADA SOUTHERN NEVADADISCIPLINARY BOARD
`Stovall, Leslie Mark on 05/15/2024
`
`circumstances the panel found, first, prior
`
`end quote.
`
`The panel further found that Mr. Stovall's
`
`actions were serious or potentially serious -- I'm
`
`sorry, Mr. Stovall's actions created a serious or
`
`potentially serious injury.
`
`If this conduct were
`
`allowed to occur that Mr. Stovall did,
`
`then the legal
`
`system would be damaged irreparably.
`
`Attorneys could use illegal means to obtain
`
`evidence and use it to coach their client or
`
`witnesses or use it as an advantage in court or
`
`negotiations with no repercussions.
`
`It would destroy
`
`confidentiality and the attorney-client privilege and
`
`no one would ever tell their attorney the truth or
`
`make a full disclosure. Without complete, full
`
`disclosure, attorneys' abilities to represent their
`
`clients would be completely defeated.
`
`Based upon the panel's findings,
`
`the
`
`baseline sanction is disbarment.
`
`So next we turn to the aggravating and
`
`mitigating circumstances.
`
`For aggravating
`
`702-509-3121
`NEVADA FIRM #069F
`INTEGRITY COURT REPORTING, LLC
`8545 W. WARM SPRINGS ROAD, SUITE A-4405, LAS VEGAS, NV 89113
`ROA Page 1822
`
`ROA Page 1822
`
`
`
`STATE BAR OF NEVADA SOUTHERN NEVADADISCIPLINARY BOARD
`Stovall, Leslie Mark on 05/15/2024
`
`Page 446
`
`disciplinary offenses. Mr. Stovall has 11 prior
`
`disciplinary actions against him from 1989 to 2020.
`
`Of concern to the panel were three.
`
`First of all,
`
`in 1993, ina Letter of Private
`
`Reprimand, he was reminded of his ethical obligations.
`
`In 1997 he was remanded again, or, excuse
`
`me,
`
`reprimanded again, excuse me, because he told a
`
`paralegal to lie to an expert witness about an
`
`appeal.
`
`He was found to have violated SCR 203(3),
`
`engaging in conduct
`
`involving dishonesty,
`
`fraud,
`
`deceit, or misrepresentation.
`
`In 2002 he was given a temporary suspension
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`for a 2001 conviction in which he pled guilty to
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`filing a false tax return.
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`In 2004 he made a conditional plea with the
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`State Bar of Nevada agreeing to a two-year suspension
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`with -- backdated with an immediate reinstatement,
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`and so he pled guilty to a violation of SCR 113,
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`commission of a criminal act that adversely reflects
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`on a lawyer's honesty,
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`trustworthiness, or fitness as
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`committed by Mr. Stovall that reflects adversely on
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`a lawyer.
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`Second,
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`the panel found an aggravating
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`circumstance of a pattern of misconduct.
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`In this
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`case the panel found that a criminal act was
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`702-509-3121
`NEVADA FIRM #069F
`INTEGRITY COURT REPORTING, LLC
`8545 W. WARM SPRINGS ROAD, SUITE A-4405, LAS VEGAS, NV 89113
`ROA Page 1823
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`ROA Page 1823
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`the lawyer's honesty,
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`trustworthiness, or fitness as
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`a lawyer.
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`Page 447
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`STATE BAR OF NEVADA SOUTHERN NEVADA DISCIPLINARY BOARD
`Stovall, Leslie Mark on 05/15/2024
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`panel found is illegal conduct, since we did find
`
`In 2002 to 2004,
`
`in the above case that I
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`just mentioned, he also committed a criminal act that
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`adversely reflected on the lawyer's honesty,
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`trustworthiness, or fitness as a lawyer.
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`The third aggravating circumstances the
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`panel found is multiple offenses. Here the panel
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`found violations of 4.4, 8.4(b) and 8.4(d).
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`The fourth aggravating circumstance the
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`panel found is refusal to acknowledge the wrongful
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`nature of conduct. At the hearing Mr. Stovall
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`continued to maintain that each court, which has
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`ruled that the documents were privileged,
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`is wrong,
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`that the documents are not privileged, and that he
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`did not do anything wrong.
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`Mr. Stovall showed no remorse, and there are
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`no assurances he would not commit the same actions in
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`the future, since he sees -- he does not see the
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`wrongful nature of his conduct.
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`The fifth aggravating circumstance the panel
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`found is substantial experience in the practice of
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`law, as Mr. Stovall has been practici
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