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`Electronically Filed
`Apr 03 2025 11:10 AM
`Elizabeth A. Brown
`Clerk of Supreme Court
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` )
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`LAURA CANTER,
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`Appellant,
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`vs.
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`TUSCANY MASTER ASSOCIATION;
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`LISA LAPLANTE; AND BECKY
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`KRAMER,
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`Respondents.
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`IN THE SUPREME COURT OF THE STATE OF NEVADA
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`Supreme Court Case No.: 90294
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`District Court Case No.: A898599
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`DOCKETING STATEMENT – CIVIL APPEALS
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`GENERAL INFORMATION
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`Appellants must complete this docketing statement in compliance with
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`Nevada Rules of Appellate Procedure (NRAP) 14(a). The purpose of the docketing
`statement is to assist the Supreme Court in screening jurisdiction, identifying issues
`on appeal, assessing assignment to the Court of Appeals under NRAP 17,
`scheduling cases for oral argument and settlement conferences, classifying cases for
`expedited treatment, and compiling statistical information.
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`
`WARNING
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`This statement must be completed fully, accurately, and on time. NRAP 14(c).
`The Supreme Court may impose sanctions on counsel or the appellant if it appears
`that the information provided is incomplete or inaccurate. Id. Failure to fill out
`the statement completely or to file it in a timely manner constitutes grounds for
`the imposition of sanctions, including a fine and/or dismissal of the appeal. Id.
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`Page 1 of 11
`Docket 90294 Document 2025-14963
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`A complete list of the documents that must be attached appears as Question
`28 on this docketing statement. Failure to attach all required documents will result
`in the delay of your appeal and may result in the imposition of sanctions. Id.
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`to
`that when obligations under NRAP 14
`This court has noted
`complete
`the docketing statement properly and conscientiously are not taken
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`seriously, valuable judicial resources of this court are wasted, making the
`imposition of sanctions appropriate. See KDI Sylvan Pools v. Workman, 107 Nev.
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`340, 344, 810 P.2d 1217, 1220 (1991). Please use divider pages to separate any
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`attached documents.
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`Judicial District: Eighth Judicial District Court, Clark County, Nevada
`1.
`County: Clark
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`Judge: Honorable Tina Talim
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`District Court Docket No: A-24-898599-C
`Department: Department XIV
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`Person filing this docket statement:
`Brian R. Dziminski, Esq., Nevada Bar Number 8436
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`Dziminski Law Group
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`10120 South Eastern Avenue, Suite 213
`Henderson, Nevada 89052
`Telephone Number: (702) 444-3525
`Email Address: brian@dziminskilaw.com
`Client Name: Laura Canter, Appellant
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`2.
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`3.
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`Nature of Disposition below (check all that apply):
`(cid:0) Judgment after bench trial
`(cid:0) Judgment after jury verdict
`(cid:0) Summary judgment
`(cid:0) Default judgment
`(cid:0) Grant/Denial of NRCP 60(b) relief
`(cid:0) Grant/Denial of injunction
`x Dismissal:
`(cid:0) Lack of jurisdiction
`(cid:0) Failure to state a claim
`(cid:0) Failure to prosecute
`x Other (specify): Order Granting Defendants’ Special Motion to
` Dismiss under Anti-SLAPP Laws
`(cid:0) Divorce Decree:
`(cid:0) Original
`(cid:0) Modification
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`Page 2 of 11
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`4.
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`(cid:0) Grant/Denial of declaratory relief
`(cid:0) Review of agency determination
`(cid:0) Other disposition (specify):
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`Does this appeal raise issues concerning any of the following?
`(cid:0) Child Custody
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`(cid:0) Venue
`(cid:0) Termination of parental rights
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`Pending and prior proceedings in this court: List the case name and docket
`5.
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`number of all appeals or original proceedings presently or previously pending
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`before this court which are related to this appeal:
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`None.
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`Pending and prior proceedings in other courts: List the case name,
`6.
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`number and court of all pending and prior proceedings in other courts which are
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`related to this appeal (e.g., bankruptcy, consolidated or bifurcated proceedings) and
`their dates of disposition:
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`None.
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`Nature of the action: Briefly describe the nature of the action and the result
`7.
`below:
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`Appellant Laura Canter and Respondents Lisa LaPlante and Becky Kramer
`own homes in Henderson, Nevada and which are part of Respondent Tuscany
`Master Association, a homeowner association. Canter alleges that LaPlante, who
`was elected as a board member of Tuscany Master Association in or about October
`of 2023, and Kramer, who served on the Communication and Events Committee for
`Tuscany Master Association beginning in or about February of 2023, engaged in
`numerous intentional acts, including without limitation, defamation, libel, slander,
`false light, intentional infliction of emotional distress, malicious prosecution, civil
`conspiracy, concert of action, and threat and harassment in violation of NRS
`116.31184, to cause and causing harm to Canter. Such intentional conduct is alleged
`to have occurred long after Canter had run for the board seat, the election was
`completed, and Canter had already lost. Finally, Canter generally alleges that even
`as to the defamatory statements which were made on an unofficial Facebook page
`and which only form part of the underlying basis for Canter’s defamation, libel,
`slander and false light claims, that Respondents knew such statements were
`knowingly false.
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`Page 3 of 11
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`After Canter filed the Complaint, Respondents filed a Special Motion to
`Dismiss under Anti-SLAPP Laws and in which they generally asserted that all of
`Respondents’ alleged conduct was protected speech in connection with an issue of
`public concern and that all of Canter’s claims should therefore be dismissed in
`constituting “a strategic lawsuit against public participation, SLAPP for short”
`under NRS 41.635 through 41.670. The District Court granted Respondents’ motion
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`as set forth in the Order Granting Defendants’ Special Motion to Dismiss under
`Anti-SLAPP Laws, and which is the order appealed from in this appeal with Canter
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`seeking reversal of such decision.
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`Issues on Appeal: State concisely the principal issue(s) in this appeal:
`8.
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`The primary issue on appeal is whether the district court erred in granting the
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`Respondents/Defendants’ Motion to Dismiss under Anti-SLAPP Laws. More
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`specifically, such sub-issues in this appeal include without limitation, and without
`waiving any other rights to appeal, the following:
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`a. Whether
`the
`granting
`in
`erred
`court
`district
`the
`Respondents/Defendants’ Motion to Dismiss under Nevada’s Anti-Slapp
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`Laws based on the controlling standards of NRS 41.635 to 41.670, inclusive,
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`and this Court’s holdings regarding the application of such statutes.
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`b. Whether all of Respondents/Defendants’ communications, including
`those after the Tuscany Master Association election was completed, were
`“good faith communication in furtherance of the right to petition to free
`speech in direct connection with an issue of public concern” pursuant to NRS
`41.637.
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`c. Whether all eleven of Appellant/Plaintiff’s causes of action should
`have been subject to dismissal pursuant to NRS 41.635 to 41.670.
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`d. Whether Appellant/Plaintiff should have been entitled to conduct
`discovery pursuant to NRS 41.660(4), especially in light of Defendants’
`argument that their statements arose from Tuscany Master Association
`business and, more specifically, from a fake Facebook profile created on an
`unofficial association group page, a profile which is alleged to have been
`created by Defendants themselves and, if confirmed, would eliminate any
`application of the Anti-Slapp statutes.
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`e. Whether
`fair due process
`justice and
`interests of
`the
`in
`Appellant/Plaintiff should have been granted leave to file a second amended
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`Page 4 of 11
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`Complaint in light of the finding that her Verified Amended Complaint
`“lacked detail.”
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`Pending proceedings in this court raising the same or similar issues: If
`9.
`you are aware of any proceedings presently pending before the court which raises
`the same or similar issues raised in this appeal, list the case name and docket
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`numbers and identify the same or similar issue raised:
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`None of which the Appellant is aware.
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`10. Constitutional issues: Does this appeal challenge the constitutionality of a
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`Nevada Statute or ordinance?
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`x No. Continue to #11.
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`(cid:0) Yes:
`a. Identify the Nevada statute or ordinance being challenged:
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`b. Is the State, any State agency, or a State officer or employee a party
`to this appeal in an official capacity?
`(cid:0) Yes (cid:0) No
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`12. Assignment to the Court of Appeals or retention in the Supreme Court:
`Briefly set forth whether the matter is retained by the Supreme Court or
`presumptively assigned to the Court of Appeals under NRAP 17, and cite the
`subparagraph(s) of the Rule under which the matter falls.
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`This case may be presumptively assigned by the Supreme Court to the Court
`of Appeals pursuant to NRAP 17(b)(5) in constituting an appeal from an order
`dismissing a complaint and thereby constituting a final judgment of $250,000 or
`less.
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`//
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`Page 5 of 11
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`11. Other issues.
`a. Does this appeal involve any of the following issues?
`(cid:0) Reversal of well-settled Nevada precedent (identify the case(s))
`(cid:0) An issue arising under the United States or Nevada Constitutions
`(cid:0) A substantial issue of first impression
`(cid:0) An issue of public policy
`(cid:0) An issue where en banc consideration is necessary to maintain uniformity
`of this court’s decisions
`(cid:0) A ballot question
`b. If so, explain:
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`13. Trial. If this action proceeded to trial, how may days did the trial last? N/A.
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`Was it a: (cid:0) bench trial (cid:0) jury trial
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`Judicial disqualification: Do you intend to file a motion to disqualify or
`14.
`have a justice/judge recuse him/herself from participation in this action? See NRAP
`35. If so, which Justice/Judge?
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`No, not applicable.
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`15. Oral argument. Would you object to a submission of this appeal for
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`disposition without oral argument? (cid:0) Yes x No
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`TIMELINESS OF NOTICE OF APPEAL
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`16. Date the written judgment(s) or order(s) appealed from was/were filed in the
`district court:
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`February 12, 2025. Notice of Entry of Order Granting Defendants’ Special
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`Motion to Dismiss under Anti-SLAPP Laws.
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`17. Date written notice of entry of the judgment(s) or order(s) was/were served:
`February 12, 2025.
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`Was service by:
`x Electronic or personal delivery
`(cid:0) Mail
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`18. Were any motions seeking relief under NRCP 50(b), 52(b), 59, or 60 or
`seeking rehearing or reconsideration filed in the district court either before or after
`the notice of appeal was filed? (attach a copy of the motion)
`x No, continue to #19.
`(cid:0) Yes:
`a. Specify the type of motion and the date the motion was filed in the district
`court (check all that apply)
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`(cid:0) NRCP 50(b)
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`(cid:0) NRCP 52(b)
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`(cid:0) NRCP 59
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`(cid:0) NRCP 60
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`(cid:0) Rehearing/Reconsideration
`b. Date the motion was served:
`c. How was the motion served:
`(cid:0) Electronic or personal delivery
`(cid:0) Mail
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`Date filed:
`Date filed:
`Date filed:
`Date filed:
`Date filed:
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`d. Date the written order resolving the motion was filed:
`e. Date written notice of entry of the order resolving the motion was served:
`f. Was service by:
`(cid:0) Electronic or personal delivery
`(cid:0) Mail
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`19. Are there any motions other than those identified in #18 above still pending
`in the district court?
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`(cid:0) Yes. Identify the motion and the date it was filed in the district court:
`x No.
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`20. Date notice of appeal was filed in the district court:
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`March 13, 2025 by Appellant.
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`21. Specify the statute or rule governing the time limit for filing the notice of
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`appeal, e.g., NRAP 4(a) or other:
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`NRAP 4(a)(1).
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`SUBSTANTIVE APPEALABILITY
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`(cid:0) NRAP 3A(b)(2)
`(cid:0) NRAP 3A(b)(4)
`(cid:0) NRAP 3A(b)(6)
`(cid:0) NRAP 3A(b)(8)
`(cid:0) NRAP 3A(b)(10)
`(cid:0) NRAP 3A(b)(12)
`(cid:0) NRS 233B.150
`(cid:0) Other (specify): ______________
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`22. Specify the statute or other authority granting this court jurisdiction to review
`the judgment or order appealed from:
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`a.
`x NRAP 3A(b)(1)
`(cid:0) NRAP 3A(b)(3)
`(cid:0) NRAP 3A(b)(5)
`(cid:0) NRAP 3A(b)(7)
`(cid:0) NRAP 3A(b)(9)
`(cid:0) NRAP 3A(b)(11)
`(cid:0) NRS 38.205
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`(cid:0) NRS 703.376
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`b. Explain how each authority provides a basis for appeal from the judgment
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`or order:
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`NRAP 3(A)(b)(1) provides authority for an appeal from a final judgment,
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`which the Notice of Entry of Order Granting Defendants’ Special Motion to
`Dismiss under Anti-SLAPP Laws constitutes.
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`//
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`Page 7 of 11
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`23. List all parties involved in the action or consolidated actions in the district
`court:
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`a. Parties:
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`Plaintiff/Appellant: Laura Canter
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`Defendants/Respondents: Tuscany Master Association, Lisa LaPlante and
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`Becky Kramer.
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`b. If all parties in the district court are not parties to this appeal, explain in
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`detail why those parties are not involved in this appeal, e.g., formally
`dismissed, not served, or other:
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`All parties in the district court are parties to this appeal.
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`24. Give a brief description (3 to 5 words) of each party’s separate claims,
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`counterclaims, cross-claims or third-party claims, and the date of formal disposition
`of each claim.
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`Complaint:
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`1. Defamation
`2. Libel
`3. Slander
`4. False light
`5.
`Intentional Infliction of Emotional Distress
`6. Malicious Prosecution
`7. Civil Conspiracy
`8. Concert of Action
`9. Threat and Harassment in Violation of NRS 116.31184
`10. Respondeat Superior
`11.
`Injunctive Relief
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`All claims in the Complaint were formally disposed of by the Notice of Entry
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`of Order Granting Defendants’ Special Motion to Dismiss under Anti-SLAPP Laws
`entered on February 12, 2025.
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`25. Did the judgment or order appealed from adjudicate ALL of the claims
`alleged below and the rights and liabilities of ALL of the parties to the action or
`consolidated actions below: x Yes (cid:0) No
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`Page 8 of 11
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`If you answered “No” to question 24, complete the following: N/A.
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`26.
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`If you answered “No” to any part of question 26, explain the basis for
`27.
`seeking appellate review (e.g., order is independently appealable under NRAP
`3A(b)): N/A.
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`28. Attach file-stamped copies of the following documents:
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`•
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`•
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`•
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`•
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`•
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`•
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`See Attached Exhibits:
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`Exhibit 1 – Complaint
`Exhibit 2 – Notice of Entry of Order Granting Defendants’ Special Motion to
`Dismiss under Anti-SLAPP Laws
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`//
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`The latest-filed complaint, counterclaims, cross-claims, and third-party
`claims
`Any motion(s) identified in questions 18 and the order(s) resolving the
`motion(s)
`Orders of NRCP 41(a) dismissals that formally resolve each claim,
`counterclaim, cross-claim and/or third-party claim asserted in the
`action or consolidated action below, even if not at issue on appeal
`All orders that finally disposes of any parties in the action below, even
`if not at issue on appeal
`Any other order challenged on appeal
`Notices of entry for each attached order
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` declare under penalty of perjury that I have read this docketing
`statement, that the information provided in this docketing statement is true
`and complete to the best of my knowledge, information and belief, and that I
`have attached all required documents to this docketing statement.
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`Signed and Dated this 3rd day of April 2025 in Clark County, Nevada.
`
`DZIMINSKI LAW GROUP
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`VERIFICATION
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`By:
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`/s/ Brian R. Dziminski
`Brian R. Dziminski, Esq.
`Nevada Bar No. 008436
`9480 South Eastern Avenue, Suite 220
`Las Vegas, Nevada 89123
`Telephone: (702) 444-3525
`Email: brian@dziminskilaw.com
`Attorneys for Appellant
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`CERTIFICATE OF SERVICE
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`I HEREBY CERTIFY that on the 3rd day of April 2025, I served a true and correct copy
`of the foregoing DOCKETING STATEMENT – CIVIL APPEALS through the court’s
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`electronic filing system to all recipients registered therein, including without limitation:
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`Edward D. Boyack, Esq. and/or Adam J. Breeden, Esq.
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`Boyack Ormer & Murdy
`7432 West Sahara Avenue, Suite 101
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`Las Vegas, Nevada 89117
`Email: ted@boyacklaw.com; adam@boyacklaw.com
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`Attorneys for Defendants
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`Persi J. Mishel, Esq.
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`10161 Park Run Drive, Suite 150
`Las Vegas, Nevada 89145
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`Email: mishelpersi@yahoo.com
`Settlement Judge
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`/s/ Brian R. Dziminski________________
`On behalf of Dziminski Law Group
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`Page 11 of 11
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`EXHIBIT 1
`EXHIBIT 1
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`EXHIBIT 1
`EXHIBIT 1
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`COMP
`ERIC DOBBERSTEIN, ESQ.
`Nevada Bar #3712
`QUOC THAI, ESQ.
`Nevada Bar #16015
`DOBBERSTEIN LAW GROUP
`9480 S. Eastern Ave., Suite 225
`Las Vegas, Nevada 89123
`eric@dobbersteinlaw.com
`qthai@dobbersteinlaw.com
`Tel: 702-430-8900
`Fax: 702-995-7005
`Attorneys for Plaintiff Laura Canter
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`DISTRICT COURT
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`CLARK COUNTY, NEVADA
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`Case No.:
`Dept. No.:
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`COMPLAINT
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`EXEMPT FROM ARBITRATION –
`AMOUNT EXCEEDS $50,000.00
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`LAURA CANTER, an individual,
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`Plaintiff,
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`vs.
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`TUSCANY MASTER ASSOCIATION, a
`non-profit entity, LISA LAPLANTE, an
`individual; LISA LAPLANTE, as Board
`Member of Tuscany Master Association;
`BECKY KRAMER, an individual; BECKY
`KRAMER, as Chairperson of Communication
`of Tuscany Master Association; DOE
`Defendants 1 through 10, inclusive; and ROE
`entities 11-20, inclusive,
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` Defendants.
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`Plaintiff Laura Canter (“Plaintiff”), by and through her attorneys of record, Eric
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`Dobberstein, Esq. and Quoc Thai, Esq., of the Dobberstein Law Group, hereby alleges for her
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`Complaint against Defendants Lisa LaPlante and Becky Kramer as follows:
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`GENERAL ALLEGATIONS
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`1.
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`That at all times relevant herein, Plaintiff Laura Canter is an individual residing in
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`the State of Nevada.
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`2.
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`That upon information and belief, and at all times relevant hereto, Counter-
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`defendant Tuscany Master Association (hereinafter “Defendant HOA”) is a Nevada non-profit
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`Las Vegas, Nevada 89123
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`9480 S. Eastern Ave., Suite 225
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` Dobberstein Law Group
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`Doc ID: ba9cc8eaf45cb7e03eaa4ebf68b0a60472d31c80
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`Case Number: A-24-898599-C
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`Electronically Filed
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`7/29/2024 1:15 PM
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`Steven D. Grierson
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`CLERK OF THE COURT
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`CASE NO: A-24-898599-C
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`Department 14
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`corporation, formed and existing under the laws of the State of Nevada.
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`3.
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`That upon information and belief, and at all times relevant hereto, Defendant Lisa
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`LaPlante (hereinafter “Defendant LaPlante”) is an individual residing in the State of Nevada.
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`4.
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`That upon information and belief, and at all times relevant hereto, Defendant
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`Becky Kramer (hereinafter “Defendant Kramer”) is an individual residing in the State of Nevada.
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`5.
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`That upon information and belief, and at all times relevant hereto, Defendant DOE
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`Individuals 1 through 10, inclusive, and ROE Corporations 11-20, inclusive, are unknown to
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`Plaintiff, who therefore sues said Defendants by such fictitious names. Plaintiff is informed and
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`believes and thereby alleges that each of the Defendants designated herein as DOES 1 through
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`10, inclusive, and Roe Corporations 11- through 20, inclusive, is responsible in some manner for
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`the events and happenings referred to herein, and caused damages proximately to Plaintiff as
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`herein alleged and that Plaintiff will ask leave of this Court to amend this Complaint, to insert the
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`true names and capacities of DOE Individuals when the same have been ascertained and to join
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`such Defendants in this action.
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`6.
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`That at all relevant times, and as alleged more fully herein, each Defendant acted
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`as an agent, servant, employee, co-conspirator, alter-ego and/or joint venturer of the other
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`Defendants, and in doing the things alleged herein acted within the course and scope of such
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`agency, employment, alter-ego and/or in furtherance of the joint venture. Each of the Defendants’
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`acts alleged herein was done with the permission and consent of each of the other Defendants.
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`7.
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`That this Court has original jurisdiction over this action because this is an action
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`JURISDICTION
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`for damages in excess of Fifteen Thousand Dollars ($15,000.00) as a result of Defendants’ acts
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`and omissions that occurred in Clark County, Nevada.
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`8.
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`9.
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`That Plaintiff has complained about events that occurred in Clark County, Nevada.
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`That Defendants are individuals residing in Clark County, Nevada.
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`10.
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`That personal jurisdiction by this Court over Defendant is proper because
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`Las Vegas, Nevada 89123
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`9480 S. Eastern Ave., Suite 225
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` Dobberstein Law Group
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`Defendants are individuals who reside in Clark County, Nevada.
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`Page 2 of 13
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`Doc ID: ba9cc8eaf45cb7e03eaa4ebf68b0a60472d31c80
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`FACTS COMMON TO ALL CAUSES OF ACTION
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`11.
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`Plaintiff repeat, reallege, and incorporate herein by this reference the allegations
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`hereinabove inclusively as though set forth at length and in full herein.
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`12.
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`That Plaintiff is the owner of a personal property located at 531 Via Del Corallo
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`Way, Henderson, NV 89011 (hereinafter “Plaintiff’s Residence”).
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`13.
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`Plaintiff’s Residence is a part of Defendant Tuscany Master Association, a
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`homeowner association.
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`14.
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`That upon information and belief, and at all times relevant hereto, Defendant
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`LaPlante is also an owner of a home within the HOA.
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`15.
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`That upon information and belief, and at all times relevant hereto, Defendant
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`Kramer is a fiancé of Scott Melia, an owner of another home within the HOA.
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`16.
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`That upon information and belief, and at all times relevant hereto, Defendant
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`LaPlante is a board member of the HOA.
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`17.
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`That upon information and belief, and at all times relevant hereto, despite not being
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`a homeowner within the HOA, Defendant Kramer is the Chairperson of Communication within
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`the HOA.
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`18.
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`That upon information and belief, and at all times relevant hereto, The HOA has
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`three unofficial Facebook groups for the homeowners: Original Tuscany Village Residents,
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`Tuscany Village Resident, and PositivelyTUSCANY.
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`19.
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`That upon information and belief, and at all times relevant hereto, Defendant
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`Kramer is an administrator of Tuscany Village Resident, the biggest Facebook Group within the
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`Las Vegas, Nevada 89123
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`9480 S. Eastern Ave., Suite 225
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` Dobberstein Law Group
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`HOA.
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`20.
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`On or about August of 2022, Plaintiff ran for a seat in the board of Chairperson of
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`the HOA.
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`21.
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`That upon information and belief, and at all times relevant hereto, Defendant
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`LaPlante, using her position as a board member of the HOA, and Defendant Kramer, using her
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`position as the Chairperson of Communication and an administrator of the biggest Facebok Group
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`within the HOA, limited Plaintiff’s opportunities to campaign for her election bid on the HOA’s
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`Page 3 of 13
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`Doc ID: ba9cc8eaf45cb7e03eaa4ebf68b0a60472d31c80
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`Facebook groups.
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`22.
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`That upon information and belief, and at all times relevant hereto, Defendants also
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`direct Scott Melia to trespass on other homeowners’ front yard and remove other candidates’
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`election signs, including those belong to Plaintiff.
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`23.
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`Throughout her campaign, Plaintiff also suffer verbal harassment from Defendants
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`both online and in person.
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`Plaintiff ultimately did not win the election.
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`After her failed election bid, Plaintiff removed herself from two out of three of the
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`HOA’s Facebook group, leaving herself only Original Tuscany Village Residents.
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`However, the animosity between Defendants and Plaintiff did not disappear.
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`On all three Facebook group, Defendants continued to harass and post false and
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`damaging statements against Plaintiff and her family, calling her a liar, a criminal, an identity
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`thief,
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`28.
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`Defendants also report Plaintiff to Henderson Police Department for a crime
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`Plaintiff’s did not commit.
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`29.
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`30.
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`Defendants also falsely stated that a warrant was issued for Plaintiff’s arrest.
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`Due to the constant cyber-bullying from Defendants, Plaintiff’s reputation within
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`the community suffered and she faced relentless harassment online as well as in person from
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`Defendants and their associates.
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`Las Vegas, Nevada 89123
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`9480 S. Eastern Ave., Suite 225
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` Dobberstein Law Group
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`FIRST CAUSE OF ACTION
`(Defamation – against all Defendants)
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`31.
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`Plaintiff repeats, realleges, and incorporates herein by this reference the
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`allegations hereinabove inclusively as though set forth at length and in full herein.
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`32.
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`Defendants made at least one false statement of fact to a third-party concerning
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`Plaintiff (each a “Defamatory Statement”).
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`33.
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`Defendants knew each Defamatory Statement was false and that Defendants
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`defamed Plaintiff, acted in reckless disregard of the truth, or acted negligently in failing to
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`ascertain the truth.
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`Page 4 of 13
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`Doc ID: ba9cc8eaf45cb7e03eaa4ebf68b0a60472d31c80
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`34.
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`Each Defamatory Statement constitutes a non-privileged publication to a third-
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`party.
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`35.
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`The publication of each Defamatory Statement was the proximate and legal cause
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`of Plaintiff’s special damages.
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`36.
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`As a direct, proximate, and foreseeable result of Defendants’ acts, Plaintiff has
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`been damaged in excess of $15,000.00, and in an amount to be determined at the time of trial.
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`37.
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`Defendants’ acts were committed with fraud, oppression, and/or malice, entitling
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`Plaintiff to punitive damages pursuant to NRS 42.005 in an amount to be determined at the time
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`of trial.
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`38.
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`As a direct, proximate, and foreseeable result of the Defendants’ act, it has become
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`foreseeable for Plaintiff to secure the services of an attorney, and Plaintiff is entitled to recover
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`fees and costs incurred herein as damages.
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`SECOND CAUSE OF ACTION
`(Libel – against all Defendants)
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`39.
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`Plaintiff repeats, realleges, and incorporates herein by this reference the
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`allegations hereinabove inclusively as though set forth at length and in full herein.
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`40.
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`Defendants made at least one false written statement of fact to a third-party
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`concerning Plaintiff (each a “Defamatory Statement”).
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`41.
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`Defendants knew each Defamatory Statement was false and that Defendants
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`defamed Plaintiff, acted in reckless disregard of the truth, or acted negligently in failing to
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`ascertain the truth.
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`42.
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`Each Defamatory Statement constitutes a non-privileged publication to a third-
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`party.
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`43.
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`The publication of each Defamatory Statement was the proximate and legal cause
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`of Plaintiff’s special damages.
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`44.
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`As a direct, proximate, and foreseeable result of Defendants’ acts, Plaintiff has
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`been damaged in excess of $15,000.00, and in an amount to be determined at the time of trial.
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`45.
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`Defendants’ acts were committed with fraud, oppression, and/or malice, entitling
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`Page 5 of 13
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`Las Vegas, Nevada 89123
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`9480 S. Eastern Ave., Suite 225
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` Dobberstein Law Group
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`Doc ID: ba9cc8eaf45cb7e03eaa4ebf68b0a60472d31c80
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`Plaintiff to punitive damages pursuant to NRS 42.005 in an amount to be determined at the time
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`of trial.
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`46.
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`As a direct, proximate, and foreseeable result of the Defendants’ act, it has become
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`foreseeable for Plaintiff to secure the services of an attorney, and Plaintiff is entitled to recover
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`fees and costs incurred herein as damages.
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`THIRD CAUSE OF ACTION
`(Slander – against all Defendants)
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`47.
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`Plaintiff repeats, realleges, and incorporates herein by this reference the
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`allegations hereinabove inclusively as though set forth at length and in full herein.
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`48.
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`Defendants made at least one false verbal statement of fact to a third-party
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`concerning Plaintiff (each a “Defamatory Statement”).
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`49.
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`Defendants knew each Defamatory Statement was false and that Defendants
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`defamed Plaintiff, acted in reckless disregard of the truth, or acted negligently in failing to
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`ascertain the truth.
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`50.
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`Each Defamatory Statement constitutes a non-privileged publication to a third-
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`party.
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`51.
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`The publication of each Defamatory Statement was the proximate and legal cause
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`of Plaintiff’s special damages.
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`52.
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`As a direct, proximate, and foreseeable result of Defendants’ acts, Plaintiff has
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`been damaged in excess of $15,000.00, and in an amount to be determined at the time of trial.
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`53.
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`Defendants’ acts were committed with fraud, oppression, and/or malice, entitling
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`Plaintiff to punitive damages pursuant to NRS 42.005 in an amount to be determined at the time
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`of trial.
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`54.
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`As a direct, proximate, and foreseeable result of the Defendants’ act, it has become
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`foreseeable for Plaintiff to secure the services of an attorney, and Plaintiff is entitled to recover
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`fees and costs incurred herein as damages.
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`Page 6 of 13
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`Las Vegas, Nevada 89123
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`9480 S. Eastern Ave., Suite 225
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` Dobberstein Law Group
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`Doc ID: ba9cc8eaf45cb7e03eaa4ebf68b0a60472d31c80
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`FOURTH CAUSE OF ACTION
`(False Light – against all Defendants)
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`55.
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`Plaintiff repeats, realleges, and incorporates herein by this reference the
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`allegations hereinabove inclusively as though set forth at length and in full herein.
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`Defendants gave publicity to a matter concerning Plaintiff which place Plaintiff
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`before the public in a false light.
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`Such a false light is highly offensive to a reasonable person.
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`Defendant acted with knowledge of or acted in reckless disregard as to the falsity
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`of the publicized matter and the false light in which the other would be placed.
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`59.
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`As a direct, proximate, and foreseeable result of Defendants’ acts, Plaintiff has
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`been damaged in excess of $15,000.00,