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Ethics Commission Report

The Nevada Commission on Ethics held a public meeting to consider motions for summary judgment in two consolidated ethics complaints against Joseph M. Lombardo, Sheriff of Clark County, Nevada. The Commission interviewed and selected Brandi Jensen to fill its open Commission Counsel position. It also welcomed Wendy Pfaff as the new Senior Legal Researcher. Under agenda item 5, the Commission heard motions for summary judgment in Ethics Complaint Case Nos. 21-062C and 21-082C against Sheriff Lombardo. Supporting documents were included in hearing books. The Commission took the matters under submission after presentations by the parties.

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Jessica Hill
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0% found this document useful (0 votes)
3K views456 pages

Ethics Commission Report

The Nevada Commission on Ethics held a public meeting to consider motions for summary judgment in two consolidated ethics complaints against Joseph M. Lombardo, Sheriff of Clark County, Nevada. The Commission interviewed and selected Brandi Jensen to fill its open Commission Counsel position. It also welcomed Wendy Pfaff as the new Senior Legal Researcher. Under agenda item 5, the Commission heard motions for summary judgment in Ethics Complaint Case Nos. 21-062C and 21-082C against Sheriff Lombardo. Supporting documents were included in hearing books. The Commission took the matters under submission after presentations by the parties.

Uploaded by

Jessica Hill
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
You are on page 1/ 456

Agenda Item 3

STATE OF NEVADA
COMMISSION ON ETHICS
http://ethics.nv.gov

MINUTES
of the meeting of the
NEVADA COMMISSION ON ETHICS

The Commission on Ethics held a public meeting on


Tuesday, May 30, 2023, at 8:30 a.m.
at the following location:

State Bar of Nevada


9456 Double R Boulevard, Suite B
Reno, NV 89521

Zoom Meeting Information


https://us06web.zoom.us/j/83154789050?pwd=NEtzdUh2UDNCalVXZHJIVEV6cWJIQT09
Zoom Meeting Telephone Number: 720-707-2699
Meeting ID: 831 5478 9050
Passcode: 578791

These minutes constitute a summary of the above proceedings of the Nevada


Commission on Ethics. A recording of the meeting is available for public inspection at the
Commission’s office and on the Commission’s YouTube channel.

1. Call to Order and Roll Call.

Chair Kim Wallin, CPA, CMA, CFM appeared in-person at the State Bar of Nevada office
in Reno and called the meeting to order at 8:35 a.m. Vice-Chair Brian Duffrin and Commissioners
Barbara Gruenewald, Esq. and Thoran Towler, Esq. also appeared in-person. Commissioner
Teresa Lowry, Esq. appeared via Zoom videoconference. Commissioners James Oscarson and
Amanda Yen, Esq. were excused. Present for Commission staff in Reno were Executive Director
Ross E. Armstrong, Esq., Associate Counsel Elizabeth J. Bassett, Esq., Senior Legal Researcher
Wendy Pfaff and Executive Assistant Kari Pedroza. Deputy Attorney General Laena St-Jules,
Esq. also appeared in person in Reno.

2. Public Comment.

There was no public comment.

3. Approval of Minutes of the May 17, 2023, Personnel Subcommittee Meeting.

Chair Wallin stated that only she and Vice-Chair Duffrin were present for the May 17, 2023
Personnel Subcommittee Meeting.

Vice-Chair Duffrin moved to approve the May 17, 2023, Personnel Subcommittee Meeting
Minutes as presented. Chair Wallin seconded the motion. The Motion was put to a vote and
carried as follows:

Chair Wallin: Aye.


Vice-Chair Duffrin: Aye.

Page 1 of 3
4. Approval of Minutes of the May 17, 2023, Commission Meeting.

Chair Wallin stated that all Commissioners were present for the May 17 Commission
Meeting, except for Commissioners Oscarson and Towler who were excused and therefore
precluded from participating in this item.

Commissioner Gruenewald moved to approve the May 17, 2023, Commission Meeting
Minutes as presented. Commissioner Lowry seconded the motion. The Motion was put to a vote
and carried as follows:

Chair Wallin: Aye.


Vice-Chair Duffrin: Aye.
Commissioner Gruenewald: Aye.
Commissioner Lowry: Aye.
Commissioner Towler: Abstain.

5. Interviews and consideration of candidates for the Commission Counsel position, and
possible appointment of an applicant to the Commission Counsel position. The
Commission may consider the character and professional competence of the following
candidates for the Commission Counsel position:
1.) Brandi Jensen
2.) Chris Davis

Chair Wallin introduced the agenda item stating that the Commission would be conducting
interviews of each of the two Commission Counsel applicants, the candidates will present their
presentations to the Commission and after the interviews and presentations the Commission
would deliberate regarding its selection of the new Commission Counsel.

The Commission then interviewed the two candidates separately in the following order:
Brandi Jensen and Chris Davis. The Commission took a twenty-minute break between interviews.

Chair Wallin expressed her gratitude to each of the applicants.

Following a ten-minute break, the Commission deliberated publicly regarding its


impression of the candidates, mentioning each applicant’s perceived assets and what they might
bring to the Commission staff team.

Commissioner Lowry extended her gratitude to the Personnel Subcommittee for its efforts
in initial interviews with the candidates. She shared her preference for Brandi Jensen as the
appointee to the Commission Counsel position.

Commissioner Gruenewald agreed with Commissioner Lowry.

Commissioner Towler echoed Commissioner Lowry’s appreciation of the Personnel


Subcommittee and noted that Ms. Jensen was his choice as well.

Vice-Chair Duffrin moved that the Commission extend an offer of the Commission Counsel
position to Brandi Jensen, Esq. contingent upon the background and reference check results.
Commissioner Gruenewald seconded the motion. The motion was put to a vote and carried
unanimously.

6. Commissioner Comments on matters including, without limitation, identification of future


agenda items, upcoming meeting dates and meeting procedures. No action will be taken
under this agenda item.

Chair Wallin welcomed Wendy Pfaff to the Commission’s staff as the new Senior Legal
Researcher.

Page 2 of 3
7. Public Comment.

There was no public comment.

8. Adjournment.

Commissioner Towler made a motion to adjourn the public meeting. Commissioner


Gruenewald seconded the motion. The Motion was put to a vote and carried unanimously.

The meeting was adjourned at 11:41 a.m.

Minutes prepared by: Minutes approved June 13, 2023:

/s/ Kari Pedroza ________________________________


Kari Pedroza Kim Wallin, CPA, CMA, CFM
Executive Assistant Chair

/s/ Ross Armstrong ________________________________


Ross Armstrong, Esq. Brian Duffrin
Executive Director Vice-Chair

Page 3 of 3
Agenda Item 4
In re Joseph M. Lombardo, Ethics Complaint
Sheriff of Clark County, Case Nos. 21-062C, 21-082C
State of Nevada, Confidential

Subject. /

MOTIONS FOR SUMMARY JUDGMENT


Hearing Book Index
TAB ITEMS Bates No.
Complaint Documents:
• Order Initiating Complaint, Accepting Jurisdiction and Directing Investigation -
HB 00001
Ethics Case No. 21-062C
• Complaint in Ethics Case No. 21-062C HB 00003
1 • Complaint in Ethics Case No. 21-082C HB 00007
• Order on Jurisdiction and Investigation – Ethics Case No. 21-082C HB 00017
• Order on Consolidation – Case Nos. 21-062C and 21-082C HB 00019
• Stipulated Facts and Documents HB 00021
Pleadings Related to Motions for Summary Judgment:
• Executive Director’s (“ED”) Motion for Summary Judgment (“MSJ”) HB 00198
o EXHIBITS HB 00220
• Subject’s Response to ED MSJ HB 00238
2 o EXHIBITS HB 00246
• Subject’s MSJ HB 00253
o EXHIBITS HB 00275
• ED’s Opposition to Subject’s MSJ HB 00303
o EXHIBITS HB 00316
3 Notice of Hearing HB 00421

Waivers:
4 • Waiver of Open Meeting Law Notice HB 00423
• Waiver of Adjudicatory Hearing 60-day requirement HB 00424
STATE OF NEVADA

BEFORE THE NEVADA COMMISSION ON ETHICS

In re Joseph M. Lombardo, Ethics Complaint


Sheriff of Clark County, Case No. 21-062C
State of Nevada, Confidential

Subject. /

ORDER INITIATING ETHICS COMPLAINT,


ACCEPTING JURISDICTION, AND DIRECTING AN INVESTIGATION
Pursuant to NRS 281A.280 and NRS 281A.715

The Commission has jurisdiction to investigate and take appropriate action


regarding an alleged violation of NRS Chapter 281A, the Ethics in Government Law
(“Ethics Law”) by a public officer or employee or former public officer or employee in any
proceeding commenced by an ethics complaint, which is filed with the Commission or
initiated by the Commission on its own motion, within 2 years after the alleged violation
or reasonable discovery of the alleged violation in accordance with NRS 281A.710.

IT IS ORDERED:

The Commission hereby initiates an Ethics Complaint against Joseph M.


Lombardo, Sheriff of Clark County, and candidate for Governor, and directs the Executive
Director to investigate potential violations of the following statutes:

NRS 281A.400(2) Using his public position to secure or grant unwarranted


privileges, preferences or advantages to benefit himself, any
business entity in which he has a significant pecuniary
interest, or any person to whom he has a commitment in a
private capacity.

NRS 281A.400(7) Using governmental time, property or equipment or other


facility to benefit his significant personal or pecuniary interest
or that of a person to whom he is a commitment in a private
capacity.

Further, the Commission directs the Executive Director to serve this order with a
Notice of Complaint and Investigation as required by NRS 281A.720.

DATED this 15th day of September, 2021.

NEVADA COMMISSION ON ETHICS

/s/ Kim Wallin


Kim Wallin, CPA, CMA, CFM
Commission Chair

Order Initiating Ethics Complaint, Accepting Jurisdiction, and Directing Investigation


Page 1 of 2

HB 00001
CERTIFICATE OF MAILING

I certify that I am an employee of the Nevada Commission on Ethics and that on


this day in Carson City, Nevada, I deposited for mailing, via U.S. Postal Service, certified
mail, through the State of Nevada mailroom, a true and correct copy of the foregoing
Order Initiating Ethics Complaint, Accepting Jurisdiction, and Directing
Investigation, addressed as follows:

Joseph M. Lombardo Cert. Mail No.: 9171 9690 0935 0037 6363 61
Sheriff of Clark County
Las Vegas Metropolitan Police
Department
400 S. Martin L. King Blvd.
Las Vegas, NV 89106

Dated: 916/21
Employee, Nevada Commission on Ethics

Order Initiating Ethics Complaint, Accepting Jurisdiction, and Directing Investigation


Page 2 of 2

HB 00002
21-062

Submitted Electronically on 09-01-2021

NEVADA COMMISSION ON ETHICS


ETHICS COMPLAINT
NRS 281A.700 to 281A.790

1. SUBJECT OF THE COMPLAINT - person you allege violated provisions of NRS Chapter 281A, the NevadaEthics in Government Law.
(Please use a separate form for each individual.)
Title of Public
Subject Name: Lombardo, Joseph Office: Sheriff
(Last, First) (Position)
Public Entity:
(Name of the entity
employing this Las Vegas Metropolitan Police Department
position)
400 South Martin Luther City, State,
Address: Zip Code: Las Vegas, NV 89106
King, Jr. Boulevard
Work: Other (home/cell):
Telephone: 702-828- Email:
3111
2. Describe the alleged conduct of the public officer or employee (subject) that you believe violated NRS Chapter281A. (Include specific
facts and circumstances to support your allegation: times, places, and the nameand position of each person involved.)

On or about June 28, 2021, Clark County Sheriff Joseph Lombardo


("Lombardo") announced his candidacy for Governor of Nevada at a
public event held at Rancho High School in Las Vegas, Nevada. The
homepage for Lombardo's campaign website,
www.joelombardofornv.com, contains numerous photos of Lombardo
wearing his Sheriff's uniform, including his Sheriff's badge, firearm,
handcuffs and other items typically worn on the belt of police officers.
The website also contains numerous photos of Lombardo in a shirt and
tie, but also wearing his badge and firearm. There are also images of a
protective vest with a patch stating "Police" across the front and with a
Metro badge, and images of Lombardo picking up and holding these
items. Lombardo's website also links to a video hosted by video hosting,
sharing and services platform Vimeo, https://vimeo.com/user143013087.
In the video Lombardo is pictured wearing his Sheriff's uniform, badge,
firearm and handling the protective vest and Sheriff's badge referenced
above. The Facebook page "Joe Lombardo for Governor,"
https://m.facebook.com/JoeLombardoNV/, contains a profile picture
showing Lombardo in his Sheriff's uniform. The page also contains
photos of Lombardo in uniform which are similar or identical to those
shown on his campaign website. The Facebook page likewise offers the
video hosted by Vimeo that is linked to from his campaign website. The
Facebook page contains a video of Lombardo announcing his campaign
Revised 04/03/2019 /PDI (GC) Ethics Complaint HB 00003
Nevada Commission on Ethics Page 1 of 4
on Fox News while wearing a suit with a small Sheriff's badge on his left
lapel (https://youtu.be/WqbR2VIp9fI).
3. Is the alleged conduct currently pending before another administrative, law enforcement or judicial body? If yes,describe:

No

4. NRS Chapter 281A requires public officers and employees to hold public office as a public trust and avoid conflicts between public duties and
private interests. (NRS 281A.020) What provisions of NRS Chapter 281A are relevant to the conduct alleged? Please check all that apply.

Seeking or accepting any gift, service, favor, employment, engagement, emolument or economic
opportunity for himself or person to whom he has a commitment in a private capacity which would tend
NRS 281A.400(1)
improperly to influence a reasonable person in his position to depart from the faithful and impartial
discharge of his public duties.
Using his position in government to secure or grant unwarranted privileges, preferences, exemptions or
NRS 281A.400(2) advantages for himself, any business entity in which he has a significant pecuniary interest, or any person to
whom he has a commitment in a private capacity.
Participating as an agent of government in the negotiation or execution of a contract between the
NRS 281A.400(3) government and himself, any business entity in which he has a significant pecuniary interest or any person
to whom he has a commitment in a private capacity.
Accepting any salary, retainer, augmentation, expense allowance or other compensation from any private
NRS 281A.400(4) source for himself or any person to whom he has a commitment in a private capacity for the performance
of his duties as a public officer or employee.
Acquiring, through his public duties or relationships, any information which by law or practice is not at the
NRS 281A.400(5) time available to people generally, and using the information to further the pecuniary interests of himself or
any other person or business entity.
Suppressing any governmental report or other document because it might tend to affect unfavorably his
NRS 281A.400(6)
pecuniary interests or the interests of any person to whom he has a commitment in a private capacity.
Using governmental time, property, equipment or other facility to benefit his significant personal or
NRS 281A.400(7) pecuniary interest, or any person to whom he has a commitment in a private capacity. (Some exceptions
apply).
A State Legislator using governmental time, property, equipment or other facility for a nongovernmental
purpose or for the private benefit of himself or any other person, or requiring or authorizing a legislative
NRS 281A.400(8)
employee, while on duty, to perform personal services or assist in a private activity. (Some exceptions
apply).
Attempting to benefit his personal or pecuniary interest or the interests of any person to whom he has a
NRS 281A.400(9)
commitment in a privatecapacity through the influence of a subordinate.
Seeking other employment or contracts for himself or any person to whom he has a commitment in a
NRS 281A.400(10)
private capacity through the use of his official position.
Representing or counseling a private person for compensation on an issue pending before a public agency
while employed, or within 1 year after leaving the service of a public agency, including before any state
agency of the Executive or Legislative Department. (State and local legislators and part-time public
NRS 281A.410
officers and employees may represent/counsel private persons before agencies they do not serve, except
local legislators may not represent/counsel private persons before other local agencies within the same
county.)
Failing to sufficiently disclose his acceptance of a gift or loan, pecuniary interest, commitment in a private
capacity to the interest of another person or the nature of any representatiation or counseling provided to a
NRS 281A.420(1)
private person for compensation before another agency in the preceeding year that is reasonably affected
by an official matter.
Failing to abstain from acting on an official matter which is materially affected by his acceptance of a gift or
NRS 281A.420(3)
loan, pecuniary interest, or commitment in a private capacity to the interest of another person.
Bidding on or entering into a government contract in which he has a significant pecuniary interest. (Some
NRS 281A.430
exceptions apply).
NRS 281A.500 Failing to file or timely file a Nevada Acknowledgment of Ethical Standards for Public Officers form.

Revised 04/03/2019 /PDI (GC) Ethics Complaint HB 00004


Nevada Commission on Ethics Page 2 of 4
NRS 281A.510 Accepting or receiving an improper honorarium.
Requesting or otherwise causing a governmental entity to incur an expense or make an expenditure to
NRS 281A.520
support or oppose a ballot question or candidate during the relevant timeframe.
Negotiating or accepting employment from a business or industry regulated by or contracted with former
NRS 281A.550 public agency within one year after leaving the service of the agency. (Failing to honor the applicable
"cooling off" period after leaving public service).

*Pursuant to NRS 281A.065, a public officer or employee has a commitment in a private capacity to the following persons:

1. Spouse; domestic partner


2. Household member
3. Family member within 3rd degree of consanguinity/affinity.
4. Employer or spouses/domestic partner/houshold member's employer
5. Substantial and continuing business relationships, i.e. partner, associate, or business entity.
6. Substantially similar relationships to those listed above, including close, personal relationships akin to family and fiduciary relationshipsto
business entities.

5. YOU MUST SUBMIT EVIDENCE TO SUPPORT YOUR ALLEGATIONS. (NRS 281A.710 through 281A.715.)
Attach all documents or items you believe support your allegations, including witness statements, public or private records, audio or
visual recordings, documents, exhibits, concrete objects, or other forms of proof.

6. Witnesses: Identify all persons who have knowledge of the facts and circumstances you have described, as well as the nature of the
testimony the person will provide.

Name and Title: Ryan Erwin


City, State,
Address:
Zip:
Las Vegas, NV 89147
Work: Other (home/cell): Email:
Telephone:
702-240-2001
Mr. Erwin is the Campaign Strategist for the Lombardo campaign. The contact information above
Nature of Testimony:
is for Mr. Erwin's business, RedRock [sic] Strategies.

Name and Title: Mark Hutchison


City, State,
Address:
Zip:
Las Vegas, NV 89145
Work: Other (home/cell): Email: mhutchison@hutchlegal.com
Telephone:
702-385-2500
Mr. Hutchison is the Chairman of the Lombardo campaign. The contact information above is for
Nature of Testimony:
Mr. Hutchison's law office, Hutchison & Steffen.
7. Requesters Information:
Your Name: Through Executive Director David R. Hall Nevada Commission on Ethics
Your Address: City, State, Carson City, NV 89703
Zip:
Day: Evening: Email: davidhall@ethics.nv.gov
Your Telephone:
775-687-5469
Your identity as the Requester will be provided to the Subject if the Commission accepts jurisdiction of this matter, unless:
Pursuant to NRS 281A.750, I request that my identity as the requester of this Ethics Complaint remain confidential because (please check
appropriate box):

I am a public officer or employee who works for the same public body, agency or employer as the subject of this Ethics
Complaint. Provide evidence in the text box below, or as an attachment, of your employment with the same public body, agency or
employer.
OR
I can show a reasonable likelihood that disclosure of my identity will subject me or a member of my house-hold to a bona fide
threat of physical force or violence. Describe in the text box below, or in an attachment, the facts and circumstances that support a
Revised 04/03/2019 /PDI (GC) Ethics Complaint HB 00005
Nevada Commission on Ethics Page 3 of 4
reasonable likelihood of a bona fide threat of physical force or violence.

A copy of this Complaint will be provided to the Subject. If your request for confidentiality is approved by the Commission, the
Complaint will be redacted to protect your identity as the Requester. The Commission may decline to maintain the confidentiality of
your identity as the Requester for lack of sufficient evidence of your employment status with the same public body, agency or
employer, or proof of a bona fide threat of physical force or violence.
If the Commission declines to maintain my confidentiality, I wish to:
Withdraw my Complaint, OR
Submit the Complaint understanding that the Subject will know my identity as the Requester.
By my signature below, I affirm that the facts set forth in this document and all of its attachments are true and correct to the best of
my knowledge and belief. I am willing to provide sworn testimony regarding these allegations. I acknowledge that this Ethics
Complaint, the materials submitted in support of the allegations, and the Commission’s investigation are confidential unless and
until the Commission’s Review Panel renders a determination. Certain Commission procedings and materials, including the
Investigatory File remain confidential pursuant to NRS 281A.750 through 281A.760.

Date: 09-01-2021
Signature:
Print Name: David R. Hall

You may file a Complaint using the Commission’s online form submission at ethics.nv.gov (Preferred) or
You must submit this form bearing your signature to the Executive Director via:
delivery/mail to Nevada Commission on Ethics, 704 W. Nye Lane, Suite 204,
Carson City, Nevada, 89703,
email to NCOE@ethics.nv.gov, or fax to (775) 687-1279

Revised 04/03/2019 /PDI (GC) Ethics Complaint HB 00006


Nevada Commission on Ethics Page 4 of 4
21-082C

HB 00007
HB 00008
HB 00009
HB 00010
October 21st, 2021

Chairwoman Kim Wallin


Nevada Commission on Ethics
704 W. Nye Lane, Suite 204
Carson City, NV 89703

Re: Complaint Regarding Sheriff Joseph Lombardo

Dear Chairwoman Wallin:

Pursuant to Nev. Rev. Stat. Ann. 281A.400(7), this letter and the accompanying Elections
Complaint Form serve as a written complaint against Sheriff Joseph Lombardo and his campaign,
Lombardo for Governor. Despite serving as the chief law enforcement officer of Clark County,
Nevada, Sheriff Lombardo has repeatedly violated state law by using official government
resources to promote his candidacy for governor. Sheriff Lombardo’s actions clearly violate the
law: the Nevada Commission on Ethics (the “Commission”) has previously considered identical
conduct by other state officials, and found it to be in violation of the law. We request an immediate
investigation into Sheriff Lombardo’s violations, and ask the Commission to take swift remedial
action to prevent the Sheriff from continuing to exploit government resources for his personal gain.

Factual Background

Joseph Lombardo is the Sheriff of Clark County, Nevada, and the Sergeant at Arms of the Nevada
Sheriffs’ and Chiefs’ Association.1 Sheriff Lombardo is also a candidate for Governor of Nevada,
and his campaign committee is Lombardo for Governor (the “Campaign”).2

Sheriff Lombardo frequently uses official law enforcement resources in his Campaign materials
and advertisements. For example, in the Campaign video announcing his candidacy, Sheriff
Lombardo appears in his official uniform and badge, carrying what appears to be his official
service weapon. 3 The video also includes other footage of what appears to be Sheriff Lombardo’s
official police vest, badge, and holstered gun.4 Similarly, the Campaign’s website and social media
pages on Facebook, Twitter, Instagram, Flickr, YouTube, and Vimeo, include numerous
photographs or footage of Sherriff Lombardo wearing his official uniform and badge.5

1
Las Vegas Metro. Police Dep’t., Sheriff Joseph Lombardo, https://www.lvmpd.com/en-us/Pages/officeofthesheriff-
SheriffJosephLombardo.aspx; Nev. Sheriffs’ and Chiefs’ Ass’n., About Us, https://nvsca.com/.
2
Joe Lombardo for Governor, https://www.joelombardofornv.com/.
3
Lombardo for Governor - Protect, Vimeo (June 28, 2021), https://vimeo.com/568396552; see Appendix.
4
Id.
5
Joe Lombardo for Governor, https://www.joelombardofornv.com/; Joe Lombardo for Nevada, Facebook,
https://www.facebook.com/JoeLombardoNV/; Joe Lombardo (@JoeLombardoNV), Twitter,
https://twitter.com/JoeLombardoNV; Joe Lombardo (@JoeLombardoNV), Instagram,
www.instagram.com/JoeLombardoNV; Joe Lombardo (JoeLombardoforNV), Flickr,
https://www.flickr.com/photos/193251823@N03/; Joe Lombardo for Nevada, YouTube
https://www.youtube.com/channel/UCQ52JaFDe77QrU5OTMWiemw; Lombardo for Governor - Protect, Vimeo
(June 28, 2021), https://vimeo.com/568396552.

HB 00011
Legal Analysis

In clear violation of Nevada law, Sheriff Lombardo has repeatedly misused official government
resources to promote his Campaign.

State law prohibits public officers like Sheriff Lombardo from “us[ing] governmental time,
property, equipment or other facility to benefit a significant personal or pecuniary interest of the
public officer.”6 The Commission has repeatedly found that this prohibition bars a law
enforcement officer from using government property, including “physical accouterments” of the
office such as a uniform and badge, to promote a political campaign.7 Specifically, law
enforcement officers who are also candidates may not wear their official badges or uniforms in
their campaign materials because it creates the appearance of a government endorsement and
provides an unfair advantage to the candidate at government cost.8

In October 2019, the Commission sent a letter to the Nevada Sheriffs’ and Chiefs’ Association, of
which Sheriff Lombardo is the Sergeant at Arms, to remind officers that “no state or local
government law enforcement official, including an elected, incumbent official, may wear his/her
uniform, badge or other physical accouterment of office . . . in support or opposition of a political
campaign, including his/her own campaign or as an endorsement.”9

Despite the Commission’s clear reminder, Sheriff Lombardo has frequently worn his official
uniform and badge, and what appears to be his service weapon, in his Campaign materials to
promote his Campaign. Footage of Sheriff Lombardo in his official uniform and badge features
prominently on the homepage of his Campaign website, and is promoted extensively throughout
his Campaign’s social media pages. Far from being isolated or one-off incidents, Sheriff
Lombardo’s repeated violations constitute a pattern of flouting the law in pursuit of his own
personal advancement.

Public office is a public trust to be held for the sole benefit of the people. 10 This responsibility is
all the more crucial where the office at issue is of the sheriff, who is entrusted with upholding the
law. But rather than upholding the law and the integrity of his office, Sheriff Lombardo has
flagrantly violated the law and exploited government resources for his own personal gain to
advance his political campaign. We urge the Commission to take action to uphold the public trust,
and make clear that no one, not even the Sheriff, is above the law.

6
Nev. Rev. Stat. Ann. § 281A.400(7). A sheriff’s office uniform and badge, which signify the power and prestige of
the office, are considered governmental property or equipment under this statute, and a public officer has a
significant personal and pecuniary interest in obtaining or maintaining an elected paid position. See In re Antinoro,
Comm’n Op. No. 18-031C, 18-052C (Nev. 2019).
7
See In re Kirkland, Comm’n Op. No. 98-41 (Nev. 1998) (finding that Nevada law prohibited a sheriff from
appearing in an official uniform and badge in a political ad to endorse another candidate); In re Kuzanek, Comm’n
Op. No. 14-61C (Nev. 2014) (concluding that an undersheriff violated Nevada law when he appeared in full uniform
and used his badge in campaign photos); In re Antinoro, Comm’n Op. No. 18-031C, 18-052C (Nev. 2019) (holding
that an elected sheriff’s use of his official uniform and badge in the course of supporting his own campaign for re-
election violated state law).
8
Id.
9
Letter from Yvonne Nevarez-Goodson, Exec. Director, Nev. Comm’n on Ethics, to Eric Spratley, Exec. Director,
Nev. Sheriffs’ and Chiefs’ Assoc. (Oct. 7, 2019).
10
Nev. Rev. Stat. Ann. § 281A.020(1)(a).

HB 00012
Sincerely,

_______________________________

Matthew DeFalco
DeFalco.Nevada@gmail.com
702-845-4431

Date: October 21st, 2021

HB 00013
Appendix

Campaign Website:

HB 00014
Campaign Website and Vimeo:

Campaign Flickr

HB 00015
Campaign Facebook

Campaign Announcement Video

HB 00016
STATE OF NEVADA

BEFORE THE NEVADA COMMISSION ON ETHICS

In re Joseph M. Lombardo, Sheriff Ethics Complaint


of Clark County, State of Nevada, Case No. 21-082C
Confidential
Subject. /

ORDER ON JURISDICTION AND INVESTIGATION


Pursuant to NRS 281A.715

The Nevada Commission on Ethics (“Commission”) received an Ethics Complaint


(“Complaint”) on October 21, 2021 regarding Joseph M. Lombardo (“Subject”). On November
18, 2021, pursuant to the requirements of the Nevada Ethics in Government Law set forth in
NRS Chapter 281A (“Ethics Law”) and NAC 281A.405, the Commission conducted its
jurisdictional and evidentiary review of the record, including the Ethics Complaint, supporting
evidence and the recommendation of the Executive Director. 1

IT IS HEREBY ORDERED:

The Commission accepts jurisdiction of this Ethics Complaint and directs the Executive
Director to investigate the Subject’s alleged violation of the following provision of the Ethics Law
for using official law enforcement equipment and resources for his campaign for Governor of
Nevada:

NRS 281A.400(7) Using governmental time, property or equipment or other


facility to benefit his significant personal or pecuniary interest
or that of a person to whom he has a commitment in a private
capacity.

The Commission further directs the Executive Director to serve this order with a Notice of
Complaint and Investigation as required by NRS 281A.720.

DATED this 18th day of November, 2021.

NEVADA COMMISSION ON ETHICS

/s/ Kim Wallin


Kim Wallin, CPA, CMA, CFM
Commission Chair

1 The following Commissioners participated in approving this jurisdictional review: Chair Wallin, Vice-Chair Duffrin

and Commissioners Gruenewald, Lowry, Towler and Yen. Commissioner Sheets voted against accepting
jurisdiction on the matter.
Order on Jurisdiction and Investigation
Page 1 of 2

HB 00017
CERTIFICATE OF MAILING

I certify that I am an employee of the Nevada Commission on Ethics and that on this day
in Carson City, Nevada, I deposited for mailing, via U.S. Postal Service, certified mail, through
the State of Nevada mailroom, a true and correct copy of the foregoing Order on Jurisdiction
and Investigation, addressed as follows:

Joseph M. Lombardo Cert. Mail No.: 9171 9690 0935 0037 6364 84
Sheriff of Clark County
Las Vegas Metropolitan Police
Department
400 S. Martin L. King Blvd.
Las Vegas, NV 89106

Dated: 11/18/21
Employee, Nevada Commission on Ethics

Order on Jurisdiction and Investigation


Page 2 of 2

HB 00018
STATE OF NEVADA

BEFORE THE NEVADA COMMISSION ON ETHICS

In re Joseph M. Lombardo, Sheriff Ethics Complaints


of Clark County, State of Nevada, Consolidated Case Nos.
21-062C and 21-082C
Subject. / Confidential

ORDER ON CONSOLIDATION
Pursuant to NAC 281A.260

The Nevada Commission on Ethics (“Commission”) received Ethics Complaint Nos. 21-
062C and 21-082C (“Complaints”), regarding Joseph M. Lombardo (“Subject”). Pursuant to the
requirements of the Nevada Ethics in Government Law set forth in NRS Chapter 281A (“Ethics
Law”) and NAC 281A.405, the Commission issued separate Orders in each Complaint case
accepting jurisdiction and directing the Executive Director to investigate the alleged violations
implicating NRS 281A.400(2) and (7) in Case No. 21-062C and NRS 281A.400(7) in Case No.
21-082C.

The Commission finds that there is good cause to consolidate the Complaints for all future
proceedings because they share common facts and issues. Therefore, the Commission hereby
consolidates Ethics Complaint Nos. 21-062C and 21-082C. 1

IT IS SO ORDERED.

DATED this 18th day of November, 2021.

NEVADA COMMISSION ON ETHICS

/s/ Kim Wallin


Kim Wallin, CPA, CMA, CFM
Commission Chair

1The Commission or the Chair may consolidate, in whole or in part, two or more ethics complaints if the Commission
or the Chair determines that the ethics complaints, share common facts and issues. NAC 281A.260.

Order on Consolidation
Page 1 of 2

HB 00019
CERTIFICATE OF MAILING

I certify that I am an employee of the Nevada Commission on Ethics and that on this day
in Carson City, Nevada, I deposited for mailing, via U.S. Postal Service, certified mail, return
receipt requested, through the State of Nevada mailroom, a true and correct copy of the
foregoing Order on Consolidation, addressed as follows:

Joseph M. Lombardo Cert. Mail No.: 9171 9690 0935 0037 6364 84
Sheriff of Clark County
Las Vegas Metropolitan
Police Department
400 S. Martin L. King Blvd.
Las Vegas, NV 89106

Dated: 11/18/21
Employee, Nevada Commission on Ethics

Order on Consolidation
Page 2 of 2

HB 00020
1

3 STATE OF NEVADA

4 BEFORE THE COMMISSION ON ETHICS


5

6 In re Joseph M. Lombardo,
Sheriff of Clark County, Consolidated Ethics Complaint
7 State of Nevada, Case Nos. 21-062C, 21-082C
8
Subject /
9

10
STIPULATED FACTS AND DOCUMENTS
11
Ross E. Armstrong, Esq., Executive Director of the Nevada Commission on
12 Ethics (“Commission”), through the Commission’s Associate Counsel, Elizabeth J.
13 Bassett, Esq., and Joseph M. Lombardo, through his attorney Samuel R. Mirkovich,
14 Esq. of the law firm Campbell & Williams, hereby jointly submit the following Stipulated
15 Facts and Documents.

16 STATEMENT OF STIPULATED FACTS

17 1. Joseph M. Lombardo (“Lombardo”) was the elected Sheriff of the Las Vegas

18
Metropolitan Police Department (“LVMPD”) in 2014 and 2018.
2. Sheriff is a public officer as defined in NRS 281A.160. Sheriff is the only
19
uniformed public office in the State of Nevada. A sheriff is never “off duty,”
20
and must always be required to respond to a law enforcement emergency.
21
3. Clark County is a political subdivision as defined in NRS 281A.145.
22
4. The LVMPD is a local agency as defined in NRS 281A.119. LVMPD
23 receives funding from the federal government of the United States of
24 America.
25 5. LVMPD’s Policy Manual is publicly available. See Exhibit “35.” Section
26 2/114.00 sets forth LVMPD’s Political Activities Policy and allows LVMPD

27 employees to appear in uniform for their own campaign photographs since

28
their doing so “does not constitute an endorsement.”

Page 1 of 8

HB 00021
1 6. Lombardo announced his candidacy for the office of Governor of Nevada on
2 or about June 28, 2021.
3 7. Lombardo campaigned as a candidate for the office of Governor of Nevada

4
from on or about June 28, 2021 to on or about election day, November 8,
2022.
5
8. Because the Nevada Legislature declined to make the position of sheriff a
6
“resign to run” position, Lombardo remained a public officer as defined in
7
NRS 281A.160 throughout his gubernatorial campaign.
8
9. The video located at https://youtu.be/9E-NjOsJKN8, Exhibit 1, features
9
Lombardo announcing his candidacy for the office of Governor of Nevada
10 on June 28, 2021.
11 10. Exhibit 1 was filmed at the office of Lombardo’s campaign manager, not his
12 LVMPD office. Exhibit 1 does not depict any LVMPD employees, LVMPD
13 insignia, or anything else that would give viewers a reason to believe

14
Lombardo was in his LVMPD office.
11. Lombardo is wearing a LVMPD Sheriff’s badge on his lapel in Exhibit 1.
15
12. During the course of Lombardo’s partisan political campaign, he created
16
certain photographs and videos. At issue below is one campaign video, a
17
still shot from that same campaign video, and two photographs. As set forth
18
in greater detail below, the foregoing images depict Lombardo in his
19
Sheriff’s uniform and/or wearing his Sheriff badge or lapel pin. The firearm
20 depicted in these images is that which he is required to carry as Sheriff, and
21 is Lombardo’s personal property (as opposed to LVMPD property.
22 13. The creation of the foregoing images (i) did not interfere with Lombardo’s
23 duties as Sheriff, (ii) did not violate any LVMPD policy, and (iii) to the extent

24
they posed any cost to LVMPD or the public, such cost was nominal.
14. The twitter account belonging to Lombardo’s campaign for Governor of
25
Nevada is @JoeLombardoNV.
26
15. Tweets posted to @JoeLombardoNV were posted in support of Lombardo’s
27
campaign for Governor of Nevada
28

Page 2 of 8

HB 00022
1 16. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
2 Sheriff’s badge in Exhibit 2, which is a video posted on @JoeLombardoNV
3 on June 28, 2021.

4
17. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
Sheriff’s badge in Exhibit 3, which is a picture posted as part of a tweet on
5
@JoeLombardoNV on June 28, 2021.
6
18. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
7
Sheriff’s badge in Exhibit 4, which is a video posted on @JoeLombardoNV
8
on July 1, 2021.
9
19. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
10 Sheriff’s badge in Exhibit 5, which is a tweet posted on @JoeLombardoNV
11 on July 7, 2021.
12 20. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
13 Sheriff’s badge in Exhibit 6, which is a tweet posted on @JoeLombardoNV

14
on July 8, 2021.
21. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
15
Sheriff’s badge in Exhibit 7, which is a tweet posted on @JoeLombardoNV
16
on July 14, 2021.
17
22. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
18
Sheriff’s badge in Exhibit 8, which is a video posted on @JoeLombardoNV
19
on July 18, 2021.
20 23. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
21 Sheriff’s badge in Exhibit 9, which is a tweet posted on @JoeLombardoNV
22 on July 18, 2021.
23 24. Lombardo was wearing his LVMPD Sheriff’s badge in Exhibit 10, which is a

24
tweet posted on @JoeLombardoNV on July 22, 2021.
25. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
25
Sheriff’s badge in Exhibit 11, which is a video posted on @JoeLombardoNV
26
on July 23, 2021.
27

28

Page 3 of 8

HB 00023
1 26. Lombardo was wearing his LVMPD Sheriff’s badge in Exhibit 12, which is a
2 tweet posted on @JoeLombardoNV on July 27, 2021.
3 27. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD

4
Sheriff’s badge in Exhibit 13, which is a video posted on @JoeLombardoNV
on July 30, 2021.
5
28. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
6
Sheriff’s badge in Exhibit 14, which is a tweet posted on @JoeLombardoNV
7
on August 3, 2021.
8
29. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
9
Sheriff’s badge in Exhibit 15, which is a tweet posted on @JoeLombardoNV
10 on August 5, 2021.
11 30. Lombardo was wearing his LVMPD Sheriff’s uniform, his LVMPD Sheriff’s
12 badge in Exhibit 16, which is a video posted on @JoeLombardoNV on
13 August 8, 2021.

14
31. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
Sheriff’s badge in Exhibit 17, which is a tweet posted on @JoeLombardoNV
15
on August 12, 2021.
16
32. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
17
Sheriff’s badge in Exhibit 18, which is a second tweet posted on
18
@JoeLombardoNV on August 12, 2021.
19
33. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
20 Sheriff’s badge in Exhibit 19, which is a tweet posted on @JoeLombardoNV
21 on August 13, 2021.
22 34. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
23 Sheriff’s badge in Exhibit 20, which is a second tweet posted on

24
@JoeLombardoNV on August 13, 2021.
35. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
25
Sheriff’s badge in Exhibit 21, which is a tweet posted on @JoeLombardoNV
26
on August 18, 2021.
27

28

Page 4 of 8

HB 00024
1 36. Lombardo was wearing his LVMPD Sheriff’s uniform, his LVMPD Sheriff’s
2 badge in Exhibit 22, which is a video posted on @JoeLombardoNV on
3 August 19, 2021.

4
37. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
Sheriff’s badge in Exhibit 23, which is a tweet posted on @JoeLombardoNV
5
on August 20, 2021.
6
38. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
7
Sheriff’s badge in Exhibit 24, which is a tweet posted on @JoeLombardoNV
8
on September 9, 2021.
9
39. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
10 Sheriff’s badge in Exhibit 25, which is a tweet posted on @JoeLombardoNV
11 on September 10, 2021.
12 40. Lombardo was wearing his LVMPD Sheriff’s badge in Exhibit 26, which is a
13 second tweet posted on @JoeLombardoNV on September 10, 2021.

14
41. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
Sheriff’s badge in Exhibit 27, which is a video posted on @JoeLombardoNV
15
on September 14, 2021.
16
42. The Facebook account belonging to Lombardo’s campaign for Governor of
17
Nevada is entitled “Joe Lombardo for Governor”.
18
43. Posts to the Facebook page “Joe Lombardo for Governor” were made in
19
support of Lombardo’s campaign for Governor of Nevada.
20 44. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
21 Sheriff’s badge in Exhibit 28, which is Facebook post on “Joe Lombardo for
22 Governor” on July 8, 2021.
23 45. Lombardo was wearing his LVMPD Sheriff’s badge in Exhibit 29, which is a

24
Facebook post on “Joe Lombardo for Governor” on July 27, 2021.
46. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
25
Sheriff’s badge in Exhibit 30, which is a Facebook post on “Joe Lombardo
26
for Governor” on August 5, 2021.
27

28

Page 5 of 8

HB 00025
1 47. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
2 Sheriff’s badge in Exhibit 31, which is a Facebook post on “Joe Lombardo
3 for Governor” on September 9, 2021.

4
48. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
Sheriff’s badge in Exhibit 32, which is a Facebook post on Joe Lombardo for
5
Governor on July 7, 2021.
6
49. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
7
Sheriff’s badge in Exhibit 33, which is a Facebook post on Joe Lombardo for
8
Governor on July 14, 2021.
9
50. Lombardo was wearing his LVMPD Sheriff’s badge in Exhibit 34, which is a
10 Facebook post on Joe Lombardo for Governor on July 22, 2021.
11

12 STIPULATED DOCUMENTS
13 Exhibit 1: The video located at https://youtu.be/9E-NjOsJKN8 features Lombardo

14
announcing his candidacy for the office of Governor of Nevada on June
28, 2021.
15
Exhibit 2: A video posted to @JoeLombardoNV on June 28, 2021 as part of a
16
tweet announcing Lombardo’s candidacy for the office of Governor of
17
Nevada.
18
Exhibit 3: A tweet posted on @JoeLombardoNV on June 28, 2021.
19
Exhibit 4: A video posted on @JoeLombardoNV on July 1, 2021.
20 Exhibit 5: A tweet posted on @JoeLombardoNV on July 7, 2021.
21 Exhibit 6: A tweet posted on @JoeLombardoNV on July 8, 2021.
22 Exhibit 7: A tweet posted on @JoeLombardoNV on July 14, 2021.
23 Exhibit 8: A video posted on @JoeLombardoNV on July 18, 2021.

24
Exhibit 9: A tweet posted on @JoeLombardoNV on July 18, 2021.
Exhibit 10: A tweet posted on @JoeLombardoNV on July 22, 2021.
25
Exhibit 11: A video posted on @JoeLombardoNV on July 23, 2021.
26
Exhibit 12: A tweet posted on @JoeLombardoNV on July 27, 2021.
27
Exhibit 13: A video posted on @JoeLombardoNV on July 30, 2021.
28

Page 6 of 8

HB 00026
1 Exhibit 14: A tweet posted on @JoeLombardoNV on August 3, 2021.
2 Exhibit 15: A tweet posted on @JoeLombardoNV on August 5, 2021.
3 Exhibit 16: A video posted on @JoeLombardoNV on August 8, 2021.

4
Exhibit 17: A tweet posted on @JoeLombardoNV on August 12, 2021.
Exhibit 18: A second tweet posted on @JoeLombardoNV on August 12, 2021.
5
Exhibit 19: A tweet posted on @JoeLombardoNV on August 13, 2021.
6
Exhibit 20: A second tweet posted on @JoeLombardoNV on August 13, 2021.
7
Exhibit 21: A tweet posted on @JoeLombardoNV on August 18, 2021.
8
Exhibit 22: A video posted on @JoeLombardoNV on August 19, 2021.
9
Exhibit 23: A tweet posted on @JoeLombardoNV on August 20, 2021.
10 Exhibit 24: A tweet posted on @JoeLombardoNV on September 9, 2021.
11 Exhibit 25: A tweet posted on @JoeLombardoNV on September 10, 2021.
12 Exhibit 26: A second a tweet posted on @JoeLombardoNV on September 10, 2021.
13 Exhibit 27: A video posted on @JoeLombardoNV on September 14, 2021.

14
Exhibit 28: A Facebook post on “Joe Lombardo for Governor” on July 8, 2021.
Exhibit 29: A Facebook post on “Joe Lombardo for Governor” on July 27, 2021.
15
Exhibit 30: A Facebook post on “Joe Lombardo for Governor” on August 5, 2021.
16
Exhibit 31: A Facebook post on “Joe Lombardo for Governor” on September 9,
17
2021.
18
Exhibit 32: A Facebook post on “Joe Lombardo for Governor” on July 7, 2021.
19
Exhibit 33: A Facebook post on “Joe Lombardo for Governor” on July 14, 2021.
20
Exhibit 34: A Facebook post on “Joe Lombardo for Governor” on July 22, 2021.
21
.....
22

23 .....
24

25 .....

26
.....
27

28

Page 7 of 8

HB 00027
1 Exhibit 35: LVMPD’s Policy Manual.
2

3 DATED this 12th day of January, 2023.

5 NEVADA COMMISSION ON ETHICS CAMPBELL & WILLIAMS


6

7 /s/Elizabeth J. Bassett /s/ Samuel R. Mirkovich


Elizabeth J. Bassett, Esq. Samuel R. Mirkovich, Esq.
8
Associate Counsel 710 South Seventh St. Ste. A
9 704 West Nye Lane, Suite 204 Las Vegas, NV 89101
Carson City, Nevada 89703
10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Page 8 of 8

HB 00028
STIPULATED DOCUMENTS
EXHIBIT 1

HB 00029
The video located at https://youtu.be/9E-NjOsJKN8 featuring
Sheriff Joseph Lombardo announcing his candidacy for the office
of Governor of Nevada on June 28, 2021.

HB 00030
STIPULATED DOCUMENTS
EXHIBIT 2

HB 00031
The video posted to @JoeLombardoNV on June 28, 2021 as part
of a tweet announcing Lombardo’s candidacy for the office of
Governor of Nevada.

HB 00032
STIPULATED DOCUMENTS
EXHIBIT 3

HB 00033
HB 00034
STIPULATED DOCUMENTS
EXHIBIT 4

HB 00035
A video posted on @JoeLombardoNV on July 1, 2021

HB 00036
STIPULATED DOCUMENTS
EXHIBIT 5

HB 00037
HB 00038
STIPULATED DOCUMENTS
EXHIBIT 6

HB 00039
HB 00040
STIPULATED DOCUMENTS
EXHIBIT 7

HB 00041
HB 00042
STIPULATED DOCUMENTS
EXHIBIT 8

HB 00043
A video posted on @JoeLombardoNV on July 18, 2021

HB 00044
STIPULATED DOCUMENTS
EXHIBIT 9

HB 00045
HB 00046
STIPULATED DOCUMENTS
EXHIBIT 10

HB 00047
HB 00048
STIPULATED DOCUMENTS
EXHIBIT 11

HB 00049
A video posted on @JoeLombardoNV on July 23, 2021

HB 00050
STIPULATED DOCUMENTS
EXHIBIT 12

HB 00051
HB 00052
STIPULATED DOCUMENTS
EXHIBIT 13

HB 00053
A video posted on @JoeLombardoNV on July 30, 2021

HB 00054
STIPULATED DOCUMENTS
EXHIBIT 14

HB 00055
HB 00056
STIPULATED DOCUMENTS
EXHIBIT 15

HB 00057
HB 00058
STIPULATED DOCUMENTS
EXHIBIT 16

HB 00059
A video posted on @JoeLombardoNV on August 8, 2021

HB 00060
STIPULATED DOCUMENTS
EXHIBIT 17

HB 00061
HB 00062
STIPULATED DOCUMENTS
EXHIBIT 18

HB 00063
HB 00064
STIPULATED DOCUMENTS
EXHIBIT 19

HB 00065
HB 00066
STIPULATED DOCUMENTS
EXHIBIT 20

HB 00067
HB 00068
STIPULATED DOCUMENTS
EXHIBIT 21

HB 00069
HB 00070
STIPULATED DOCUMENTS
EXHIBIT 22

HB 00071
A video posted on @JoeLombardoNV on August 19, 2021

HB 00072
STIPULATED DOCUMENTS
EXHIBIT 23

HB 00073
HB 00074
STIPULATED DOCUMENTS
EXHIBIT 24

HB 00075
HB 00076
STIPULATED DOCUMENTS
EXHIBIT 25

HB 00077
HB 00078
STIPULATED DOCUMENTS
EXHIBIT 26

HB 00079
HB 00080
STIPULATED DOCUMENTS
EXHIBIT 27

HB 00081
A video posted on @JoeLombardoNV on September 14, 2021

HB 00082
STIPULATED DOCUMENTS
EXHIBIT 28

HB 00083
HB 00084
STIPULATED DOCUMENTS
EXHIBIT 29

HB 00085
HB 00086
STIPULATED DOCUMENTS
EXHIBIT 30

HB 00087
HB 00088
STIPULATED DOCUMENTS
EXHIBIT 31

HB 00089
HB 00090
STIPULATED DOCUMENTS
EXHIBIT 32

HB 00091
HB 00092
STIPULATED DOCUMENTS
EXHIBIT 33

HB 00093
HB 00094
STIPULATED DOCUMENTS
EXHIBIT 34

HB 00095
HB 00096
STIPULATED DOCUMENTS
EXHIBIT 35

HB 00097
Las Vegas Metropolitan Police Department
Partners with the Community

2/114.00 POLITICAL ACTIVITIES POLICY

It is the policy of this department that its facilities, equipment and on-duty personnel will not be used by political
candidates seeking public office for ANY political purpose. Candidates may be escorted through open work areas;
however, they may not attend or interrupt meetings, conferences or briefings to campaign. They may shake hands
and distribute literature while being escorted through open work areas though no campaign literature (posters, flyers,
buttons, etc.) will be left for distribution, posted or prominently displayed in any department area. Candidates’ visits
and escorts are coordinated and approved by the Office of Intergovernmental Services.
Photographing or filming within department facilities will not be allowed, however, public areas or parking lots may
be used as long as property, equipment, or personnel are not “posed” specifically for the photography (the use of shift
changes and vehicle check outs as background are unavoidable). Department employees are not authorized to appear
in any photograph or commercial on duty and may not appear, in uniform, while off duty. The only exception to this
is for an LVMPD employee who is a candidate, appearing in his own photograph since this does not constitute an
endorsement. Questions and/or authorization regarding use of department property will be directed to the Office of
Intergovernmental Services.

Department members who are political candidates (or members working on their behalf) must ensure their conduct is
responsive to the citizens of Clark County in a law enforcement capacity first and foremost. Any campaigning that
must be done during normal work hours will require the use of leave and a leave slip must be submitted. Department
issued cellular telephones will not be used for ANY unofficial purpose related to political activities. Department
vehicles are provided for public safety purposes only and should not be used for political activities. If unavoidable,
mileage must be logged and reimbursed to the department at the prevailing Federal rate. Such logs will be submitted
to the Chief Financial Officer, Office of Finance, by the 5th of each month.

While on duty or acting under “color of law” members shall not solicit or make contributions directly or indirectly,
on any pretext, to any person, committee, or association, for political purposes, nor shall they interfere or use the
influence of their office for political reasons.

Department values (particularly integrity and accountability in this case) must be demonstrated by the actions of
employees to ensure the community that they can depend on members of this department to act in a responsible and
ethical manner at ALL times. (1/09, 2/11)■

HB 00098
Las Vegas Metropolitan Police Department
Partners with the Community

4/103.14 PUBLIC STATEMENTS ABOUT CONTROVERSIAL SUBJECTS

While on duty or under “color of law” members shall not publicly express an opinion on racial, religious, political, or
controversial subjects, and shall refrain from public discussion of the demerits of any law, unless it is the expressed
opinion of the department. Members shall not engage in political or religious discussions to the detriment of good
discipline, and shall not speak disparagingly of the nationality, color, creed, or belief of any person. (7/73)■

HB 00099
Las Vegas Metropolitan Police Department
Partners with the Community

4/103.16 POLITICAL ACTIVITIES

While on duty or acting under “color of law” members shall not solicit or make contributions directly or indirectly,
on any pretext, to any person, committee, or association, for political purposes, nor shall they interfere or use the
influence of their office for political reasons. (7/73)■

HB 00100
Las Vegas Metropolitan Police Department
Partners with the Community

4/103.27 SOCIAL MEDIA and ELECTRONIC COMMUNICATIONS by DEPARTMENT


MEMBERS

This policy establishes the department’s position on the use and management of social media and provides rules and
precautions on communications, verbal or written, by department members.

DEFINITIONS

Page The specific portion of a social media website where content is displayed and managed by an
individual or individuals with administrative rights.
Post Content an individual shares on a social media site or the act of publishing content on a site.
Profile Personal information that a user provides on a social media site.
Public Concern Topics that relate to a matter of political, social, or other concern to the community. It does
not include topics that relate to employment/personnel matters or information learned in the
course of employment.
Social Media A category of electronic resources that integrate user-generated content and user participation,
such as Facebook, Twitter, Instagram, YouTube, Snapchat, etc., and smart phone or other
portable device applications.
Speech Expressions or communication of thoughts or opinions in spoken words, in writing, by
expressive conduct, symbolism, or images.

GENERAL

Public employees are public servants and are entrusted with the public trust. Because of this public trust, law
enforcement personnel are held to a higher standard of professionalism than private citizens. Law enforcement
personnel must work hard to gain the trust and confidence of the community they serve. Department members must
give thoughtful consideration to their actions to avoid damaging the reputation and trust the department has with the
community.

Department members shall abide by the following:


1. Adherence to 1/000.02, Law Enforcement Code of Ethics is required in the personal use of social media.
2. Public employees have qualified First Amendment rights. As public employees, speech, on - or off-duty,
made pursuant to official duties is not protected speech under the First Amendment and may form the basis
for discipline if deemed detrimental to the efficiency of operations of the department.
3. Department members are free to express themselves as private citizens in matters of public concern to the
degree that their speech does not:
a. Impair working relationships of the department for which loyalty and confidentiality are important.
b. Impede the performance of duties.
c. Impair discipline and harmony among co-workers; or
d. Negatively impact or tend to negatively impact the department’s ability to serve the public.
4. Department members will not post, transmit, or otherwise disseminate any information, documents, photos
or videos, to which members have access as a result of employment, without written permission from the
Sheriff, or designee.
5. Department members are prohibited from disclosing information pertaining to any other members of the
Department without permission of the affected member (to include “tagging” in text or photos).
6. Officers working in a covert capacity, as defined by LVMPD 5/206.01, Covert and Undercover Officers, will
not post any form of visual or personal identification. In addition, officers working in this capacity will not
post anything that could reveal or compromise any covert operation. For officer safety purposes, it is required
that officers working in a covert capacity and have posted anything, past or present, that may identify the
officer as a department member must remove all such posts.

ON-THE-JOB USE OF ELECTRONIC COMMUNICATION

A. Department Sanctioned Presence:

HB 00101
Las Vegas Metropolitan Police Department
Partners with the Community

a. Each social media page shall include an introductory statement that clearly specifies the purpose and
scope of the agency’s presence on the website.
b. Social media page(s) will be designed for the target audiences such as potential LVMPD employees and
volunteers (established and approved by the department).
1. Procedures:
a. All department social media sites/pages shall be approved by a Deputy Chief, or designee, or as
otherwise determined and forwarded to PIO for approval and registry. All department social media
sites/pages shall be regularly monitored by the bureau or section which created the page. The department
member or position responsible for monitoring shall be identified to PIO.
b. Social media pages will clearly indicate they are maintained by the department and display department
contact information prominently.
c. Content regarding programs, services, events or initiatives on social networking sites should point users
to the LVMPD website for expanded content.
d. Social media content will be consistent with department strategic goals and adhere to applicable laws,
regulations, and policies, including all information technology and records management policies.
e. Social media pages should state that the opinions expressed by visitors to the page do not reflect the
opinions of the LVMPD:
1) Page shall clearly indicate that posted comments will be monitored and that LVMPD reserves the
right to remove postings deemed inappropriate.
2) Page shall clearly indicate that any content posted or submitted for posting is subject to public
disclosure.
B. Department-Sanctioned Use:
1. Department members representing the department via social media outlets will do the following:
a. Conduct themselves at all times as representatives of LVMPD and, accordingly, shall adhere to all
LVMPD 4/101.00, General Conduct policies and observe proper decorum.
b. Identify themselves as a member of the department.
c. Make no statements about any suspect or arrestee, or comments concerning pending prosecutions or
otherwise disseminate personal or confidential information, including but not limited to photographs or
videos, related to department training, activities, or work-related assignments without express written
permission.
d. Monitor public comments and respond to those that may spread misinformation.
e. Conduct no political activities or private business.
f. Keep information current and up-to-date.
2. Department members shall observe and abide by all copyright and trademark restrictions in posting materials
to electronic media. (See LVMPD 2/125.00, Copyright of LVMPD Emblems (Badge/Logo)
C. Potential Uses:
1. Social media is a valuable investigative tool when seeking evidence or information about missing persons,
criminal investigations, etc.
2. Social media can be used for community outreach and engagement by providing crime prevention tips,
soliciting tips about crimes, etc.
3. Social media can be used to make time-sensitive notifications related to road closures, special events, etc.

PERSONAL USE OF ELECTRONIC COMMUNICATION

A. Precautions:
1. Department members should be mindful that once a photo has been posted to the internet, it can never be
purged out of existence. As such, department members are cautioned that the following actions could have a
detrimental effect on department member’s safety and the operational security of the department:
a. Posting/displaying department logos, uniforms, or similar identifying items on social media.
b. Posting/displaying on social media personal photographs or providing similar means of personal
recognition that may cause a person to be identified as an officer or a department member.
2. Department members should be aware that privacy settings and social media sites are constantly in flux, and
should never assume that personal information posted on such sites is protected from public access.
3. Department members should expect that any information created, transmitted, downloaded, exchanged, or
discussed in a public online forum may be accessed by the department at any time without prior notice.

HB 00102
Las Vegas Metropolitan Police Department
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4. Department members should be aware that they may be subject to civil litigation for:
a. Publishing or posting false information that harms the reputation of another person, group or
organization (defamation).
b. Publishing or posting private facts and personal information about someone without permission that has
not been previously revealed to the public, is not legitimate public concern, and would be offensive to a
reasonable person.
c. Using someone else’s name, likeness, or other personal attributes without that person’s permission for
an exploitative purpose; or
d. Publishing the creative work of another, trademarks, or certain confidential business information without
the permission of the owner.

B. Prohibitions:
1. Department members shall not access personal social networking site(s) while on duty.
2. Department members shall not use the department logo, a replica of the badge or use “LVMPD” as part of a
page, posting, signature or to serve as an embellishment of any statement.
3. Department members are prohibited from speech that ridicules, maligns, disparages, or otherwise promotes
discrimination against race, ethnicity, religion, sex, national origin, sexual orientation, age, disability,
political affiliation, gender identity and expression or other explicit class of individuals.
4. Department members are prohibited from speech or other expression that suggests the person is engaged in
behavior reasonably considered to be unlawful or reckless toward public safety.
5. Engaging in prohibited speech as stated in this policy, may negatively affect the department member’s
credibility and impair the member’s ability to perform the essential job functions. A department member’s
speech is a reflection of character and values. Speech that fundamentally conflicts with the department’s
ICARE values negatively affects both the member’s ability and the department’s ability to serve the
community. Violations of this policy or related policies (values, conduct, etc.) in the use of social media that
bring the member or the department into discredit or would tend to bring the member or the department into
discredit will result in the department taking appropriate action up to and including termination. (11/11,
7/15)■

HB 00103
Las Vegas Metropolitan Police Department
Partners with the Community

4/107.00 APPEARANCE STANDARDS

Section 1 Purpose and Scope


Section 2 Grooming Standards
Section 3 Commissioned Uniform Standards
Section 4 Plainclothes Commissioned Dress Standards
Section 5 Civilian Dress Standards
Section 6 Uniform Management, Care, and Maintenance
Section 7 Attire for Courtroom Appearances, Administrative Hearings, and Media Briefings
Section 8 Medical Exemptions

Section 1 Purpose and Scope

It is the policy of this Department to ensure that all employees portray the most favorable image of law enforcement.
Such an image should reflect a high professional standard and be consistent with public expectations, projecting
uniformity and neutrality.
All supervisors are responsible for strict supervision of this policy by monitoring the daily dress and appearance of
employees, conducting inspections, promptly addressing violations, and ensuring that employees’ essential equipment
is approved and operable.

Each area commander will ensure that a formal inspection is conducted by supervisors at least monthly to verify that
employees are in compliance with Department policy. Supervisors will inspect all personnel for compliance to the
grooming, uniform, equipment, and appropriate documentation/permit (e.g., possession of Nevada driver’s license)
guidelines established within Department policy. Additionally, supervisors will inspect all force tools (see LVMPD
6/002.02, Use of Force). A Squad Inspection Report (LVMPD 208) will be completed during inspections, forwarded
to the bureau/area commander, and the file will be maintained for a period of one year. If bureau commanders have
questions regarding an employee’s professionalism or reasonableness as applicable to the standards outlined herein,
they may consult the Professional Standards Division Director.

Section 2 Grooming Standards

While on duty or representing the Department, employees will be neat and clean in their public appearance.
Employees will practice good personal hygiene.

DEFINITIONS

branding The act of intentionally burning the skin for the purpose of creating designs, forms,
figures, or art.
body modifications The intentional act of modifying one’s body in order to create a substitution for the natural
human form. This does not include reconstructive surgeries or minor, commonly
practiced cosmetic surgery.
scarification The intentional act of cutting the skin for the purposes of creating designs, forms, figures,
or art.
tattoos The act or practice of marking the skin with indelible or semi-permanent designs, forms,
figures, or art by placing ink or pigment under the skin.

HAIR

1. All Personnel
Hairstyles will be reasonable, professional, and appropriate to the business environment. Hair color will be
common, natural colors with no unnaturally colored streaks. Wigs and hairpieces will also adhere to these
standards.

2. Male Commissioned Personnel

HB 00104
Las Vegas Metropolitan Police Department
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Hair will be neat, clean, trimmed, well-groomed, and will not exceed ½ inch below the top of the buttoned
shirt collar while standing. Hairstyles will be professional and conservative and will not be cut into unusual
shapes (e.g., mohawk, faux-hawk, severe comb-over cuts), or have shaved designs (e.g., severe razor parts),
braids, or jewelry attached. Bangs will be cut or styled so that hair will not interfere with vision. Hair on the
sides of the head will be combed so as not to cover more than ½ inch of the outside portion of the ear.
Sideburns will not extend past the middle of the ear, will not be any wider than one inch at the bottom, and
will not be conspicuous in manner. Hair should not stand out from the head at an excessive length and will
not interfere with the wearing of Departmental headwear.

3. Female Commissioned Personnel


Hair will be neat, clean, and well-groomed. Hairstyles will be professional and conservative, and will not be
cut into unusual shapes (e.g., mohawk, faux-hawk, severe comb-over cuts), or have shaved designs (e.g.,
severe razor parts), or jewelry attached.

While in uniform, hair length will not exceed ½ inch below the top of the buttoned shirt collar while standing.
Bangs will be cut or styled so that hair will not interfere with vision. Long hair may be worn if it is gathered
neatly into a ponytail or braid and fastened securely to the head so that the hair does not exceed ½ inch below
the top of the buttoned shirt collar while standing. Likewise, buns with loose hair extending at the end, or
loose unsecured hair (not to include bangs) when medium and long hair are worn up on top of the head, are
prohibited. Hair should not stand out from the head at an excessive length and will not interfere with the
wearing of Departmental headwear.

Hair combs, clips, or bands may be worn to secure the hair, but they must be black, brown, or tan and without
ornamentation. Combs or clips will be no longer or wider than two inches. Hairbands will be no wider than
two inches.

BEARDS

1. Civilian Personnel
Beards are permitted; however, facial hair will be clipped not to exceed ¼ inch in length (not longer than a
#2 clipper guard). Goatees or other customized beard creations are not permitted.

2. Commissioned Personnel
LVMPD maintains a “clean-shaven” policy and officers are not permitted to have a beard while in uniform.
Beards or a growth of whiskers will be permitted only for valid medical or religious reasons (see 5/101.24
Harassment and/or Discrimination; Prevention, and Complaint Process), or when required by the nature of
the assignment (e.g., covert officers, etc.). For medical exemption application requirements and grooming
standards, see the “Medical Exemptions” section of this policy. An officer who normally works in a covert
capacity and is permitted to wear a beard, will not wear the beard in uniform.

MUSTACHES

1. All Personnel
Mustaches may be worn neatly trimmed and may not extend down over the middle of the upper lip, over ½
inch out past the corners of the mouth, or more than ¼ inch below the corners of the mouth.

FINGERNAILS

1. Female Civilian Personnel


Nail polish will be appropriate to the business environment, and nails will not exceed one half inch in length
from the tip of the finger (length may be further restricted based on assignment).

2. Male Civilian and Commissioned Personnel


Nails will be unadorned, neatly groomed, and not exceed the tip of the finger.

HB 00105
Las Vegas Metropolitan Police Department
Partners with the Community

3. Female Commissioned Personnel


Nails will be neatly groomed and not exceed 1/4 inch past the tip of the finger. Nail polish is permissible;
however, colors will be in neutral, light tones and without designs.

MAKEUP

1. Female Personnel (Civilian and Commissioned)


Makeup will be appropriate and not distracting within the business environment. Makeup will be worn in a
conservative manner with neutral colors and lightly applied. Permanent eye liner and eyebrow filling/tinting
in the form of cosmetic tattooing is permissible. If worn, permanent eye liner and eyebrows will be
conservative, in good taste, and complimentary to the wearer’s complexion. The tattoo(s) shall not be brightly
colored and will be no more than ⅛ inch in width, not extending past the outer corner of the eye. Eyelash
extensions will not be excessive in length or thickness and must appear natural so as not to be distracting, if
worn.

JEWELRY

1. Civilian Personnel
Jewelry may be worn in a tasteful and business-like manner. Male employees will not wear earrings.
Employees are prohibited from stretching their earlobes, a process called “gauging.” Members are prohibited
from attaching or displaying objects or jewelry on or through the nose, tongue, eyebrow, or other exposed
body part (except the ears for females). All jewelry implants will not be exposed or visible.

2. Male Commissioned Personnel


Male employees will not wear earrings. Officers are prohibited from attaching or displaying objects or
jewelry on or through the nose, tongue, eyebrow, or other exposed body part. Necklaces worn must not be
visible while in uniform.

3. Female Commissioned Personnel


Females may wear one earring in each earlobe. They will be matching stud-type with the stone or
ornamentation not exceeding 1/4 inch in diameter. Officers are prohibited from attaching or displaying
objects or jewelry on or through the nose, tongue, eyebrow, or other exposed body part. Necklaces worn must
not be visible while in uniform.

WRISTWATCHES

1. All Personnel
Watches/Watchbands may be worn in sizes and shapes that do not impair job performance. Styles and colors
must be conservative in nature.

AFFIXED CLOTHING ACCESSORIES

1. All Personnel
a. Employees will not affix to any uniform or civilian clothing while on duty or present in a Department
facility any badge, pennant, button, insignia, emblem, device, or decoration that promotes an
organization (e.g., team logo), corporation (e.g., hotel logo), or viewpoint (e.g., religious or political)
unless specifically authorized by the Deputy Chief of the Professional Standards Division.
b. Removable badge lanyards are permitted; however, designs, insignias, and logos must be professional.
1) Civilian employees are permitted to accessorize removable badge lanyards as appropriate in a
business environment.

BODY MODIFICATIONS

1. All Personnel

HB 00106
Las Vegas Metropolitan Police Department
Partners with the Community

Employees are prohibited from having “3D dermal” implants electively placed under their skin or from
altering their appearance in any significant or unconventional manner, including via surgery. Body
modifications including, but not limited to, “elf ears,” tongue splitting, visible scarification, teeth sharpening,
or any other body modification that deforms the conventional appearance of a visible body part (not covered
by a standard duty uniform) from its original genetic design is prohibited. This does not preclude employees
from commonly practiced cosmetic surgeries (e.g., facelift surgeries, cosmetic dermal fillers, or Botox).

TATTOOS, SCARIFICATION, AND BRANDING

1. All Personnel
Tattoos or branding will not be exposed or visible while on duty or while representing the Department. Such
markings must be covered by clothing. For employees hired before April 15, 2012, markings that cannot be
covered by clothing will be covered using makeup, neutral-toned bandages, or patches. For employees hired
on or after April 15, 2012, using makeup or bandages to conceal any tattoo, brand, or scarification is not
approved. Employees are prohibited from getting tattoos or any other type of markings on their hands, neck,
head, or face, except as noted below.

a. Hands
A tattoo or brand in the form of a ring is permissible on the wearer’s finger (not thumb) with the
limitation of one per hand. The tattoo(s) will not exceed ¼ inch in width and will be in good taste.

b. Neck
No tattoo, brand, or scarification may be visible above the collar on the neck or above the collarbone
while wearing an underlying t-shirt.

c. Head/Face
Permanent makeup only as approved in “Makeup” section.

d. Content
Tattoos, brands, and scarification anywhere on the body that promote racism, discrimination, extremist
or supremacist philosophies, lawlessness, violence, or contain pornographic or lewd material that do not
conform with Department values are prohibited. Any tattoo that signifies “scorekeeping” related to
police activity or unprofessionally signifies membership(s) in unofficial law enforcement groups is
strictly prohibited. Such tattoos, brands, or scarification may render the employee ineffective in their
position and/or tend to bring the Department into public discredit.

When a tattoo, brand, or scarification which may violate Department policy, though would normally be
concealed by clothing, is brought to the attention of the Department (i.e., during the process of dressing
for duty in a locker room), LVMPD is obligated to investigate and act appropriately.
1) Any member sustained for having an obscene or discriminatory tattoo, brand, or scarification will
be subject to disciplinary action up to, and including, termination. In the event a disciplinary action
less than termination is considered, a condition of the discipline will require the member to remove
the tattoo, brand, or scarification at their own expense in order to maintain employment with
LVMPD.
2) Members must be mindful of LVMPD 4/103.27, Social Media and Electronic Communications by
Department Members regarding posting photographs of tattoos, brands, or scarification on any
social media sites. LVMPD will not peruse member websites seeking out pictures of tattoos, brands,
or scarification.

2. The Human Resources Bureau will ensure that the nature of permanent tattoos, brands, or scarification
anywhere on the body are in compliance with policy for all applicants for employment. Applicants who have
such tattoos, brands, or scarification will be required to remove them at their own expense if they wish to be
considered for employment.

HB 00107
Las Vegas Metropolitan Police Department
Partners with the Community

Section 3 Commissioned Uniform Standards


Employees on duty will not wear uniforms or carry essential equipment that do not conform to Department
specifications or regulations. Employees are required to maintain their uniforms and equipment in good repair and to
possess only approved equipment while in the performance of their duties.

DEFINITIONS

inclement weather Stormy or extreme weather including rain, hail, sleet, snow, or cold weather.
1. “Cold weather” is a temperature under 55ºF.
2. “Moderate UV day” has a UV index greater than four.

MANDATORY WEARING OF UNIFORM

All commissioned personnel will work in the standard duty uniform at least three times during the year. (Officers on
light duty are exempt.) The first time will be during Police Memorial Week (announced by Administrative Notice
annually), the second time will be on September 11, and the third time will be on October 1. For plainclothes
assignments, supervisors will inspect the appearance of the uniform for care and maintenance during these times and
will document the inspection on a Squad Inspection Report (LVMPD 208).

DEPARTMENT-ISSUED IDENTIFICATION

On-duty uniformed personnel will wear their Department-issued badge or a cloth badge on their outermost garment.
While in Department facilities, employees in plainclothes or civilian clothing will display the Department
identification card.

UNIFORM APPEARANCE GENERAL RULES

1. Uniforms will be freshly pressed with military pleats, dry-cleaned, and adequately tailored.
2. The uniform shirt button flap will be aligned with the zipper flap on the trousers.
3. The cuffs on long-sleeved shirts will not be rolled up and will remain buttoned (exception being utility
uniforms where sleeves are designed to be worn rolled up utilizing a military sleeve roll above the elbow).
4. The gun belt buckle will be centered with the trouser zipper.
5. Trousers will be worn outside the boots (with the exception of motor officers and when tactical trousers are
bloused).
6. Uniform hats will be worn squarely on the head with the bill positioned approximately two fingers above the
bridge of the nose.
7. Items such as chains, personal keys, and papers will not be attached to, hung on, or protruding from any
portion of the uniform. (Traffic officers may wear whistle with chain attached to epaulet of the shirt.)
8. If a t-shirt is worn, it must be crewneck style, and it must be white in color (except as otherwise noted in this
policy).
9. Footwear, except as specified in this policy, will be solid black in color; plain toe with no stitching designs
or perforations, and must be able to hold a shine; black shoestrings required; snaps, buckles or Velcro are not
permitted; trademarks, logos, or brand names cannot be visible; heel not more than 1.5 inches in height from
the point of attachment at the sole.
10. Socks must be solid black if exposed when standing or sitting.
11. Tie and tie tack, if required, will be Department-issued. (When required to wear ties, personnel will wear the
tie tack in the center of the tie midway between the top and lower edges of the shirt pockets.)

STANDARD-ISSUED UNIFORM SPECIFICATIONS

1. Standard Duty Uniform for Commissioned Personnel


a. Tan long- or short-sleeved shirt
b. White undershirt
c. Tan pants

HB 00108
Las Vegas Metropolitan Police Department
Partners with the Community

2. Utility Uniform
Authorized as the duty uniform for specialized units (e.g., K9, Air Support, and Recruiting as listed below)
or when approved by the division commander for special duty on a case-by-case basis.
a. Green fatigue long-sleeved shirt
b. Green fatigue pants
c. Green flight/jump suit
d. Black tee undershirt (will not be worn as the outermost garment in public)
e. A cloth unit insignia will be worn above the left breast pocket flap by personnel who wear the utility
uniform as the duty uniform. A name tag will be sewn above the right breast pocket flap. LVMPD-issued
patches will be worn on both shoulders and left chest.

3. Formal Dress (Class A)


Utilized for formal occasions such as academy graduations, funerals, ceremonies and at the discretion of the
Sheriff.
a. Long-sleeved green shirt
b. Tan tie with tie tack
c. Tan pants
d. All ribbons and decorations
e. Class A dress hat and cap piece (captains and above, Academy TAC staff only)

4. Formal Dress – Honor Guard


a. White shirt
b. Honor Guard jacket
c. Honor Guard (Metro Green) tie with tie tack
d. Honor Guard breast badge
e. Class A trouser
f. Class A dress hat with cap piece
g. High gloss duty belt and gear
h. Corfram dress shoes
i. White gloves
j. All ribbons and decorations

SPECIAL DUTY UNIFORM SPECIFICATIONS

1. All Hazard Regional Multi-Agency Operations and Response Section (ARMOR)


a. Utility uniform specifications but with tan fatigue shirt/pants or jumpsuit
b. Desert subdued patches
c. Black long- or short-sleeved polo shirt
d. Tan boots

2. Bicycle/Enduro Uniform
Only issued to officers who operate a bicycle or Enduro motorcycle for at least 75% of their duty shift.
Officers wearing this uniform will not operate other patrol vehicles except in case of an emergency or to
allow officers access to gear. Bicycle officers may drive a vehicle to the duty location and then deploy on
bicycles.
a. LVMPD-issued yellow long-or short-sleeved bicycle shirt
b. Black fatigue pants (or shorts-bicycle only)
c. Black short-sleeved tee undershirt or black long-sleeved mock-turtleneck undershirt with “LVMPD”
embroidered on collar
d. Black baseball cap
e. Gloves (see “Gloves” section below)
f. Sunglasses or eye protection at all times when operating a motorcycle
g. Helmet is required at all times when operating a motorcycle or bicycle (see “Headwear”)
h. Bicycle officers are permitted to wear athletic shoes which meet the general footwear specifications
regarding color, material, and fasteners

HB 00109
Las Vegas Metropolitan Police Department
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i. Enduro officers must wear boots


3. Firearms Training and Tactics Unit (FTTU) (full-time only)
a. Utility uniform specifications but with tan fatigue shirt/pants or jumpsuit
b. Red polo shirt and red undershirt while conducting training
c. Tan boots

4. Gangs Enforcement Team (GET)


a. Black fatigue uniform pants
b. Tan long-sleeved polo shirt
c. In winter only – black mock-turtleneck undershirt with “LVMPD” embroidered on the collar

5. Homeless Outreach Team


a. Utility uniform specifications
b. No assignment name tape will be worn

6. Homeland Security Saturation Team (HSST)


a. Utility uniform specifications
b. In winter only – black mock-turtleneck undershirt with “LVMPD” embroidered on the collar
c. During training for mobile field force duties only:
1) Black fatigue uniform pants
2) Tan long-sleeved polo shirt

7. Organizational Development Bureau (ODB) (Academy, AOST, EVOC, FTTU, MACTAC, RBT)
a. Utility uniform specifications
b. Black long- or short- sleeved polo shirt
c. Black physical fitness uniform

Police Academy Recruit Training


a. Tan shirt
b. Tan pants
c. Baseball hat
d. Physical fitness uniform as determined by the Training Section

8. Search and Rescue


a. Utility uniform specifications
b. Red undershirt
c. Reflective patches

9. DSD Special Emergency Response Team (SERT)


a. Utility uniform specifications
b. Green undershirt

10. SWAT
a. Utility uniform specifications
b. Green undershirt
c. Subdued patches
d. When wearing heavy body armor, may elect to wear a tactical shirt
e. Black baseball hat with embroidered subdued star
f. SWAT vest to include the LVMPD subdued patch

11. Traffic Bureau (Motor Unit, Traffic Training Unit)


a. Motor Unit
1) Standard duty uniform shirt
a) May wear whistle with chain attached to epaulet of the shirt
2) In winter only – black or yellow mock-turtleneck undershirt with “LVMPD” embroidered on the

HB 00110
Las Vegas Metropolitan Police Department
Partners with the Community

collar
3) Tan breeches
4) Boots meeting the general footwear specifications regarding color, material, and fasteners (see
“Uniform Appearance”). Boot tops will be of material capable of high shine and will extend past
calf of leg to within 3-6 inches below the knee. Tops may have a small buckle.
5) Helmet is required when operating a motorcycle (See “Headwear”)
6) Gloves (see “Gloves”)
7) Sunglasses or eye protection are required when operating a motorcycle (see “Sunglasses/Eye
Protection”)

b. Traffic Officer Assigned to a Patrol Vehicle


1) Standard duty uniform shirt
a) In winter only – black or yellow mock-turtleneck undershirt with “LVMPD” embroidered on
the collar
b) May wear whistle with chain attached to epaulet of the shirt
2) Tan breeches
3) Boots meeting the general footwear specifications regarding color, material, and fasteners (see
“Uniform Appearance” above). Boot tops will be of material capable of high shine and will extend
past calf of leg to within 3-6 inches below the knee. Tops may have a small buckle.

c. Traffic Training Unit


1) Utility uniform specifications
a) Tan long-sleeved polo shirt
b) Green tactical uniform pants

UNIFORM EQUIPMENT

The following items are required to complete the Department uniform.


1. Badge – Commissioned employees will be issued authorized LVMPD badges.
a. Commissioned personnel may obtain a flat badge to use off-duty when not in uniform. Flat badges may
be obtained from the Supply Section after completion of field training.
b. Department employees will not purchase, use, or carry an unauthorized badge for the purpose of official
identification.
2. Valid Nevada driver’s license
3. Duty belt and accessories – Uniformed personnel will not mix nylon gear with basketweave gear; however,
basketweave and leather gear can be mixed. Nylon, basketweave, and/or leather gear must be black in color.
a. Authorized firearm as listed in LVMPD 5/208.02, Authorized Firearms & Associated Equipment.
1) Ensure weapon is loaded with duty ammunition.
b. Authorized holster (at least a level II retention) on the side of the strong hand (right-handed on the right
or left-handed on the left).
1) Cross draw position is prohibited.
2) Double holsters worn on the duty belt are prohibited.
3) Wearing a concealed back-up weapon in the waistband area must conform to LVMPD 5/208.02,
Authorized Firearms and Associated Equipment.
4) Drop-leg and/or thigh holsters are prohibited.
c. Ammunition magazine carrier(s) – Positioned on either side of the buckle and may be worn vertically or
horizontally. Must be predominantly black in color to match the duty belt.
d. Baton and baton holder – The 22-inch auto-lock baton is standard issue. Officers may purchase a 21-
inch to 26-inch friction-lock baton.
e. Handcuffs – Issued or personally owned handcuffs will be carried inside a secured case on the belt and
must be either black or chrome in color.
f. Key holder (and handcuff key) – Officers must have a handcuff key on their key holder or on their
person.
g. OC dispenser and carrying case
h. Electronic Control Device (ECD) – When holstered and carried on the officer’s duty belt, it will be

HB 00111
Las Vegas Metropolitan Police Department
Partners with the Community

placed on the weak side, opposite the duty firearm, positioned for either a weak hand draw or a strong
hand cross-draw. Issued to uniformed patrol sergeants and officers as well as SWAT, GET, K9, and
Headquarters Security Detail. Upon transfer to an assignment other than those listed above, sergeants
and officers must return the ECD to the Supply Section. DSD will follow SOP 09.08.02, General
Housing Unit Operations, reference carrying of the ECD.
i. Belt keepers – Duty belt must be secured to under belt
j. Flashlight and flashlight holder – Required for corrections officers, recommended for police officers
k. Rescue knife – Required for corrections officers
4. Soft body armor (required in some instances, see Soft Body Armor section) – Carriers, if visible, must be
white or tan if wearing the summer or utility uniform or black in color if wearing the dark green shirt or
tactical uniform.
5. Body worn camera – Will be worn in accordance with LVMPD 5/210.01, Body Worn Cameras
6. Pen
7. Standard-Issued name plate/name tag – Will be worn on the right breast of the uniform shirt with the optional
accompanying shooter badge
8. Unit insignia – The following are authorized to be worn while officers are assigned to the respective unit:
a. Traffic – One winged wheel and arrow attached on each collar
b. FTO, CFTO, TAC – One on each collar
c. Honor Guard, SWAT, K9, Academy, recruiter, crisis negotiator, gang officer, firearms instructor,
defensive tactics instructor, motor instructor, SERT, investigative units such as Homicide, etc. – Unit
plate will be placed on the top edge of left breast pocket.

The following items are optional to complete the Department uniform. Optional items must match the material and
style of the duty belt:
1. Second pair of handcuffs (must be in a matching case)
2. Knife and knife carrier – Folding knife with blade not exceeding four inches. Knives are to be secured.
3. Flashlight and flashlight holder – optional for POs

HEADWEAR

Headwear is authorized or required as indicated and will not be worn indoors unless otherwise specified. The bill of
the cap must face forward. Optional headwear items (with the exception of balaclavas) are stocked by the Logistics
Bureau and are purchased by the officer authorized to wear the item.

1. Formal dress hat


Issued to captains and above and Academy TAC staff. Only worn with the formal uniform (with exception
of both police and corrections academy staff during recruit inspections). The hat will not be altered in any
manner, nor will the crown wire or plastic grommet be removed, bent, or otherwise fashioned to produce a
bow or sag in the crown. The formal dress hat may be worn indoors and outdoors for inspections, ceremonial,
or formal occasions.

2. Black LVMPD baseball cap


Only permitted to be worn during prolonged periods of time when exposed to inclement weather. Motor,
bicycle, and Enduro officers may wear the cap upon removing a helmet while on duty. This item cannot be
altered (e.g., custom embroidery is not permitted).

3. Black knit/fleece cap


Optional item. Only worn when outdoors to protect from exposure to cold weather. No insignia or embroidery
is authorized. Must be solid black and worn and at least two inches from the eyebrow.

4. Helmet (protective)
Motor, bicycle, and Enduro officers are required to wear a helmet while operating/riding their means of
transport.

5. Riot Helmet

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Matte black riot helmets outfitted with a face shield will be issued to all commissioned police and will be
worn when directed by superiors. Riot helmets require a Velcro name tape affixed to the back on the bottom
between the two screws. (Corrections officers are not issued riot helmets but they are distributed when needed
by the DSD Supply Section.)

6. Gas Mask/Carrier and Cartridge


To be utilized during protest or riot situations (see LVMPD 5/211.09, Protests: Peaceful Demonstrations,
Civil Disobedience, and Riots).

7. Utility hat
Optional item. A wide-brim hat often described as a sun hat, Boonie hat, or Tilly hat. Must be tan in color
and embroidered with “Metro Police” on the front and the US flag in full color on the wearer’s left side. Only
permitted to be worn during prolonged periods of time when exposed to inclement weather or on moderate
UV days.

8. Balaclava
Optional item. Must be olive green or black in color. The wearing of any cloth hood which covers the head
and neck and is intended to conceal an officer’s identity is prohibited in police tactical operations except on
a restricted basis to prevent the identification of undercover police personnel after a tactical operation (e.g.,
a premises search after the service of a search warrant).

Officers wearing balaclavas will limit suspect and citizen contact and avoid public view with the following
exceptions:
a. Motor officers may wear the balaclava when operating motorcycles in cold weather. Upon any contact
with citizens, motorcycle officers will immediately remove the balaclava.
b. SWAT officers may wear the balaclava when conducting tactical operations and there is the probability
of fire and/or explosives in the operational area. Under these circumstances, the balaclava is considered
protective clothing for the officer.
c. DSD SERT officers may wear the balaclava when conducting tactical operations within jail facilities or
other operations as directed by the SERT commander.

SOFT BODY ARMOR

The wearing of soft body armor vests is encouraged for all officers and is mandatory as specified below. An
officer’s yearly uniform allowance provides funds for the purchase of soft body armor.
Wearing a soft body armor vest is mandatory for:
1. On-duty uniformed police officers hired on or after July 1, 2008
2. Uniformed corrections officers hired on or after July 1, 2008 who are on duty outside of the Clark County
Detention Center
3. Patrol service representatives hired on or after July 1, 2008
4. Officers engaged in planned, high-risk tactical operations with a threat level equal to or exceeding the
National Institute of Justice (NIJ) standard for Level IIA

Exceptions will be granted to:


5. Officers in an office or classroom environment
6. Officers in a ceremonial function (i.e., Honor Guard)

Any other exception must be approved by the respective division commander.


Rifle carrier or tactical vests purchased after April 11, 2019 must be black in color with the yellow LVMPD badge on
the front and the large “POLICE” insignia across the front and back with yellow Velcro star on wearer’s left side.
Vests of a different color purchased prior to April 11, 2019 may continue to be worn until they become damaged;
however, officers must still conform to the insignia requirements as documented above.

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JACKETS/VESTS

1. Standard duty
Olive drab, two-piece jacket (shell and liner)

2. Inclement weather
a. Brown or high-visibility color raincoat
b. Resident officers – 5.11 aggressor parkas (color: tundra)
c. FTTU – 5.11 three-in-one parka (color: range red)

3. Traffic officers
May wear authorized leather jackets (at the officer’s expense) or authorized black and gold motor jackets.
(Black and gold jackets in the possession of officers no longer assigned to Traffic may continue to be worn
until they become damaged or worn but will not be replaced.)

4. Bicycle/Enduro officers
Black and yellow jackets will be issued to bike and Enduro officers only. (Jackets in the possession of officers
no longer assigned to full-time bike duties may continue to be worn until they become damaged or worn but
will not be replaced.)

5. Criminalistics Bureau personnel


May wear black or yellow jackets or vests with appropriate bureau/section markings.

6. Identification jackets
a. Yellow lightweight jackets with the words “METRO POLICE” or yellow jackets with the words “Crime
Scene Investigations” silkscreened on the back. (The lightweight or heavy weight bike jacket will not be
issued as an identification jacket.)
b. PEAP, chaplains, and ODB will wear black, two-piece jacket (shell and liner).

7. Identification/High visibility vests


Black CSI or yellow mesh vests may be worn for identification purposes or during instances of traffic control
or overtime events.

GLOVES

Gloves are mandatory for bike, Enduro, and Motor Unit officers; outside of these sections, gloves are optional. The
wearing of gloves will be at the discretion of each employee, keeping in mind the purpose of the gloves is for protection
of the hand and not to promote any particular image. White dress gloves (issued by Supply Section) may be worn for
formal events when appropriate. The following are the guidelines for all uniformed personnel:
1. No weighted or “sap” gloves or gloves with plastic knuckle inserts
2. Must have fingers (no fingerless gloves, except for bike officers)
3. Must be black or tan in color and made of vinyl or leather.
4. Disposable gloves may be worn when handling unclean subjects or objects, and disposable gloves with
reinforced tips will be made available for use during searches as added protection from punctures.
5. When not being worn, gloves must be kept out of public view (i.e., concealed completely in a pocket and not
hanging from a belt or pocket)

Leather or vinyl gloves are not to be considered as a safeguard against contact with blood or other potentially infectious
materials. Leather or vinyl cannot be thoroughly disinfected once contaminated; therefore, it poses a risk of
contamination and must then be discarded in the manner prescribed for hazardous waste materials.

SUNGLASSES/EYE PROTECTION

Sunglasses may be worn during the daylight hours only and must be of a color and style that portrays a professional
appearance.

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The following are acceptable:


1. Non-mirror lenses – Iridium lenses (Lens colors must be conservative in nature)
2. Frames and lenses free of ornamentation
3. Frames (metal or plastic) in silver, gold, black, or brown
4. Neck straps of thin material and black or brown in color

INSIGNIA OF RANK

1. Sheriff
Will wear four stars fixed to each side of the collar of the uniform shirt (top point of star pointing toward top
edge of collar, ¾ inch from the leading edge and centered between the top and bottom of the collar).

2. Undersheriff
Will wear three stars placed on the uniform in the same manner as the Sheriff.

3. Assistant Sheriff
Will wear two stars placed on the uniform in the same manner as the Sheriff.

4. Deputy Chief
Will wear one star placed on the uniform in the same manner as the Sheriff.

5. Captain
Will wear two bars fixed to each side of the collar of the uniform shirt, ¾ inch from the leading edge and
centered between the top and bottom edge of the collar.

6. Lieutenant
Will wear one bar placed on the uniform in the same manner as the captain’s bars.

7. Sergeant
Chevrons will be sewn to the sleeves of Department uniforms.

SERVICE STRIPES

Personnel having sufficient service with the Department may wear service stripes on the sleeve of the green uniform
shirt, tan long-sleeved shirt, and PSR uniform shirts. Each stripe represents four years of service. Year of service is
computed from the date the individual was commissioned as a police or corrections officer, or a combination thereof,
or hired as a PSR with LVMPD, and performing duties as such on a regular basis.

SERVICE/UNIT PINS

The following pins are authorized to be worn on the corner of the flap on the right-hand breast pocket of the uniform
shirt:
1. Department service pin
2. LVMPD miniature badge (in civilian dress only)
3. Small U.S. flag

SERVICE AWARDS

1. Department Commendations
A maximum of three award ribbons may be worn on the uniform for normal duty (see LVMPD 5/101.30,
Department Commendations, for precedence order requirements).

2. Qualifications badges
One of the following qualification badges, if earned, may be worn under the name plate on the right breast

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pocket flap:
a. Marksmanship
b. Aviation
c. Gang Liaison Officer
d. Crisis Intervention Officer

Section 4 Plainclothes Commissioned Dress Standards

WEARING OF PLAINCLOTHES BY COMMISSIONED PERSONNEL

Commissioned employees of the Department wearing civilian clothing on duty will dress in accordance with their
position requirements, taking into consideration the environment, public contact, and job responsibilities. Employees
will be in compliance with this policy at all times while representing the Department. Officers working in plainclothes
or covert assignments will maintain the ability to be deployed in uniform within one hour of notification. (Exemptions
must be approved through the division commander or the Health and Safety Section.)

DEFINITIONS

business professional Clothing that presents a semi-formal or formal professional appearance (conservative
attire suit, sportscoat, dress slacks, and tie).
business casual attire Less formal than traditional business wear, but still intended to give a professional
and businesslike impression (collared shirts, polos, sweaters, pressed khakis/chinos).

GENERAL APPEARANCE

1. Clothing will be suitable for a business environment. Clothing will be clean, pressed, and not worn, torn, or
patched. Clothing not widely accepted as business attire will not be allowed. Generally prohibited (clothing
styles and items) are: crewneck shirts, t-shirts, sweat shirts, tank tops, halters or backless dresses, see-through
fabrics, short dresses or skirts (shorter than 4 inches above the knee), sweat pants, leggings/exercise pants,
sweat suits, any type of shorts, and bib overalls. (Leggings/Exercise clothing are any stretchy material
designed to be form fitting and/or are meant for exercising or lounging. Exercise clothing is authorized during
physical fitness or defensive tactics training sessions.)

2. Must wear clothing of a fabric which is considered “dress” in nature or look (e.g., denim/jean fabric is
unacceptable).

3. Fabric of jackets, shirts, blouses, skirts, and pants must match or be of a presentable contrast of colors and
materials.

4. Clothing may not have obscene or slang slogans or advertising printed on them. Trademark brand logos of
commercial names such as that of hotels, casinos, or bars are prohibited.

5. Shirts/blouses will not be unbuttoned to an excess that compromises a professional appearance.

6. Shoes must be clean and in good repair. Safety issues should be considered in footwear selection; high heels
and/or platforms may not be appropriate in some environments (both at the discretion of the bureau/area
commander). “Flip-flops” or any casual sandals are prohibited.

7. Hats may be worn, when dressed in business casual, only outdoors, while maintaining a professional
appearance. Hats must be removed when entering any building.

PLAINCLOTHES OFFICER EQUIPMENT

1. Badge

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2. Firearm (per LVMPD 5/208.02, Authorized Firearms and Associated Equipment)


3. Department ID on your person
4. Non-uniformed commissioned personnel the rank of lieutenant and below are required to carry at least one
(1) intermediate force option (baton, oleoresin capsicum [OC] spray, or electronic control device [ECD]) on
their person when on duty (see LVMPD 6/002.00, Use of Force, “General Rules”)
a. Miniature canisters may be carried in place of full-size dispenser
b. 11.8-inch to 16-inch concealable, expandable baton may be carried in place of standard baton
c. ECDs are issued to plainclothes officers and sergeants assigned to the Criminal Apprehension Team
(CAT) and the Repeat Offenders Program (ROP)

Section 5 Civilian Dress Standards

Employees of the Department wearing civilian clothing on duty shall dress in accordance with their position
requirements, taking into consideration the environment, public contact, and job responsibilities. Employees will be
in compliance with this policy at all times while representing the Department.

GENERAL APPEARANCE

1. Clothing will be suitable for a business environment. Clothing will be clean, pressed, and not worn, torn, or
patched. Clothing not widely accepted as business attire will not be allowed. Generally prohibited (clothing
styles and items) are: crew neck shirts, t-shirts, sweat shirts, tank tops, halters or backless dresses, see-through
fabrics, short dresses or skirts (shorter than 4 inches above the knee), sweat pants, exercise pants, sweat suits,
leggings, any type of shorts, and bib overalls. (Leggings/Exercise clothing are any stretchy material designed
to be form fitting and/or are meant for exercising or lounging.)

2. Civilian employees may wear denim jeans upon approval of the bureau commander if they are well-fitted,
clean, pressed, in good repair, and worn with an appropriate top or shirt. Denim must not be studded or faded
(either by design or wear).

3. Fabric of jackets, shirts, blouses, skirts, and pants must match or be of a presentable contrast of colors and
materials.

4. Clothing may not have obscene or slang slogans or advertising printed on them. Trademark brand logos of
commercial names such as that of hotels, casinos, or bars are prohibited.

5. Shirts/blouses will not be unbuttoned to an excess that compromises a professional appearance.

6. Shoes must be clean and in good repair. Safety issues should be considered in footwear selection; high heels
and/or platforms may not be appropriate in some environments (both at the discretion of the bureau/area
commander). “Flip-flops” or any casual sandals are prohibited.

7. Hats may be worn outdoors, while maintaining a professional appearance, but must be removed when
entering any building.

CIVILIAN UNIFORM SPECIFICATIONS

Civilian personnel issued uniforms will ensure that uniforms and shirts are clean, pressed, and present a professional
appearance. Footwear and other accessories will be regulated by their division commander.
1. Supply clerks, custodians, supply technicians, shuttlers, and service aids
a. Tan long- or short-sleeved shirt with section emblem
b. Shuttlers – black mock turtleneck permissible
c. Black uniform pants
d. Olive drab jacket with section emblem only
e. Fleet personnel – dark tan baseball cap embroidered with “FLEET”

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2. Records and Fingerprint personnel assigned to the Customer Service Section and DSD technicians
a. Black smock, must be zipped or buttoned with two Department shoulder patches
1) Cannot be worn outside LVMPD facilities

3. Metro Volunteer Program (MVP)


a. Yellow long- or short-sleeved polo with MVP star patch and “Volunteer” silkscreened on the back
b. Yellow lightweight jacket with the words “POLICE VOLUNTEER”
c. Dark tan baseball cap embroidered with “LVMPD VOLUNTEER”
d. High visibility yellow-lined jacket with MVP star patch on the left chest and “LVMPD STRT”
silkscreened on the back

4. Chaplains
a. Yellow lightweight jacket with the word “CHAPLAIN”
b. LVMPD issued Polo shirt
c. Long- or short-sleeved Oxford shirt

5. UFRB Volunteers
a. Yellow long- or short-sleeved polo with “UFRB Volunteer” on the front, left chest and silkscreened on
the back.
b. Yellow lightweight jacket with the words “UFRB Volunteer”

6. Evidence Vault Technicians


a. Olive drab, two-piece jacket (shell and liner) with evidence technician emblem

7. Traffic Control Assistants


a. Tan short-sleeved or long-sleeved shirt with unit emblem shoulder patches and unit chest emblem
b. Green pants
c. Olive drab, two-piece jacket (shell and liner) with unit emblem shoulder patches and unit chest emblem
d. Grooming standards must fall in compliance with commissioned personnel

8. Patrol Service Representatives


a. Tan short-sleeved or long-sleeved shirt with unit emblem shoulder patches and unit chest emblem
b. Green pants
c. Olive drab two-piece jacket (shell and liner) with unit emblem shoulder patches and unit chest emblem
d. Black baseball hat
e. Grooming standards must fall in compliance with commissioned personnel

9. Cadets
a. Tan short-sleeved or long-sleeved shirt with unit emblem shoulder patches and unit chest emblem
b. Green pants
c. Olive drab, two-piece jacket (shell and liner) with unit emblem shoulder patches and unit chest emblem
d. Grooming standards must fall in compliance with commissioned personnel

10. Explorers
a. Tan short-sleeved or long-sleeved shirt with unit emblem shoulder patches and unit chest emblem
b. Green pants
c. Olive drab, two-piece jacket (shell and liner) with unit emblem shoulder patches and unit chest emblem
d. Grooming standards must fall in compliance with commissioned personnel

11. Sheriff Civil Deputies


a. Tan short-sleeved or long-sleeved shirt with unit emblem shoulder patches
b. 5.11 Stryke Pants
c. Olive drab two-piece jacket (shell and liner) with unit emblem shoulder patches and unit star emblem on
left chest
d. Deputy sheriff baseball hat

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e. Grooming standards must fall in compliance with commissioned personnel

EQUIPMENT ITEMS FOR PSRs, CADETS, and EXPLORERS

1. Duty belt and accessories – Uniformed personnel will not mix nylon gear with basketweave gear; however,
basketweave and leather gear can be mixed. Nylon, basketweave, and/or leather gear must be black in color.
a. Inner belt
b. OC spray and holder
c. MK3
d. Citation holder
e. Key snap
f. Keepers
g. Radio holder

Section 6 Uniform Management, Care, and Maintenance

All uniforms and equipment issued by the Department is LVMPD property and must be returned upon separation from
the Department. Each employee is responsible for the care and maintenance of uniforms and other issued equipment.

Uniforms and associated equipment will comply with specifications as set forth by the commander of the Professional
Standards Division. The Logistics Bureau is responsible for ensuring items procured by the Department meet the
specifications established.

UNIFORM ISSUANCE

1. Upon completion of their respective academies, commissioned personnel and cadet/PSR personnel will be
issued a basic inventory of equipment and uniforms. Civilian personnel may be issued uniforms and
equipment based on their assignment.

2. All uniforms and equipment are issued via Uniform/Equipment Issue Request (LVMPD 449). This includes
new and replacement issues for worn, damaged, or lost items. All requests will be reviewed and signed by
the employee’s chain of command through the bureau/area commander and must be received by Logistics
before items will be issued.
a. Employees requesting replacement of a worn or damaged item must turn in the item before receiving a
replacement. All turned in items must be cleaned.
b. Employees are responsible for replacing lost or misplaced items/uniforms, or the cost replacement dollar
value of the missing item(s) will be deducted from the employee’s final payroll check.
c. If an employee loses Department property or becomes the victim of a crime that is documented and items
are lost or stolen, the employee will attach a copy of the report to the LVMPD 449 (see LVMPD
5/103.28, Reporting Damage/Loss to Department Property and Equipment).

3. Officers assigned part-time duties (e.g., bike patrol, Enduro, sections within ODB) will be issued a reduced
inventory of those uniforms.

4. Employees are required to affix their personnel number to uniforms and equipment that are not serialized.

5. Optional, approved, non-issued items may be purchased by employees from the Department: knit cap, Tilley
hat, polo shirt, etc.

CARE AND CONDITION OF UNIFORM

1. Uniforms will not be noticeably worn or patched. Overused uniforms shall be returned to the Uniform Shop
and replaced.
2. All leather gear will be polished using a wax-based product. Lacquers and artificial polishing agents are
prohibited.

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3. Basket-weave nylon duty gear will be cleaned using non-abrasive and non-wax products. Wax-based
products should not be used. Lacquers and artificial polishing agents are prohibited.
4. The badge and hat piece will be regularly cleaned in soapy, non-abrasive solution and buffed with a soft cloth
to a high luster. Metal polish is not allowed on these items as it will remove the outer protective coating.
5. Name plates and shooting badges will be regularly polished.
6. Uniforms and jackets will be dry-cleaned as needed.
7. Soft body armor and carrier will be cleaned and maintained as recommended by the manufacturer.

REQUESTS FOR CHANGES TO THE APPEARANCE STANDARDS POLICY

This policy will be strictly adhered to and any requested changes will go through the following process:

New Uniform and/or Equipment Requests


1. All requests for new uniforms and/or related equipment must be submitted via Uniform/Equipment
Recommendation Request (LVMPD 387) and approved through the requester’s chain of command through
their division commander to the Professional Standards Division commander. The Professional Standards
Division commander will determine if the request will be forwarded to the Office of the Sheriff for approval.
2. Requests must include a fiscal impact statement for all Department purchases. The Office of Finance will
determine if the submitted fiscal impact statement can be accommodated by the current budget. Bureaus, area
commands, and units of the agency will not purchase uniform items without approval from the Office of
Finance.

Section 7 Attire for Courtroom Appearances, Administrative Hearings, and Media Briefings

1. Employees are required to wear business professional attire or the uniform of the day when appearing in any
courtroom or at any Department administrative hearing (e.g., Use of Force Board, Disciplinary Board,
Vehicle Collision Board).

2. Wearing a tie for male employees is mandatory when appearing in any District or Federal courtroom or
administrative hearing (e.g., testifying in front of governmental boards).

3. When appearing in pre-arranged television interviews, media briefings, speaking engagements, or similar
activities, employees will wear business casual or business professional attire as directed by the bureau
commander.

Section 8 Medical Exemptions

Clean-Shaven Exemption Process


1. To obtain medical exemption from the clean-shaven policy the affected employee will:
a. Contact Risk Management and request an exemption.
b. Continue to comply with the Department’s clean-shaven policy until an exemption has been certified by
Risk Management.
c. Provide medical records from treating physician documenting the nature of the skin condition, the degree
and/or severity of the condition, duration of condition, the extent the condition affects the ability of the
member to comply with the clean-shaven policy, and clearly substantiate why the exemption is needed.
The medical documentation must have been obtained within 30 days of the request for medical
exemption.
d. If the medical documentation is insufficient, submit to an examination by a Department-appointed
physician. The member will utilize personal leave time for the purposes of a medical examination
intended to determine if a medical exemption should be granted.
e. If Risk Management certifies the exemption from the clean-shaven policy, the employee will receive a
copy of the form.

2. Upon medical exemption certification:

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a. Employees with a medical exemption will not shave. Facial hair will be clipped not to exceed ¼ inch in
length (not longer than a #2 clipper guard). The hair will grow naturally and there will be no edging,
trimming, or shaving of the hair on the lip, face, neck, or cheeks. Goatees or other customized beard
creations are not permitted while on duty.
b. Exemptions expire one year from the date issued, unless the medical certification provides for a shorter
duration, and employees must reapply at the end of each term unless the affected employee has provided
documentation from a treating physician stating that the affected employee’s medical condition is
permanent and chronic.
c. In the event of a mobilization requiring the use of a gas mask, the exemption to this policy may be
temporarily revoked. The employee must be prepared to shave and have a shaving kit available.

Employees who qualify for a religious exemption from the clean-shaven policy per LVMPD 5/101.24,
Harassment and/or Discrimination Prevention and Complaints, will also adhere to the above grooming
standards.

3. Risk Management will:


a. Forward written instructions to the member requesting an exemption.
b. Upon certification, ensure that the date of issuance is recorded on the member’s copy of the Medical
Exemption form.
c. Ensure that the original Medical Exemption form is placed in the member’s medical file.
d. Ensure that the employee and their bureau/area commander receive a copy of the Medical Exemption
form.
4. Bureau/area commanders will ensure that:
a. A copy of the Medical Exemption form is placed in the supervisor’s employee performance file (SEPF).

For any other medical exemption, contact Risk Management. (4/19, 12/20)■

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4/103.19 GIVING TESTIMONIALS, SEEKING PUBLICITY

Members shall not give testimonials, or permit their names or photographs to be used for advertising purposes.
Members shall not seek personal publicity either directly or indirectly in the course of their employment. (7/73)■

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4/109.10 CARE OF PROPERTY AND EQUIPMENT

It is the policy of this Department that all employees charged with the care and control of Department property and
equipment will use these items responsibly and in the manner for which they are intended.

DEFINITIONS

Department property Any item that is Department-owned, and/or Department funded, or used by an
employee for its assigned use, including any personally owned weapon used on duty
or as a backup weapon.
secured compartment A compartment that can only be opened with a key or combination, is permanently
within a vehicle anchored to the vehicle, and conceals the items inside (e.g., a trunk that cannot be
opened directly from the driver compartment of the vehicle, locking glove box, or
trunk safe).

Employees also bear the responsibility for the proper care, maintenance, and serviceable condition of any Department
property issued for or assigned to their use, including equipment issued during special events. Employees will
promptly report all damage, theft, or loss of Department property or equipment to their immediate supervisor and
follow the procedures established in LVMPD 5/103.28, Reporting Damage/Loss to Department Property and
Equipment. Employees may be held responsible, including disciplinary action, for the replacement or repair cost of
lost or damaged Department equipment because of willful or negligent action. All equipment, clothing, and uniforms
issued by the Department is LVMPD property and must be returned upon conclusion of employment.

Employees are responsible for the proper storage and security of property and equipment or animals assigned to them
that if lost or stolen would constitute a breach of security. Firearms will not be left unsecured in an LVMPD facility
(e.g., an office setting, briefing room, or locker room).

Department property, equipment, animals, and controlled items (e.g., uniforms, badges, identification cards, weapons,
radios, body-worn cameras, computers, personnel rosters, or phone rosters) will not be left in any vehicle, except:
1. Department property locked in a marked or un-marked Department-owned vehicle while the employee is on
duty unless exigent circumstances prevent the locking of the vehicle. Firearms carried on duty or as a back-
up weapon will be carried in accordance with LVMPD 5/208.00, Firearms Procedures, and will not be left
unsecured in a Department vehicle.
2. Department property stored in any vehicle that is parked in the enclosed garage of an employee’s residence
when the garage door is closed and secured.
3. Department property locked inside a secured compartment or locked trunk within the employee’s personal
vehicle or Department-owned vehicle.
4. Department property locked inside a vehicle parked within the fenced perimeter of a police facility.
5. Department-owned canines may be left in a secured canine vehicle so long as the vehicle is climate controlled
and being monitored by the canine heat monitoring system.

When housed in a police facility, equipment will be secured in a locker or other type of secure compartment. When
housed in a police facility, animals will be secured in a kennel or stall. Firearms will be kept from public view/access
when not worn (e.g., secured and stored in a desk, briefcase, locker, or other secure location).

When housed at an employee’s residence or the residence of another, Department firearms and weapons used on duty
or as a backup weapon will be kept in a secure location inaccessible to children or others. Department-owned canines
will be secured in an approved kennel provided by the Department and under the direction of the K-9 Detail Manual.
If a question exists regarding the adequacy of an employee’s Department property or equipment storage arrangements,
the employee’s bureau commander will make the determination. In the event of a Department-owned canine, the K-9
section lieutenant will make the determination.

Supervisors will investigate and report the circumstances of negligence, misuse, abuse, or careless loss of Department
property and equipment that is readily identified as police equipment used in the line of duty or a Department-owned

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canine. All firearms that are lost or stolen will immediately be reported to the local authorities once the employee has
knowledge of loss or theft.
In the case of Department-owned canine, any accidental or unintentional bites, negligent behavior, or carelessness
with the animal resulting in injury to a citizen or the animal may subject the employee to disciplinary action. The
only exception to this regulation is when the assigned canine is kenneled at a Department-approved animal facility
or at a Department-contracted veterinarian facility. See LVMPD 6/002.00, Use of Force Tools and Techniques,
Section VIII., Use of Canine, item 4. (8/18, 3/21)■

HB 00124
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4/110.02 IMPROPER USE OF ELECTRONIC COMMUNICATION DEVICES

Members will refrain from unnecessary conversation and/or the transmission of superfluous messages via voice or
digital radio communications or electronic mail. All rules and regulations of the Federal Communications Commission
(FCC) will pertain to department communications (i.e., the use of obscene words or language, or the willful or
malicious interference with any communications). All radio and electronic communications must pertain to
department/police functions. Any improper use of the communications or computer systems will result in disciplinary
action.

Cell phone cameras or video recorders are not intended to be used for official purposes where photography or video
is required or desirable. Due to issues involved in the collection and storage of criminal history information, record
sealing, chain of custody issues and other legal concerns, members are not authorized to take, use, collect, store or
distribute photographs or videos taken of suspects, crime scenes or any other official department activity, either on a
department issued cell phone with photo and video capabilities or a personally owned cell phone camera or any other
personally owned camera or photo/video device. Exceptions must be approved by the bureau/area commander and the
camera specifications must be approved by Information Technologies Bureau.

With the exception of the Public Information Office, no one shall publish or display (i.e. Facebook, Twitter, or
YouTube) any department photos or videos without the authorization of their bureau/area commander.

All employees are further advised that the department, in order to manage its communications/computer systems, may
at any time, with or without warning, monitor communications, both digital and/or voice, on any of its systems,
including radio, computer, pager/voice mail and telephone systems. In addition, such communications can become
public record if subpoenaed. (3/09, 2/11)■

HB 00125
Las Vegas Metropolitan Police Department
Partners with the Community

5/111.10 ELECTRONIC COMMUNICATIONS GUIDELINES

It is the policy of this department that electronic mail, Internet, Criminal Justice Information Systems (CJIS), and
telecommunications access are resources made available for department employees to communicate with each other,
other governmental entities, companies and individuals for the benefit of the department. The systems are not to be
used for employee personal gain or to support or to advocate any non-departmental business or purpose. In addition,
all computers, databases and confidential information must be protected from unauthorized or inappropriate use. The
following Computer Use Agreement will be followed by all LVMPD employees when logging onto a department
computer.

This disclaimer strictly prohibits the use of device for personal reasons. Such as but not limited to:
1. Downloading, creating or accessing MP3, .WAV or sound files that are not business related.
2. Downloading, creating or accessing pictures, graphics or video files that are not business related.
3. Accessing websites that are not business related.
4. Downloading/installing application software or other programs that were not purchased by LVMPD.
Including but not limited to: freeware, demo version, evaluation trial version, beta versions, toolbars,
screenshots, backgrounds, themes, etc. without the permission from ITB.
5. The use of printers or any peripherals for non-business related purposes.
6. The use of portable hard drives and USB “thumb” drives which are not authorized by ITB.
7. Unauthorized tampering or modifying the operating system or hardware configuration of a computer,
printer, notebook or Toughbook. Any modifications to your computer must be performed or authorized by
ITB.
8. Attempting to access another member’s account for which they do not have authorization or explicit
consent is prohibited.

COMPUTER AND PASSWORD SECURITY

A password is a unique user access code required to enter any LVMPD computer system and application system. For
CJIS security compliance, the password must be a minimum of 8 characters, the password must be different than your
user name or User ID, the password may not be reused, and the password may not be a dictionary word or a proper
name. A password will not be shared or otherwise compromised without the express permission of a lieutenant, or
higher. If it becomes necessary to divulge a password to another member, the password should be changed as soon as
the need for the “shared” password is no longer required. Information Technologies Bureau will automatically request
all users to change their password every 90 days.

When necessary to leave a work area unattended, members must log out of the computer or lock their workstation to
ensure security of their computer and e-mail system account. (Note: To lock a workstation, press “ctrl-alt-delete”, then
select “lock workstation”. To unlock the workstation, select “ctrl-alt-delete,” then enter your password when
prompted.) Members may allow other members to “proxy” into their e-mail system account when necessary to allow
for the conduct of daily business, but become responsible for any activities conducted on their account even by the
proxy. (Exception: Information Technologies personnel may proxy into workstations, with verbal permission of the
user, to conduct official business as necessary.)
Monitors must be positioned so as not to be in view of unauthorized personnel. If it is not possible to change the
position, the monitor must be completely darkened, turned off, or covered with a monitor security screen until
unauthorized personnel are not within viewing range.

Computers on the first level of buildings must not have the monitors facing the outer windows. If floor plan prohibits
this, the blinds must be closed at all times to prevent unauthorized viewing of monitors.

“TO EVERYONE” E-MAIL MESSAGES

The “LVMPD_EVERYONE” and “DSD_EVERYONE” addresses in the email system allow employees to
communicate with all members of the Department who have an assigned Department email address. These addresses
are not to be used for any non-departmental business or purpose. All email correspondence addressed to
“LVMPD_EVERYONE” must be routed through the respective bureau/area commander or their designee for approval

HB 00126
Las Vegas Metropolitan Police Department
Partners with the Community

prior to being forwarded to the Office of Public Information for publication. Information will not be published unless
the email comes from the computer of a bureau/area commander or their designee. If the correspondence is extremely
time-sensitive, the Office of Public Information can be contacted via telephone.

ELECTRONIC COMMUNICATIONS CONTROLS

LVMPD reserves the right to monitor and will conduct an annual audit of all aspects of electronic telecommunications
including e-mail and Internet communications. No electronic communications systems within this department are
considered private or confidential. It is against the policy of this department to attempt to gain access to another
members account for which they do not have authorization or explicit consent. If it becomes necessary for an
employee’s supervisor to monitor messages to assure efficient performance and appropriate use, they must first obtain
the approval of a bureau/area commander or above, before requesting access to electronic communications records
(i.e., e-mail, pagers, and cell phones).

DEPARTMENT E-MAIL

The approval of the bureau/area commander or above is required before requesting Information Technologies grant
monitoring capabilities of another employees’ department e-mail.

Information Technologies Bureau will:


1. Upon receipt of request to monitor another employee’s department e-mail, ensure approval has been obtained
from a bureau/area commander or above.
2. Grant monitoring capabilities.
3. Follow up with the requestor in 30 day increments to verify if monitoring continues to be necessary.
4. When no longer necessary, disable monitoring capabilities.

CRIMINAL HISTORY SENT VIA E-MAIL

Criminal History Record Information (CHRI) that is sent through e-mail must meet the following requirements:
1. No encryption necessary for e-mails within LVMPD.COM, CCDANV.com, CityofHenderson.com, or
ClarkCountyNV.gov e-mail domain addresses. All e-mails that do not fall within one of the above e-mail
domains must have the CHRI encrypted.
2. Encryption software will need to be provided from, and coordinated with the receiving Agency, along with
approval and coordination/oversight from ITB
3. CHRI sent to other agencies must be logged with a LVMPD 507, Secondary Dissemination Log.

DEPARTMENT PAGERS

The approval of the bureau/area commander or above is required before requesting the Information Technologies,
Cell Phone Detail grant monitoring capabilities of another employees’ department issued pager (i.e., pager cloning).

Radio System Bureau


1. Upon receipt of request to monitor another employee’s activity, ensures approval has been obtained from a
bureau/area commander or above.
2. Grants monitoring capabilities.
3. Follows up with the requestor in 30 day increments to verify if monitoring continues to be necessary.
4. When no longer necessary, disables monitoring capabilities.

DEPARTMENT CELLULAR PHONES

Bureau/area commander, or their designee, receives a paper copy of the cell phone bills/logs on a monthly basis to
ensure proper usage and reimbursement. Access to another employee’s cell phone records, beyond these provided
monthly, must be approved by a bureau/area commander or above, prior to requesting copies from the Information
Technologies, Cellular Phone Detail.

HB 00127
Las Vegas Metropolitan Police Department
Partners with the Community

Information Technologies Bureau, Cellular Phone Detail will:


1. Upon receipt of request to monitor another employee’s activity, ensure approval has been obtained from a
bureau/area commander or above.
2. Grant monitoring capabilities.
3. Follow up with the requestor in 30 day increments to verify if monitoring continues to be necessary.
4. When no longer necessary, disable monitoring capabilities. (5/12, 3/20)■

HB 00128
Las Vegas Metropolitan Police Department
Partners with the Community

4/109.07 UNAUTHORIZED USE OF DEPARTMENT PROPERTY, FACILITIES, OR ADDRESS

No member of the Department shall use Department property or facilities for personal, social, or unofficial purposes.

No member shall use the Department address for unofficial purposes such as vehicle registration, vehicle title, or
personal mail that does not contain law enforcement related material.

DMV APPLICATION FOR ALTERNATIVE ADDRESS

At the time of application for or renewal of a driver’s license, an officer may request the display of their employer’s
address. The address to be used will be 3141 Sunrise Ave., Las Vegas, NV 89101. The Department of Motor Vehicles
(DMV) will forward the request to LVMPD. Only bureau commanders are authorized to approve the request.

LVMPD is not responsible for personal mail delivered to any Department facility. (3/09, 12/19)■

HB 00129
Las Vegas Metropolitan Police Department
Partners with the Community

2/125.00 COPYRIGHT OF LVMPD EMBLEMS (BADGE/LOGO)

The design of the LVMPD badge is protected by federal copyright. Reproductions of the badge must have the
copyright symbol, “©1973 LVMPD.”

The emblems commemorating Metro’s anniversaries have been registered with the State of Nevada. Reproductions
of the emblems are to be accompanied by the trademark (TM) and Service Mark (SM) symbols.

“LVMPD” has also been registered with the State of Nevada and will be displayed as LVMPD®.

It is the policy of this department that all reproductions (other than for official use) of the badge, anniversary emblems
or the logo “LVMPD,” including artwork, must be approved by the Undersheriff prior to use. Requests are not
necessary for use of LVMPD copyrighted material on perishable items such as cakes for retirement ceremonies or
items such as paper retirement banners, which are intended to be used for one such occasion and discarded.

SELLING OF LVMPD MERCHANDISE


Several special interest groups affiliated with the department sell merchandise bearing the LVMPD insignia or
emblem to raise funds to benefit their group (i.e., Traffic and K-9 for competitions, Gangs Section for their annual
convention, the Explorers, and many others). These special interest groups must meet the following criteria prior to
selling any copyright merchandise:
1. Special Interest Group must be affiliated with the department. Profits must benefit the special group affiliated
with the department.
2. Special Interest Group must be a current 501C3 Tax Exempt Non-Profit (applied for through the IRS).
3. All merchandise bearing the copyrighted LVMPD emblems must be pre-approved by the Undersheriff.
a. Submit the artwork or a prototype for the Undersheriff to view;
b. Submit a plan to include the number of items to be produced, the price at which they will be sold, who
the projected consumer will be, and the means by which the merchandise will be sold.
4. After receiving approval of the Undersheriff, place order for items to be sold.
5. All purchases, sales and transactions must take place outside of the departmental processes. (12/10, 12/14)■

HB 00130
Las Vegas Metropolitan Police Department
Partners with the Community

4/103.21 CHARITABLE FUND RAISING/ SOLICITING ON DUTY

CHARITABLE FUNDRAISING

LVMPD members have a long history of being charitable and participating in non-profit events.

Vendors, persons, or department employees will be allowed to use limited department time to participate in non-profit
charities/events. The on-duty time spent toward these charities will be minimal and will be limited to the time devoted
to the administrative tasks of passing out and collecting pledge forms. All other time volunteered will be done during
the employee’s off-duty hours and hours volunteered will not be compensated. Employees who participate in events
such as Brass Challenge, police memorial relays, bicycle rides, or other sporting events may be allowed vacation or
bonus time to compete and will not use department time to participate.

Any department employees accepting donations on behalf of any charity must go through an auditing process
established by the charity to account for the money or items collected. If a procedure for accounting and handling
earned funds or donations is not available, the LVMPD Cash Handling Procedural Guidelines for Charitable
Fundraising Organizations will be used and is available in the LVMPD Intranet under the Accounting Section.

LVMPD MERCHANDISE

There are multiple sections within the department which sell LVMPD apparel and keepsakes to earn funds for
competitions, etc. It is the policy of this department all such sales must be approved by the Charitable Fundraising
Board prior to any items being ordered for sale. A LVMPD 533, Charitable Fundraising Request Form, must be
submitted after ensuring all merchandise is designed to comply with LVMPD 2/125.00, Copyright of LVMPD Emblem
(Logo/Badge), and there is an accounting system in place for earned funds. Such items may be advertised through the
LVMPD Intranet (Everyone Notices). Units or individual employees who sponsor or lead a fundraising activity should
be responsible for pickup and delivery of the items they are selling.

OTHER NON-LVMPD MERCHANDISE

The sale of non-LVMPD merchandise for charitable fundraising will not be allowed while on-duty or on department
property.

Members are prohibited from soliciting contributions and buying or selling of any and all merchandise while on-duty
(even if an outside employment request has been approved). This includes outside fundraisers for schools or school
groups, sports teams, and any other extra-curricular activities (i.e., candy bars, cookie dough, Girl Scout cookies, etc.).
In addition, the solicitation for merchandise parties (i.e., Pampered Chef, purse or jewelry parties, etc.) is also
prohibited under this restriction. This will prevent any involved party from feeling intimidated or obligated to
participate.

LVMPD INTRANET AND EVERYONE (E-MAIL) NOTICES

The LVMPD Public Information Office (PIO) will internally promote department sanctioned fundraising events and
the sale of department affiliated merchandise through Intranet postings and Everyone Notices (e-mails).

The PIO will send press releases for department sanctioned events only after notification from the Charitable
Fundraising Board Chairperson, or designee, has confirmed the event has been approved. Once the event organizer
has approval to hold the event, PIO will be notified.

CHARITABLE FUNDRAISING BOARD

A Charitable Fundraising Board will be formed, with representation by the following positions:
Division Commander, Support Division – Chairperson
Police lieutenant or Captain
Corrections lieutenant or Captain

HB 00131
Las Vegas Metropolitan Police Department
Partners with the Community

A PIO member
Director or Manager from the Accounting Section
A Director
A member from the Office of General Counsel

The Charitable Fundraising Board will meet quarterly, or as needed, and have the responsibility of reviewing LVMPD
related fundraising requests. Requests for charitable fundraising can be submitted to the Charitable Fundraising Board
for their approval, using the Charitable Fundraising Request Form. The board will grant a one-time approval for a
specific event, grant approval on an on-going basis, or deny the request.

OTHER NON-SANCTION EVENTS

Members must refrain from soliciting or otherwise participating in non-sanctioned LVMPD charities while on-duty
or in uniform, or in any manner that directly associates LVMPD with a charity. Participating in charitable events
while identifying oneself as an LVMPD member gives the perception LVMPD is supporting the event. For this reason,
department members may not use LVMPD vehicles or equipment to support non-sanctioned fundraising events.
Having LVMPD equipment and vehicles at a fundraising event leads the public to believe LVMPD supports the charity
or event. Additionally, the LVMPD cannot use taxpayer dollars to pay for equipment, vehicles, demonstrations, and
manpower used for entertainment or exhibitions at non-sanctioned fundraisers.

SELLING OF FOOD ITEMS

The Southern Nevada Health District (SNHD) has jurisdiction over all public health matters in the Health District,
NRS Chapter 439. This includes the adoption of regulations regarding food establishments and food handling, NRS
446.940(2). All food establishments must follow these regulations, though there are some exceptions. When selling
food items, department members must acquire the exemption from SNHD prior to submitting the LVMPD 533.

VOLUNTARY SERVICES

Charitable activities and fundraising (for events such as homeless individuals, military families, Santa Cops, Turkey
Drive, LVMPD family, & etc.) can still be accomplished. The planned amount of duty time spent on the event must
be supported by the Division Commander, and approved by the Charitable Fundraising Board.

Off-duty officers are prohibited from volunteering their services to private or charitable organizations for the purpose
of performing traffic control, security, or other law enforcement-related activities or functions.

Private organizations are not mandated by Nevada law to provide worker’s compensation coverage for volunteers. As
such, worker’s compensation is generally not provided for personal injury incurred in voluntary police activities, even
though such activity primarily benefits the private organization.

This policy applies to both uniformed and non-uniformed services.

501(c)(3) CHARITABLE ORGANIZATIONS

Individual sections within LVMPD are prohibited from setting up 501(c)(3) Charitable Organizations. Board
members of these organizations assume a financial responsibility for all monies taken in, how funds are used, any
misappropriations, and they are subjected to tax reporting requirements. Exceptions are the 501(c)(3) programs
already established as of July 1, 2013, and those that exist through the PPA, PMSA, or PPACE. Other areas should
apply to run fundraising programs through the already established Metro Foundation.

PROCEDURE

LVMPD affiliated group requesting to Fundraise will:


1. Determine if item(s) complies with LVMPD 2/125.00, Copyright of LVMPD Emblem (Badge/Logo).
2. Complete the Charitable Fundraising Request Form, LVMPD 533.

HB 00132
Las Vegas Metropolitan Police Department
Partners with the Community

3. Submit the form through their chain to the Division Commander for approval.

Division Commander will:


4. Review request and forward form to Charitable Fundraising Board Chairperson (Support Division
Commander).

Charitable Fundraising Board will:


5. Quarterly, or as needed, review all Charitable Fundraising Request Forms.
6. Determine if Fundraising Request is consistent with the LVMPD mission, ensures appropriate use of solicited
funds, and can be classified as a charitable event.
7. Approve or deny request.
8. Notify group of approval or denial of request by returning a copy of the Charitable Fundraising Request
Form, through the division and bureau/area commander, with decision appropriately noted.
9. Forward copy of approved requests to PIO.

LVMPD affiliated group requesting to Fundraise will:


10. Ensure the proper charitable organization receive funds collected on their behalf. (4/16, 3/17)■

HB 00133
Las Vegas Metropolitan Police Department
Partners with the Community

5/111.04 DEPARTMENT MEMBER IDENTIFICATION CARDS

All department members and volunteers will be issued a photo identification card by the Records and Fingerprint
Bureau that will be carried with them on duty. This photo identification will be presented for viewing, upon request
and whenever practical, to the public to aid identification of personnel. This section does not apply to members acting
in an undercover capacity.
Upon issue, a photo identification card will be valid for five (5) years. Members shall obtain new cards within 90
days after transfer to any non-uniform assignment that may cause them to substantially alter their appearance (i.e.,
Vice Section or Narcotics Crime Section). Members leaving such assignments shall obtain a new identification card
within 15 days after transferring to a uniform assignment or any other assignment requiring compliance to grooming
standards. It will also be the responsibility of members to obtain a new card within 15 days of the expiration date or
change in their name, rank or classification.

Member/Volunteer will:
1. Report to the Records and Fingerprint Bureau in proper business attire or uniform (the only exception will
be upon approval of the bureau commander for officers in non-uniform assignments that may cause them to
substantially alter their appearance):
a. New members will provide an In & Out Sheet from the Personnel Management Team, Office of Human
Resources.
b. Volunteers provide a referral from the Office of Human Resources.
c. Current members provide former or expired identification card or event number for lost/stolen card (see
LVMPD 5/103.28, Reporting Damage/Loss to Department Property and Equipment).

Note: Members who have changed their name must bring their updated social security card indicating the new name
to Payroll Section prior to reporting to the Records and Fingerprint Bureau for new identification.

Retiring/Retired Members will:


2. Report to the Records and Fingerprint Bureau in proper attire or uniform for their retirement photo.
3. Request replacement identification card through the Office of Human Resources, who will verify eligibility
through the Office of the Undersheriff and notify the Records and Fingerprint Bureau.

Records and Fingerprint Bureau will:


4. Verify information through the Employee Roster or notification from Office of Human Resources and photo
identification.
5. Capture member/volunteer photo and signature if necessary.
6. Issue photo identification card to member/volunteer, or
7. Forward retirement identification card to the Office of the Sheriff or provide replacement card to retiree.
8. Invalidate former or expired identification card:
a. If the member wishes to keep the expired identification badge, the Fingerprint Bureau can return the
invalidated (hole-punched) badge to the member.
b. If the member doesn’t wish to keep the expired badge, the Fingerprint Bureau will shred the badge.

The wearing of member identification (hang badges, badges, etc.) is mandatory at all LVMPD facilities when in
civilian attire. Member identification badges will be clipped on, with picture facing forward, and worn over the left
pocket or left side of the chest area or worn on a lanyard around the neck.

Members will not display their identification card while off-duty or engaged in non-police activities.

ALL IDENTIFICATION CARDS, INCLUDING RETIREMENT IDENTIFICATION CARDS, REMAIN THE


PROPERTY OF THE LAS VEGAS METROPOLITAN POLICE DEPARTMENT. (5/13, 7/15)■

HB 00134
Las Vegas Metropolitan Police Department
Partners with the Community

4/102.13 DETENTION FACILITY SECURITY

Only authorized personnel on official police business will be admitted into the LVMPD Detention facility through the
vehicle sally ports and walk-in door located on First Street. Weapons will be stored in the areas provided, prior to
entrance into a detention facility security area. Non-uniformed personnel will display an authorized hang badge while
inside the LVMPD Detention facility. (7/78)■

HB 00135
Las Vegas Metropolitan Police Department
Partners with the Community

5/101.32 REQUESTING REIMBURSABLE OVERTIME

It is the policy of this department that department members are permitted to perform reimbursable overtime only when
authorized by the Events Planning Section, which schedules events, makes assignments, and ensures compliance with
city and county codes, when applicable.

GENERAL

To qualify for reimbursable, overtime an officer must have satisfactorily completed field training. Upon completion
of Field Training, officers on probation are authorized to create an account in the Cop Logic Overtime Management
System (OTMS) and sign up for any available event. If during the officer’s probation, his supervisor determines that
the officer’s work performance is not meeting standards, the Events Planning Section (EPS) will be notified through
the officer’s chain of command. The officer’s OMS account will be suspended by EPS until advised the officer’s
performance has returned to a satisfactory level. Dispatchers who have not been released to work a channel alone are
not eligible to work reimbursable overtime and may not create an account.

When a supervisor is not assigned, the senior officer working the event will be responsible for ensuring a safe event
by maintaining professionalism at all times, upholding the policies and standards of the department as well as the EPS.
The senior officer will contact an area supervisor or watch commander in situations requiring supervisory approval of
response (e.g., use of force, citizen complaints, etc.).

Officers found in violation of department policies, Events Planning Section guidelines, and/or complaints of
misconduct may be prohibited from working reimbursable overtime for a period of up to 120 days. Contact reports
will be forwarded to the immediate supervisor for action. Reimbursable overtime assignments are a privilege and not
guaranteed for any officer. All events are subject to cancellation at any time. Events Planning overtime is handled as
regular overtime, in accordance with LVMPD 5/101.33, Overtime, which states (in part):

“Employees who are on sick leave, worker's compensation; FMLA, military leave, maternity, paternity,
extended or catastrophic leave; modified duty; leave without pay; or suspensions are not eligible to work
overtime of any kind (except emergency overtime). Employees who are on suspension are considered to be
suspended from the date and time indicated in the suspension notice until the beginning of their next regularly
scheduled work day. (Exception: Personnel who are in an ADA Accommodated Position, in accordance with
LVMPD 5/110.17, Disability Accommodation, may work overtime under certain conditions with the
approval of the Health and Safety Services Section or by direction of the Sheriff.)

Employees are not eligible to work overtime during their regular duty hours on any day that they are on
compensatory leave, vacation, bonus, off in lieu of holiday, floating holiday or professional leave. However,
employees can work overtime outside their regular duty hours during this type of leave and on any RDO
during those work periods. It should be noted, however, that working reimbursable overtime does not relieve
the employee from the responsibility of reporting on time for any normal tour of duty. All employees are
subject to emergency overtime, as necessary.

Officers who are on modified duty due to their involvement in a use of force incident are exempt from the
prohibition of working overtime. However, these officers will only be allowed to work in positions that have
no potential for suspect contact, such as in a Unified Command Post.”

Unless specifically requested by the Events Planning Section through the appropriate supervisors, there will be no
shift-adjust or RDO adjust in order to work an event. The only exceptions to this rule are Resident Area officers
working reimbursable overtime at community events within their assigned areas. This exception must be approved by
the bureau commander and will be based upon operational need (i.e.: cost effective, impractical to staff otherwise due
to location or distance, eliminate travel pay for non-Resident Area officers, etc.).

HB 00136
Las Vegas Metropolitan Police Department
Partners with the Community

STAFFING AUTHORIZATION

Department members will not casually or formally solicit overtime for their respective detail; this includes supervisors
and/or officers assigned to specialty units. Members are not authorized to schedule themselves or anyone else to work
any reimbursable overtime events, except as provided below. All requests from businesses or citizens for officers to
work reimbursable overtime must be forwarded to and approved by the Events Planning Section. Members receiving
such requests will refer requestor to the Events Planning Section and will not agree to/nor work any reimbursable
overtime unless properly approved and staffed through the Events Planning Section.

Officers will not use their badges/identifications to obtain access to an event, unless on official duty. Officers working
an event in an official capacity (not in a reimbursable overtime status) will sign in at the Events Planning command
post (CP). If no CP is established, officers will personally contact the senior officer assigned to the event to advise
him/her of their presence. Only officers on official duty, or assigned to an event are authorized access to the event.
The supervisor, or senior officer assigned to an event by the Events Planning Section is responsible for ensuring that
only authorized personnel gain access to the event. If admittance is obtained, the supervisor/senior officer will advise
the venue manager (if possible) of the presence of additional officers. At the conclusion of the event, the
supervisor/senior officer will complete a memorandum explaining the circumstances for which access was approved
and forward to the Events Planning Section.

Any exceptions to staffing authorization for reimbursable overtime must be approved by the Events Planning Section
lieutenant, or designee.

PROCEDURE

Events Planning Section will:


1. Coordinate and schedule authorized reimbursable overtime for motion picture and television productions,
parades, rallies, sporting events, concerts, and other special events.
2. As part of the permit process for special events, administer the program to ensure strict adherence to policies,
statutes, and other matters by involved members, including eligibility.
3. Provide written instructions regarding the specifics of an assignment to include, but not limited to, equipment
needs, parking, briefings, peculiarities of the event, etc. Failure to abide by policies, procedures or
instructions, or any other actions which bring discredit to the department, may result in disciplinary action or
prohibition of future reimbursable overtime.
4. Notify officers to work events as necessary in situations including, but not limited to, the reserve list being
exhausted, short notice of an event, or special equipment needs.

Officers, Dispatchers and Sergeants Requesting/Working Reimbursable Overtime will:


5. Each week after 1800 hours on Friday and before 1000 hours on Monday, log onto the Coplogic Overtime
Management System (OTMS) website and review the available overtime assignments.
a. The Events Planning Section is responsible for the daily administration, operation, and integrity of
OTMS.
b. Supervisors, officers and civilian coordinators assigned to the Events Planning Section are exempt from
the above procedure.
c. The specific guidelines, oversight, and restrictions pertaining to the Events Planning Section will be
detailed in the Events Planning Section Manual.
d. There are no limits on an officer’s reimbursable overtime, however, officers assigned to the Events
Planning Section will not have unlimited access to reimbursable overtime.

In order to create an account in the copLogic Overtime Management System, eligible Police Officers, Police Sergeants,
Corrections Officers, Corrections Sergeants, and Dispatchers shall go to the following web sites and follow the
provided directions:

Officers: http://secure.coplogic.com/otms/usersignup/100443400/100443601
Sergeants: http://secure.coplogic.com/otms/usersignup/100443400/100443602
Dispatchers: http://secure.coplogic.com/otms/usersignup/100443400/100443600

HB 00137
Las Vegas Metropolitan Police Department
Partners with the Community

CO: http://secure.coplogic.com/otms/usersignup/100443400/100451500
CO Sgt: http://secure.coplogic.com/otms/usersignup/100443400/100451501

After an account has been created, department members are responsible for logging into the system, and prioritizing
their choices for overtime between the hours indicated in step 5 above.

6. Each Monday morning the OTMS will randomly assign department members to the available overtime
positions and send an e-mail notification to the officers confirming their assignment.

Additional requirements concerning the Overtime Management System:


a. If, after being assigned, an officer cannot work the event, the officer must immediately go to the OTMS
website to cancel themselves off the assignment.
b. Officers may sign-up for themselves and one other officer on the OTMS website. Both officers must
select each other in order to be assigned together. Members who sign up another member who cannot
work overtime will have their event cancelled.
c. Officers will not sign up for an assignment that is in conflict with normal duty hours. Ending times on
most events are estimates only and cannot be guaranteed.
7. Ensure that the written instructions pertaining to the event are printed out and reviewed as soon as possible
after being scheduled to work an overtime assignment. Members must confirm the information, including
date, time, location and instructions for the overtime position.
8. Pick up required authorized equipment from the station of assignment, or if not assigned to a patrol station,
from the area command in which the special event is held. Unauthorized equipment will be returned to the
station and pay adjusted for the time required to do so. The officer may also be subject to disciplinary action.
9. Report to the assignment with sufficient report forms, citations, equipment, etc. If working a traffic control
or pedestrian control assignment, on public or private property, wears the department approved reflective
vest for visibility. Vests are available at area commands or the Supply Section.
10. Contact the Events Planning Section immediately if unable to report to an assigned event. Members are NOT
authorized to find their own replacement.
11. Members failing to report to an assignment will be considered in violation of the department policy regarding
reporting for duty, and depending on the circumstances, may be prohibited from working reimbursable
overtime for a period of up to 120 days.
12. Call the Overtime Secure Line (593-5014) upon securing from an event, and reports name, P#, event worked,
and date/time logged on/off the event. Members need to be concise in their reports, and ensure that only one
member calls in the times. Members will not be paid for an event until the secure times are reported to Events
Planning.
13. Sergeant or senior member send a memo to the Events Planning supervisor reporting any significant incidents
during the tour of duty, such as use of force, accidents, injuries to the officer or others, liability issues,
complaints or commendations and recommendations for improvement or problems encountered.

Events Planning Lieutenant/Sergeant will:


14. Research event problems and/or recommendations and provide a written response to officers/supervisors
inquiries.
15. Investigate complaints of members not following Events Planning Section guidelines or complaints of officer
misconduct while working reimbursable overtime. Recommend revoking the privilege of working
reimbursable overtime for a specific period or completes applicable Incident Report if appropriate.
16. Make final decisions regarding member eligibility for working reimbursable overtime. Complete and submit
Contact Reports through the member’s chain of command and notify Payroll Section of any member’s
ineligible for reimbursable overtime assignments.
17. Issue specialized equipment, such as binoculars, mass casualty bags, reflective vests, etc., to supervisors and
employees for specific events.
18. Monitor and complete unannounced quality checks on events on a regular basis. (10/17, 4/18)■

HB 00138
Las Vegas Metropolitan Police Department
Partners with the Community

5/106.04 FLYING WHILE ARMED; TRANSPORTING PRISONERS AND PROTECTING


DIGNITARIES ABOARD COMMERCIAL AIRLINES

Commissioned officers, who have an operational need to fly armed on a commercial aircraft as authorized by their
chain of command, must follow these procedures prior to arriving at the airport.

REQUIREMENTS TO CARRY WEAPONS ABOARD COMMERCIAL AIRCRAFT


1. Be a full-time sworn/commissioned law enforcement officer.
2. Be authorized by LVMPD to have the weapon in connection with assigned duties, and have an operational
need to fly armed as defined by Title 49 Code of Federal Regulations and further explained in the next section.
3. Have completed the training program “Law Enforcement Officers Flying Armed,” mandatory per Title 49 of
the Code of Federal Regulations.

The bureau/area commander (as the authorizing LVMPD official) of the traveling officer is responsible for ensuring
the above criteria have been fulfilled prior to authorizing the request and that the LVMPD 225/226 form has been
signed and scanned into OnBase. Authorizing an officer to fly armed for reasons other than those specified in Title
49 CFR may result in the officer being restricted from boarding the aircraft, loss of this privilege to the LVMPD, and
potential civil and/or criminal charges being assessed on the officer and/or agency.

OPERATIONAL NEED TO FLY ARMED

In order to carry a firearm in the cabin of the aircraft, the officer must be on official LVMPD business and meet the
requirements for operational need as specified in Title 49 Code of Federal Regulation (CFR) § 1544.219 Carriage of
Accessible Weapons.

Operational Need, as defined by Title 49:

The “Armed LEO [Law Enforcement Officer] must have a need to have the weapon accessible from the time he or
she would otherwise check the weapon until the time it would be claimed after deplaning. The need to have the weapon
accessible must be determined by the employing agency, department, or service and be based on one of the following:

1. The provision of protective duty, for instance, assigned to a principal or advance team, or on travel required
to be prepared to engage in a protective function.
2. The conduct of a hazardous surveillance operation.
3. On official travel required to report to another location, armed and prepared for duty.
4. Employed as a Federal LEO, whether or not on official travel, and armed in accordance with an agency-wide
policy governing that type of travel established by the employing agency by directive or policy statement.
5. Control of a prisoner, in accordance with Sec. 1544.221, or an armed LEO on a round trip ticket returning
from escorting, or traveling to pick up, a prisoner.
6. TSA Federal Air Marshal on duty status.”

Following are examples (not all inclusive) of non-authorized reasons for flying armed. In these cases the request
should be denied by the officer’s bureau/area commander and the officer may not fly armed.

1. Attending a conference
2. Going on vacation
3. Wants to carry firearm for personal protection
4. Did not attend Law Enforcement Officers Flying While Armed training by the Federal Air Marshal Service
5. Not on official LVMPD business
6. Not performing VIP protection
7. Not transporting a prisoner
8. Not performing hazardous surveillance operations
9. Not required by LVMPD to report to another location, armed and prepared for duty (i.e. reporting to another
jurisdiction for emergency operational assistance)
10. Has an operational need to fly, however they will be checking into a hotel immediately after landing.*

HB 00139
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* If the officer is not performing VIP protection, or transporting a prisoner, the firearm must be placed in a locked
hard case in their check-in luggage unless the operational need by the department requires they have the weapon upon
departing the plane (i.e. immediate surveillance of subject). If they are checking into a hotel first, or going to another
location where the weapon is not needed immediately, then the officer is not authorized to fly armed and must have
the firearm correctly secured in their check-in luggage.

OBTAINING ALPHANUMERIC IDENTIFIER

After the request to fly armed is vetted and approved by the bureau/area commander and the LVMPD 225/226 form
has been signed and scanned into OnBase, the officer’s bureau of assignment must send a properly formatted NLETS
administrative message to the Federal Air Marshal Service (FAMS) using a pre-formatted J-Link Administrative
Message (AM). A unique alphanumeric identifier code will be required for the airport of departure, and one for the
airport from which the member will depart upon their return.

It is recommended that the AM be transmitted a minimum of 24 hours prior to travel. Once the AM message is received
by FAMS, a return message will be sent back from the FAMS Transportation Security Operations Center (TSOC)
with a unique alphanumeric identifier for verification at the airport on the day of travel. This response should be
printed out and provided to the officer.

To retrieve the pre-formatted AM message, follow these steps:


1. Within J-Link, type TEMPLATE in the TranCode field and press the TAB key.
2. The TEMPLATES transaction screen will appear. Press the SEND button.
3. A list of templates will appear. Scroll down to template titled “LVMPD225/226” and click the title hyperlink.
4. A pre-formatted AM message will appear. Complete the fields as indicated below.

Completing the fields in the AM message:

NOTE: Do not remove, or add, any ‘periods’ (.) in the message.


1. NAM: Enter the officer’s full name in Last Name, First Name format. Example: NAM/SMITH, JOHN.
2. AGY is preformatted, do not modify.
3. BCN: Enter the Personnel Number of the officer. Example: BCN/1234.
4. OFC is preformatted, do not modify.
5. NAO is preformatted, do not modify.
6. CRT: This field is used to indicate the officer has completed the mandatory flying while armed training by
FAMS. Enter YES if trained. If officer is not trained, stop now and do not send the message. Example:
CRT/YES.
7. CPN: Enter the cell phone of the officer, entered without dashes. Example: CPN/17028281234.
8. APN is preformatted, do not modify.
9. EIT: Explanation of Individual’s Travel (previously Escorted Individual Type) per Title 49 CFR 1544.219.
If transporting a prisoner specify as “PRISONER;” for VIP protection specify “PROTECTIVEDETAIL;”
for official police activity that requires the officer to be “armed and prepared for duty” and the armed LEO
must have an operational need to have the weapon accessible on the aircraft, specify “ENFORCEMENT” or
“INVESTIGATION.” Example: EIT/PRISONER.
10. EIN: Enter the escorted individuals name in Last Name, First Name format. Example: EIN/BADGUY,
JOHN.
11. NOA: Enter the name of the airline. Example: NOA/AMERICAN.
12. FLN: Enter the flight number. This provides the TSA, as well as the LEO flying armed and the LVMPD, the
necessary level of liability protection in the event of an incident. Multiple flight numbers can be included
and should be entered in chronological order and separated by commas. Example: FLN/123456, or
FLN/AA1234, AA5678, UA9012.
13. DOF: Enter the date of flight in MMDDYY format. Example: DOF/010113.
14. DAP: Enter the departing airport’s three (3) digit airport code. Example: DAP/LAS. Airport “Ident” codes
can be found online: http://www.iata.org/publications/Pages/code-search.aspx.
15. CAP: Enter the connecting airport (if any). Multiple airport codes can be included, separated by commas.

HB 00140
Las Vegas Metropolitan Police Department
Partners with the Community

Example: CAP/RNO, or CAP/DCA, CLT, GSP.


16. FDA: Enter the final destination airport. Example: FDA/SEA.
17. REFER: This field contains the information of the person sending the message. No period is required at the
end of the REFER line. Example: REFER/DOE, JANE P#1234 702-828-1234.
18. AUTH is preformatted, do not modify.

Example completed message:


LEOFA
NAM/JOHNSON, JOHN.
AGY/LAS VEGAS METROPOLITAN POLICE DEPARTMENT.
BCN/12345.
OFC/LOCAL.
NAO/LOMBARDO, JOSEPH.
CRT/YES.
CPN/17025555555.
APN/17028283111.
EIT/PRISONER.
EIN/WESTON, MICHAEL.
NOA/AMERICAN.
FLN/A12345.
DOF/032813.
DAP/LAS.
CAP/.
FDA/LAX.

REFER/ANDERSON, JANE P#1234 702-828-5555

AUTH/JOSEPH LOMBARDO SHERIFF METROPOLITAN POLICE DEPARTMENT LAS VEGAS NEVADA

TRAVEL DATE CHANGES

If for some reason the officer’s travel date changes (i.e. weather, flight delays), a new alphanumeric identifier must be
obtained.

PROCEDURES FOR CARRYING WEAPONS ABOARD COMMERCIAL AIRCRAFT

Note: When time permits, officers should contact TSA at McCarran International Airport on the day prior to travel
advising; name, department, airline, flight numbers, date and time of departure. TSA can be contacted via phone at
(702) 577-9421 or email at lascoordinationcenter@tsa.dhs.gov.
1. On the day of travel, the officer checks-in at the airline ticket counter and identifies himself by presenting his
badge, employee ID and a second form of government identification with the original Travel Authority form
properly completed and signed. The LEO fills out the armed traveler paperwork provided by the airline,
commonly referred to as Person Carrying Firearms (PCFA) forms, and proceeds to the Armed LEO Screening
Checkpoint. **Do not go to the main passenger screening area**
2. At the Armed LEO Screening Checkpoint, LEO provides the unique alphanumeric identifier and displays his
badge, employee ID, a second form of government identification, boarding pass, and required PCFA forms.
3. The LEO will complete the LEO Logbook and proceed to the boarding gate.
4. At the boarding gate the LEO will provide the airlines’ PCFA forms and inform the gate agent of the LEO’s
presence and status.
5. The LEO then meets with the Pilot in Command, Federal Air Marshals, Federal Flight Deck Officers, and/or
other Law Enforcement Officers onboard the flight as directed.
6. Officers may not drink any alcoholic beverage(s) while armed aboard an aircraft.

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ADDITIONAL PROCEDURES FOR OFFICERS TRANSPORTING PRISONERS ABOARD COMMERCIAL


AIRCRAFT

1. Notifies the airline at least one hour before departure, or as soon as practical, of the identity of the prisoner
and the flight on which the prisoner will be carried.
2. Notifies the airline if the prisoner is considered dangerous. Federal Air Regulations require dangerous
prisoners be accompanied by at least two officers.
3. Be equipped with adequate restraining devices to restrain prisoner, if necessary.
4. Keep the prisoner under surveillance at all times.
5. Be familiar with any additional requirements of the airline.

CARRYING A DEADLY WEAPON IN CHECKED BAGGAGE

Before any officer may be permitted to carry a deadly or dangerous weapon in checked baggage, the airline must be
notified that the weapon is in the baggage (stored in a hard firearms case), must be assured the weapon is unloaded
and the baggage is locked. The officer checking the baggage must retain the key or lock combination.

OBTAINING “LAW ENFORCEMENT OFFICERS FLYING ARMED” TRAINING

Before any Law Enforcement Officer will be permitted to fly armed, it is mandatory they complete “Law Enforcement
Officers Flying Armed” training. The Office of Law Enforcement/Federal Air Marshal Service maintains oversight of
the Law Enforcement Officers Flying Armed training program. They may be contacted using LVMPD e-mail accounts
only at: leofatrn.trn@dhs.gov. The LVMPD Organizational Development Bureau posts training announcements for
this training one month in advance.

GENERAL QUESTIONS AND GUIDANCE

For general questions or guidance related to Law Enforcement Officers flying armed or for time sensitive training
requests, please contact the Office of Law Enforcement/Federal Air Marshal Service at (855) FLY-LEOS (359-5367)
or LEOFA@dhs.gov (3/16, 10/16)■

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Las Vegas Metropolitan Police Department
Partners with the Community

5/107.18 REQUESTS FOR ASSISTANCE FROM MOVIE/TELEVISION COMPANIES

All requests from movie and television companies for movie making assistance will be referred to the Office of Public
Information (PIO). Requests for police assistance for normal law enforcement duties will be handled as requests from
any citizen are handled by the Events Planning Section.

Office of Public Information


1. Receives the request for assistance from a movie/television company.
2. Reviews the request to ensure that:
a. The department and community are shown in a favorable light.
b. The assistance requested is in accordance with department policies and procedures; and
c. All involved department personnel, facilities, and equipment, (including uniforms and badges), are used
and displayed in an appropriate manner. No on-duty officers; or officers working reimbursable overtime
will participate in the production as an actor.
3. Forwards request to the Office of the Sheriff with a recommendation for approval or denial.
4. Notifies the requester if the request is denied; or notifies Events Planning Section if the request is approved.

Events Planning Section


5. Fills requests for traffic control and other departmental assistance in accordance with LVMPD 5/101.32,
Requesting Reimbursable Overtime.
6. Notifies the requester of the arrangements.
7. Forwards the name and address of the requester, and the nature of the request to Accounting Section.

Officer Assigned
8. Calls the Overtime Completion Line with hours worked when the assignment is completed.

Events Planning Section


9. Submits overtime information to the Payroll Section.

Payroll Section
10. Computes the officer’s overtime pay.
11. Forwards to the Accounting Section the total amount of applicable overtime paid to the officer.
Accounting Section
12. Bills the movie/television company for reimbursement of overtime expenditures. (3/94, 5/03)■

HB 00143
Las Vegas Metropolitan Police Department
Partners with the Community

5/107.44 COMMUNITY VOLUNTEER VIOLENCE ACTIVATION RESPONDER

It is the policy of this department to strengthen its partnership with the community by coordinating with faith-based
leaders, community and business partners and stakeholders who can assist in bringing about sense of calm and peace
to an affected community in the aftermath of a violent crime; help suppress future retaliatory violence stemming from
that violent crime; and establish a collaborative effort to identify, develop and implement joint strategies to enhance
and promote a culture of non-violence in our community.

REBUILDING EVERY CITY AROUND PEACE (RECAP)

Rebuilding Every City Around Peace (RECAP) is open to faith-based volunteers who are members of any and all
religions, faiths, denominations, creeds, as well as members of the community at large who wish to serve the
community in this volunteer capacity regardless of race, color, religion, gender, gender expression, age, national
origin, disability, or sexual orientation.

RECAP is a collaborative partnership between faith-based and community leaders, community partners, certified
Violence Responder Volunteers and the department.

RECAP consists of an Executive Board and two advisory boards: The LVMPD Advisory Board and the Faith-
Based/Community board.

The Executive Board is co-chaired by the Undersheriff and the Assistant Sheriff of the Law Enforcement Operations
Group, as well as the Chair and the Chair Pro Tem of the Faith-Based Advisory Board, and shall consist of members
of both Advisory groups in addition to any other members that are approved of by a majority vote of the executive
members.

The Executive Board will meet quarterly (at a minimum) to set goals, foster open dialogue, ensure collaboration on
relevant Community Policing initiatives, review and monitor Activation Activity, in addition to any other matters the
board deems necessary and appropriate.

To enhance communication and effectiveness of RECAP, the members of the Advisory Boards may, as needed, meet
jointly to conduct reviews, discuss strategies and outcomes, and address RECAP recruitment, continued education
and training, and any other issues as they arise.
The Executive Board will review and vote on all proposed revisions to this policy.
DEFINITIONS

Activation Event – A violent crime (i.e., shooting, stabbing, aggravated assault, etc.) has been committed and, upon
review of the facts and circumstances, officers in charge of the scene determine that there is a high likelihood of
retaliation by subjects associated with the victim.
Activation Responder Volunteer – An individual that has been certified by the faith-based RECAP board by or before
April 1, 2014, or have participated in and completed the Violence Responder RECAP workshop, and meet all
conditions set forth in the policy below.

Call-Out List – is the list of Activation Responder Volunteers from which bureau/area commanders or their designees
may call to respond to Activation (see below).

Primary Activation (Phase I) – A faith-based/community response initiated by the department when a preliminary
investigation of a violent event indicates the strong probability of retaliation, a violent event that involves youth crews,
gangs, or racial tension; an event so egregious that it affects the safety and security of the affected community, despite
the fact that there is little or no likelihood of retaliation; or circumstances prior to and/or after civil unrest incident(s)
(will not be activated during the incident).

Secondary Activation (Phase II) – A follow-up event, within 72 hours, to a Primary Activation held on behalf of, and
in, the affected community, conducted in collaboration with community and faith-based partners to promote peace in
the aftermath of the violent event. The purpose of such events is to send the message of non-violence; to convey to

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Partners with the Community

our community that violent crime in not an acceptable social norm in our city; to create a bridge between citizens and
law enforcement; to increase the opportunity for citizens to report criminal activity and increase our ability to solve
homicides; and whenever possible to introduce resources to communities in need by canvassing residents and
identifying service gaps.

Funeral and Prayer Vigil Call Outs (Phase III) – On a case by case basis, at the discretion of RECAP Executive Board
and area/bureau commanders, the RECAP message of non-violence will be presented at a funeral, prayer vigil, or
memorial services of a victim of homicide. Participation of the Faith-Based RECAP clergy in officiating these services
may, from time to time allow an opportunity for law enforcement officials to attend and build further rapport with
community in a time of heightened emotions and act as additional opportunity to prevent further violence and/or
resulting unrest.

ACTIVATION RESPONDER VOLUNTEER LISTS

Activation Responder Volunteers are identified as connected to the department’s various Community Oriented
Policing (COP) units at the area commands. The Office of Community Engagement (OCE) will maintain a master list
of certified Activation Volunteers who may choose to serve more than one area command. The master list will also
be made available to the Communications Bureau Commander, all area commanders, and the RECAP Faith-Based
Advisory Group members.
Each area commander shall have direct access to the RECAP Violence Responder Volunteer lists kept by OCE, and
the Faith-Based Advisory Group lists and resources. Each area command shall maintain a list of no less than six
Activation Responder Volunteers that will primarily serve in that area command to be called upon to assist the
community, victims and affected families, and community residents during the immediate aftermath of an event. These
volunteers will attend and assist in the coordination of all Primary and Secondary Activation events.

Should none of the individual area command Activation Responder Volunteers be available, there will be a master list
of Volunteers available to respond to any area command kept by the Advisory Boards, OCE, and the Communications
Bureau.

The Advisory Boards will also maintain a shared list of the most experienced Volunteers, who as mentors and trainees
of newly certified Responder Volunteers, are available to attend Primary Activations in all areas of department
jurisdiction.

ACTIVATION RESPONDER VOLUNTEER REQUIREMENTS

All Activation Responder Volunteers that have not been active by or before April 1, 2014 or grandfathered into call-
out list by a vote of the RECAP boards will be required to:
1. Complete a certification workshop to be held at department headquarters.
2. Undergo a Personal History Check.
a. If a candidate has open felony warrants or active felony cases will not be certified.
3. Participate in a ride-along with patrol units from the applicable area command.
4. Partner with an established Activation Responder Volunteer for the first three call-outs.
5. Participate in at least two Secondary Activations before being certified to respond to a Primary Activation
without a more experienced Activation Responder Volunteer.
6. Candidates will be presented to Executive Board for final approval by a majority vote.
7. All RECAP Violence Responders must be issued a RECAP Volunteer Identification Badge and must wear
them whenever performing their RECAP functions or while on LVMPD property.

PROCEDURE

Primary/Phase I Activation Initiation

The On-scene Supervisor will:


1. Coordinate with investigators to determine if the event is a qualifying Activation Event.
2. If so, notify the area/bureau commander, or designee, and the watch commander.

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Partners with the Community

3. Notify OCE lieutenant, or designee, and the Faith-Based/Community RECAP Advisory Board Chair, or
designees, utilizing the Activation Tree List.
4. Notify the on-call Activation Responder Volunteer and secondary responder from RECAP list provided by
OCE and or Communications and provide the volunteer with the on-scene law enforcement contact
information, including the reporting site and any other pertinent information.

The Area/Bureau Commander, or designee, will:


5. Review the facts and determine if Primary Activation is to be initiated for the purposes of interrupting the
cycle of retaliatory violence:
a. If so, the location of the Primary Activation will be the probable retaliation location, that may include
the hospital, jail, residence of the victim, crime scene, or any place determined by the supervisors and
officers on-scene that they deem appropriate or necessary to the circumstances.
b. All Final Command and operational decisions will be in the control of the area/bureau commander, or
designee.

Upon closing of the initial investigation and corresponding approvals from investigative detail, the area/bureau
commander, or designee, has the discretion of including Activation Responder Volunteers in subsequent briefings
regarding the incident.

Secondary/Phase II Activation - Community Follow-Up Peace Rally/Stop the Violence Event

The Area/Bureau Commander, or designee, will:


1. Determine if a Secondary Activation shall be initiated designed to address community healing and with the
intent of preventing potential retaliations and to create communication between law enforcement and
community with the goal to develop trust.
2. If a Secondary Activation is scheduled, the bureau commander, or designee, will notify the lieutenant (and
designee) at OCE:
a. The event can take the form of a peace rally, neighborhood march, walk, barbecue, resource fair or other
similar appropriate event.
b. Area command COP Units are encouraged to conduct survey of residents regarding crime, violence, and
quality of life issues for assessment of needs and resources.
c. The event will be conducted in conjunction with community and faith-based volunteers, organizations
and agencies to promote peace, good will, and calm during a challenging time and to disrupt retaliatory
violence and develop trust with law enforcement.
d. The exact nature and coordination of the event will be at the discretion of area command COP and with
the technical assistance if needed of OCE staff in collaboration with faith-based and community
volunteers.

Additional Role of Area/Bureau Commanders or designee will:


3. Designate one RECAP Certified Responder Volunteer to be main point of contact for Activation
coordination, outreach and participation in RECAP sub committees.
4. Send after Action Reports to OCE; RECAP Coordinator and the designated Faith-Based RECAP Advisory
Board Member of the details of Primary and Secondary Activations held. Details will include date, time,
place, type of activation, names of officers present, names of RECAP Volunteers present, notes on outcomes
and an approximate number of community members in attendance for Phase II.

The RECAP Role and Function of OCE:


5. Partner with the RECAP Faith/community Based Advisory Board.
6. Coordinate LVMPD RECAP meetings and special events.
7. Train, certify, and coordinate continuing education and quarterly meetings of all RECAP Violence Responder
Volunteers:
a. Training will consist of a five-hour curriculum that covers: role of the responder; crime trends; the nature
of trauma and crisis intervention; Forensic Overview – the nature of preservation of crime scenes.
8. Maintain back up listings of certified volunteers by area command.

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9. Upon being notified of Primary/Phase I Activation the lieutenant or designee may, depending on the
circumstances of the event, dispatch an OCE detective and/or a Fusion Liaison Officer to the scene to
facilitate RECAP Violence Responder at the scene; escort them to preserve the integrity of crime scenes;
collaborate with Intel and other officers.
10. In collaboration with ANSEC, the OCE will maintain data to measure the frequency and effectiveness of the
RECAP efforts of each area command, issue relevant reports and share data and information with the RECAP
Executive Board and its Advisory Groups for review and strategic planning purposes.
11. Assist in the development of the RECAP Initiative by providing technical assistance to law enforcement and
community towards community coalition building around RECAP.
12. Provide continuity of protocols and programs that are in place to strengthen a culture of nonviolence, conflict
resolution, and peace in our community. (3/16)■

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Las Vegas Metropolitan Police Department
Partners with the Community

5/107.45 CRITICAL CRASH RESPONSE OUTREACH (CCRO)

It is the policy of this Department to coordinate with faith-based leaders, community and business partners, and
stakeholders who can assist in bringing about a sense of calm and peace to an affected community in the aftermath of
a critical injury or fatal vehicle collision. The Traffic Bureau’s mission is to ensure traffic and public safety through
education, enforcement, and innovation. In an effort to strengthen community support, the Critical Crash Response
Outreach (CCRO) was created.

CRITICAL CRASH RESPONSE OUTREACH

CCRO is a collaborative partnership between LVMPD’s Traffic Bureau and faith-based community leaders,
community partners, and certified volunteers.

The Traffic Bureau and its faith-based partners will establish a collaborative effort to identify, develop, and implement
joint strategies to create, enhance, and promote an awareness and implementation of traffic safety. Community
partners have demonstrated a commitment and a vested interest to the area commands they serve. The Traffic Bureau
will utilize volunteers from across the valley to support and promote healing and resiliency in the aftermath of a traffic
fatality or serious crash.

ACTIVATION PHASES

CCRO activations are initiated on a case-by-case basis when a crash warrants results in critical bodily harm or fatality.
Upon arrival, the CCRO volunteer will make contact with the officer and/or Trauma Intervention Program (TIP)
volunteer to receive further direction upon making contact with the family or friends of the decedent/critically injured
person.

Phase I – A response initiated by a captain or designee (i.e., Fatal Detail sergeant) when a crash occurs if the family
of the decedent or critically injured person arrives on scene or to the hospital. The volunteers will respond to the scene
of the crash, hospital, family’s residence, or any place determined by the supervisor on-scene, as they deem appropriate
or necessary due to the circumstance.

Phase II – Within 12-24 hours after a crash, or as soon as next of kin have been notified by the Coroner’s Office,
CCRO volunteers will make contact with the decedent or critically injured person’s family, or any other involved
party as deemed necessary. The volunteers may address and offer services the family may be in need of to include,
but not limited to: build a rapport and fostering goodwill in a time of heightened emotions, offer condolences, grief
counseling, funeral planning and preparations, prayer vigils, or other needs as deemed appropriate and necessary.

CCRO volunteers will communicate with the decedent’s family about the desire for law enforcement presence during
the funeral services. CCRO volunteers will communicate with the Traffic Bureau commander or designee of the
family’s acceptance or refusal of request. If approved, the Traffic Bureau commander or designee will attend or
designate appropriate personnel.

Phase III – The Traffic Bureau and its faith-based community partners will collaborate and plan events and initiatives
to go into to the community and educate the public about traffic safety with the objective of reducing and preventing
traffic fatalities.

AFTER-ACTION REPORT

At the conclusion of any CCRO activation, the Traffic Bureau commander or designee and the lead CCRO volunteer
will complete an after action report. These reports will be collected by the designated LVPMD coordinator, as
appropriate, or sent electronically to the Traffic Bureau.

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CRITICAL CRASH RESPONSE OUTREACH VOLUNTEER POLICIES

CCRO is open to faith-based volunteers who are members of any religion, faith, denomination, creed, as well as
members of the community who wish to serve the community in this volunteer capacity regardless of age, race, color,
religion, gender expression, national origin, disability, or sexual orientation.

CCRO volunteers are identified as connected to the Traffic Bureau’s Training & Community Policing Unit. The Office
of Community Engagement (OCE) will maintain a master list of certified volunteers who may choose to serve in a
CCRO capacity. The Traffic Bureau will maintain a list of volunteers designated by the area command(s) they wish
to serve.

CCRO volunteer training and background requirements are established in LVMPD 5/107.44, Community Volunteer
Violence Activation Responder, and they are subject to change in writing depending on Department and community
needs.

ACTIVATION CCRO VOLUNTEER REQUIREMENTS

All volunteers in a Phase I or II capacity must:


1. Complete a certification workshop to be conducted at Department headquarters, the Traffic Bureau,
or faith-based location.
2. Undergo a criminal history check. An applicant who has open felony warrants or active felony cases will not
be certified.
3. Partner with an established activation responder volunteer when requested.
4. Participate in continuing education and training as provided by the Traffic Bureau Office or OCE.
5. Be issued a volunteer identification badge and wear the badge whenever performing CCRO functions or
while on LVMPD property. (5/19)■

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Partners with the Community

5/110.23 COMMISSIONED OFFICER/EMPLOYEE DEATHS

It is the policy of this department to provide caring assistance to the immediate survivors of present and past
commissioned officers of the LVMPD. The department will provide all available support during this traumatic period
of readjustment for the surviving family.

LINE OF DUTY DEATHS

The coordination of events following a line of duty death is an extremely important and complex responsibility.
Professionalism and compassion must be exhibited as an obligation to the officer’s family and the law enforcement
community. The wishes of the family are of great importance and take precedence over those of the department. The
department is committed to providing the best possible support for the officer’s family.
Sheriff (or his designee) will:
1. Coordinate with PEAP to provide concurrent personal notification (whenever possible) to the officer's
immediate family of the officer's line of duty death or life-threatening injuries, whether the death or injuries
were felonious or accidental while performing a work-related function, either on or off duty.

PEAP will:
2. Coordinate with the Sheriff (or his designee) to provide concurrent notification (whenever possible) to the
officer's immediate family of the officer's line of duty death or life-threatening injuries, whether the death or
injuries were felonious or accidental while performing a work-related function, either on or off duty.
3. Provide transportation to the hospital for immediate family members in the case of life-threatening injuries.
4. Contact the honor guard commander in the event of death, or imminent death, to alert the honor guard
members.

Designated Identified Employee will:


NOTE: Department members may choose to designate another current employee to respond with the
Sheriff/PEAP to notify family members of any serious injury/death by entering an LVMPD Serious/Critical
Injury Contact in Employee Self Service (ESS) under LVMPD Contact Data.
5. Respond with Sheriff (or his designee) and PEAP to provide notification and support to the immediate family
of the officer’s line of duty death or life-threatening injuries.

Designated Ranking Officer (for life-threatening injuries) will:


6. Respond as soon as possible to the hospital.
7. Serve as liaison between the officer’s family and the hospital staff.
8. Remain at the hospital as long as the family is present, and ensures along with PEAP, that the needs of the
family are met.

Bureau/Area Commander in the Officer’s Chain of Command will:


9. Coordinate with the family, PEAP, the honor guard commander, and others in ensuring the needs of the
family are met.
10. Determine what services will be impacted by the line of duty death and take necessary steps to ensure that
personnel in the bureau/area command are properly supported in consultation with PEAP.

PEAP will:
11. Function as the liaison between the department and the officer’s family regarding funeral planning.
12. Provide a source of continuous emotional support of the officer’s family.
13. Remain readily available and continues to contact and follow up with the family in the period following the
death.
14. Coordinate with the Sheriff regarding department representation and family support during any out-of-town
dedications or ceremonies pertaining to the officer’s death.
15. Ensure the family receives appropriate support during any subsequent trial or hearing pertaining to the
officer’s death.
16. Notify a department Chaplain to respond to the bureau/area command affected by the officer’s death or life-
threatening injury.

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Office of Public Information (PIO) will:


17. Make appropriate notification to department members, including the announcement of the period of symbolic
display of mourning upon direction from the Sheriff (LVMPD 4/107.00, Appearance Standards).
18. Immediately respond to affected bureau/area command to monitor information disseminated to public and
media inquiries. (Citizens/media coming in person to offer assistance get information etc.)
19. Make appropriate media releases.
20. Attend, with approval of the family, any family interviews with the media to assist the family so as not to
jeopardize any future legal proceedings.
Honor Guard Commander will:
21. Activate Honor Guard to act as peer support to affected bureau/area command.
22. Assist PEAP with finalizing funeral plans.
23. Meet with Events Planning and other details, if needed, once funeral plans are finalized to address any
potential contingencies.
24. Dependent on the family’s wishes, conduct rehearsal sessions for the service and burial.
25. Render Police Honors as appropriate (LVMPD 5/102.42, Honor Guard).

Communications will:
26. Secure the officer’s P number at the appropriate time.

Health and Safety Manager will:


27. Meet with the family, at an appropriate time following the funeral, to explain the various benefits due to
them, and to assist in obtaining those benefits.
28. Contact OSHA within eight hours of any occupational-related death.

OTHER DEATHS - PRESENT AND RETIRED EMPLOYEES

The Sheriff or his designee may institute any part of this procedure, or other support, for the natural or accidental
deaths of present and retired employees. The degree of the department’s involvement in the funeral will largely depend
upon the wishes of the employee’s immediate survivors.

PEAP will:
1. Contact the employee’s family to determine the degree of department involvement desired by the family.
2. Coordinate the department’s participation in the funeral with the honor guard commander and other members
as appropriate and at the direction of the Sheriff.

Communications Supervisor will:


1. Contact the honor guard commander as soon as they have been made aware that an active member of the
department has died.

Honor Guard Commander will:


2. Respond, if possible, to the location of the deceased officer.

SYMBOLIC DISPLAY OF MOURNING

At the direction of the Sheriff, department employees may participate in a symbolic display of mourning by wearing
a shrouded badge following the death of a fellow officer. This display of honor and respect for the fallen officer will
continue through the funeral services.

When an officer dies in the line of duty, commissioned officers will immediately shroud badges and maintain shrouded
badges until the end of their respective shift on the day of the fallen officer’s funeral. When an officer dies a non-
duty death or a retired officer (in good standing) dies, the shrouding of badges is authorized on the day of the funeral.

Uniformed Commissioned Employees - Displays the uniform breast badge with a black, one-half inch diagonally-
oriented (left top to right bottom) band across the face of the badge.

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Non-uniformed Commissioned and Civilian Employees - Displays the miniature badge with a black, one-eighth inch
diagonally-oriented (left top to right bottom) tape across the face of the badge. The badge may be worn on the left
lapel of a coat or jacket, upper left chest or collar area of a shirt, blouse, or dress, or in a similarly professional manner.
Other Shrouded Badge Events:
1. National Peace Officers Memorial Day (May 15).
2. Southern Nevada Law Enforcement Officer Memorial Ceremony.
3. September 11.
4. October 1.
5. At the direction of the Sheriff or designee upon the line of duty death of an officer from a neighboring
jurisdiction.

ANNUAL LVMPD FALLEN OFFICER MEMORIAL BADGE

During May of each year, officers will be authorized to wear this badge instead of the standard LVMPD badge.
Civilian employees may wear the lapel pin at their discretion. Officers are authorized to wear this badge during police
funerals and days after an officer’s death leading up to the funeral. The Sheriff may designate any other day or time
frame in which officers are permitted to wear this badge.

FUNERALS

Members are encouraged to attend funerals of other LVMPD members, when possible. Proper attire is:
1. On-duty – the uniform of the day.
2. Off-duty/civilian – professional attire.
3. If speaking at a funeral – the winter uniform.

FLAG PROTOCOL AND THE NATIONAL ANTHEM

Flag etiquette, as established by www.usaflag.org, will be observed with hoisting, lowering, or passing the national
colors. During the ceremony of hoisting or lowering the flag, when the flag is passing in a parade or review, and
during the singing or playing of the National Anthem:
1. Non-uniformed officers present will stand at attention, face the flag, and place their right hand over their
heart. Any headdress will be removed and held in the right hand at the left shoulder, with the hand being
over the heart.
2. Uniformed officers will render the military salute. In a moving column, the flag will be saluted at the moment
it passes.
3. Exception: An officer has been assigned to actively monitor the crowd or to a post wherein saluting would
jeopardize officer safety (i.e., checking people or packages entering a facility, crowded areas, handling a
disturbance or a suspect, etc.).

CONTINUED SUPPORT FOR THE FAMILY

Officers of PEAP will provide a source of continuous emotional support for the officer’s family. These officers will
be readily available to the family and will continue to contact and follow-up with them in the period following the
death.
These officers will also coordinate with the Sheriff regarding department representation and family support during
any out-of-town dedications or ceremonies pertaining to the officer’s death.

During the year that the fallen officer's name is added to the Police Memorial in Washington, DC and the State
Memorial in Carson City, two (2) members of the department will escort the immediate survivors and act as the official
representatives of the department during the ceremonies. The two members are to be selected by the immediate
survivors to bring comfort and give support to them during the ceremonies. (9/17, 3/18)■

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5/211.09 PROTESTS: PEACEFUL DEMONSTRATIONS, CIVIL DISOBEDIENCE, AND RIOTS

It is the policy of this Department to protect people, their property, and rights while providing the best in public safety
and service. This includes those individuals exercising their First Amendment right to peaceably assemble. Under the
U.S. Constitution, persons and groups have a right to organize and participate in First Amendment assemblies on
sidewalks, in parks, or other public ways near the object of their protest so they may be seen and heard.

It is neither the intention nor the desire of the Department to suppress or restrain lawful activity. First Amendment
rights do not safeguard violations of established laws, advocating imminent violence, endangering or physically
harassing people, rioting, looting, blocking the entrance to a building, or assembling on private property without the
consent of the owner. Under federal, state, and local law, governments are allowed to place reasonable time, place,
and manner restrictions on the freedom of speech. Reasonable restrictions may be applied only as necessary to
maintain public safety and order and to facilitate uninhibited commerce and freedom of movement.

In the context of this policy, a protest encompasses different forms of dissent, varying in degrees of action or
disruption. These forms of protest are defined as: peaceful demonstrations, civil disobedience, and riots. Protests can
be unpredictable and liable to rapidly change. Accordingly, within an event, there may be a mixture of different forms
of protest or activities of protesters.

DEFINITIONS

anticipated event An activity involving large numbers of people that requires a permit or is planned and
publicized beforehand, including parades, marches, rallies, concerts, religious
gatherings, parties, community activities, sporting events, labor disputes, and peaceful
demonstrations.
unplanned or An unanticipated or unannounced public gathering where the Department did not
spontaneous event receive prior notice or have time to preplan a response to address public safety
concerns.
buffer zone A safety zone created by officers which renders the area safe.
crowd management Techniques used to address crowds, including a display of police officers, containment,
travel lane closures, buffer zones, mobile field force tactics, dispersal tactics, and arrest
procedures.
dispersal order A verbal announcement given to the crowd to inform them of the law they are violating
and the consequences of such violation.
field force extrication The process of safely removing protesters from protester devices intentionally used to
(FFE) obstruct the law. This process is completed by utilizing techniques and specialized
training by the Homeland Security Saturation Team (HSST).
mobile field force A large element of police officers specially organized to implement and apply crowd
management techniques during protests through presence, maneuver, and enforcement.
protest A form of dissent, varying in degrees of action or disruption, identified as:
1. Peaceful Demonstration – A lawful public expression of objection, disapproval,
or dissent toward an idea or action
2. Civil Disobedience – Nonviolent protest where there is an intentional breach of
the law
3. Riot – An assembly that constitutes a clear and present danger of violent or
unlawful acts, including, civil unrest, destruction of property, arson, looting, or
when another immediate threat to public safety, peace, or order appears
protester device A device (e.g., bicycle locks, chains, tripods, or sleeping dragons) that physically or
mechanically connects a person or animal to a stationary object in violation of the law.
These devices are used to create confusion, delay law enforcement response, and tax
public safety resources.
Homeland Security A team of officers who are a primary Departmental asset to rapidly respond to a protest.
Saturation Team (HSST) These officers are well-rehearsed in crowd management techniques and have the
training, tools, and skills to safely extricate an individual from protester devices.

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RESPONSE PROTOCOL

The Department’s response to protests (peaceful demonstration, civil disobedience, or riot) will emphasize the concept
of de-escalation (see LVMPD 6/002.00, Use of Force) where the Department’s intent is to slow down and stabilize
any conflict as safely as possible by reducing danger through the use of verbal persuasion, tactics, and resources. The
Department will ensure that tactics and resources are properly and proportionally balanced against the activities
observed or anticipated, understanding that the current situation may be evolving. Additional factors, e.g., crowd size,
time of day, and location, will also be considered in determining the Department’s response.

Ideally, police action in peaceful demonstrations will be minimal, and the Department’s primary role will be to assist
in the safe movement of the crowd. In many circumstances, officers will be staged out of view of protesters, and the
protest will only be monitored. In other circumstances, officers will be visible, present, and placed at critical locations
to keep the peace, help with traffic control issues, and enforce violations of the law.

When it is necessary to implement crowd management measures or take enforcement action, it should be an organized
and well-communicated effort involving multiple officers and supervisory oversight.

GENERAL RULES

The following are rules that apply to protests:


1. The Department utilizes the Incident Command Structure (ICS) as a standard tool for command, control,
response coordination, and overall management of complex incidents, planned events, or emergencies (for
further guidelines and tasks, see LVMPD 5/213.06, Major Incident and All Hazard Plan). ICS will be
implemented in LVMPD’s response to protests.
2. Department supervisors are responsible for attempting communication with protest organizers or leaders. In
many protest situations, contact with formal or informal leaders can be established. Communication between
the Department and protest leaders helps to clarify expectations of both demonstrators and police, and thereby
increases the likelihood that a demonstration will remain a peaceful and lawful gathering.
3. Department supervisors will attempt to communicate with professional members of the media and legal
observers (or their liaison). Professional members of the media should be identifiable by carrying a press
pass and/or clothing that shows they work for a media company, and legal observers should be identifiable
by attire from the organization they are representing. (Legal observers function as an independent entity that
monitors, records, and reports on acts taken by the police or government.)
4. Officers will be identifiable by a name plate or name badge on their uniform and/or tag attached to the back
of their helmet (see LVMPD 4/107.00, Appearance Standards). Officers will give their name and P# if asked
(see LVMPD 4/102.12, Interaction with the Public).
5. Officers will maintain a fair and professional attitude to all parties involved in a protest and avoid expressing
any personal opinion concerning the protest (see LVMPD 4/103.26, Respect for Individual Rights of
Persons).
6. To maintain impartiality, officers will avoid fraternizing with parties involved in the protest. At any protest
location, the involved parties may have food and beverage available for their personnel; officers will not
accept food, beverage, or any gratuity from any persons. In labor disputes, officers should not enter the
property where a protest is occurring, except for official business.
7. Officers will refrain from personal cell phone usage and will neither take photographs of the protest nor pose
with protesters (see LVMPD 4/103.27, Social Media and Electronic Communications by Department
Members).
8. Officers issued a body worn camera (BWC) will ensure they are utilized to document police actions at a
protest (see LVMPD 5/210.01, Body Worn Cameras).
9. Officers and supervisors will be properly equipped, including protective gear such as helmets, gas masks,
and carriers (see LVMPD 4/107.00, Appearance Standards). Officers assigned to a traffic control task will
wear a reflective vest and utilize a flashlight, when necessary. Additional equipment needs (e.g., flex cuffs
or fire extinguishers) will be managed by a supervisor.
10. Since the use of patrol dogs may inflame a volatile situation, the Department will place limitations on their
use for crowd management and protests (see LVMPD 6/002.00, Use of Force).

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11. LVMPD’s Use of Force policy does not change during periods of protest; officers’ actions must remain in
accordance with all regulations that pertain to use of force tools or techniques.

ANTICIPATED EVENT

The affected Patrol Bureau and the Support Operations Bureau captains are responsible for acting as the liaison with
LVMPD and event organizers who are planning a protest.

Patrol Bureau and Support Operations Bureau captains or designees will:


1. Make every effort to contact the organizer(s) prior to a protest or an anticipated event to ascertain the
particulars regarding the protest (e.g., permits, location, time, duration, scope, and type of planned activities).
a. Communicate expectations and inform organizer(s) on permissible and restricted actions during the
event. Provide a handout, outlining unlawful acts or other public safety concerns.
2. Assist with the coordination of any planning meetings prior to the event between the group involved and the
bureau(s) affected (e.g., Events Planning, Special Investigations, Public Information Office, Emergency
Management, Detention Services Division).
a. Arrange for medical or fire department personnel to be staged nearby when necessary.
3. Research and assess information on past events.
4. Forward information regarding the protest(s) to Fusion Watch.
5. Determine the appropriate response based upon the form or anticipated activities of protest (peaceful
demonstration, civil disobedience, or potential riot) and complete an Incident Action Plan (IAP) with the
assistance of the Events Planning Section, when necessary, and evaluate the need for larger distribution of
the IAP with the intent to give other Departmental resources notice. The IAP will outline the booking process
for handling and care of arrestees.

UNPLANNED OR SPONTANEOUS EVENT

When responding to an unplanned or spontaneous protest or large public gathering, first-responding officer will
conduct an assessment of conditions, including:
1. Location
2. Number of participants
3. Apparent purpose of the event
4. Identity of event organizers
5. Any initial indicators of unlawful or disruptive activity
6. Presence of counter-protesters

The initial assessment will be promptly communicated through Dispatch, and a supervisor will be assigned to the call.
When an event requires continuous oversight or monitoring by a supervisor, the supervisor will assign themselves as
the incident commander (IC). Upon responding to a protest, the supervisor or IC will evaluate the current and evolving
conditions. In addition to the conditions noted by the first-responding officer(s), the supervisor or IC will assess:
1. Any evolving threat to public safety
2. Protection and preservation of citizens’ civil rights
3. Unlawful actions or violations of laws or ordinances, if any, of protesters
4. Movement of vehicular traffic and pedestrian safety concerns
5. Impact of protest on business and commerce
6. Level of communication and cooperation with event organizers, legal observers, and professional members
of the media
7. Anticipated duration of the event
8. Positioning of officers and crowd management tactics, including the need to designate units for overwatch
9. Need for the authorization of police protective gear
10. Need for additional units or resources (e.g., in-the-box squads, Traffic, Emergency Management, SWAT)
11. Need for a scribe to record operational decisions and actions (including logging use of force by officers)
12. Need to video record protest activities (either by BWCs or handheld recorder)
13. Necessity for medical assistance to be staged nearby
14. Environmental factors (e.g., weather and street conditions)

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At minimum, the area command captain will be made aware of the protest that requires continuous oversight. Dispatch
will make appropriate notifications and requests for additional resources relayed by the IC. As circumstances warrant,
the IC will provide periodic updates through the chain of command, relaying information to senior command staff
regarding the event.

COMMUNICATION DURING PROTESTS

A loudspeaker or public address system should be used to increase the likelihood that all crowd members can hear
police commands. Police personnel will not enter an obviously hostile crowd solely for the purpose of communication.
When possible, clear instructions and advisements will be communicated to the crowd and protest organizers in an
effort to seek voluntary compliance for adherence to relevant public safety concerns. Consideration should be given
to providing instructions to the crowd from different advantage points, locations, or angles. The IC and supervisors
are responsible to ensure that all orders given to a crowd are consistent, lawful, and appropriate for the circumstances.

ORDERS TO DISPERSE

When confronting a dangerous crowd or a situation where public safety has been compromised, the Department will
declare it an unlawful assembly and attempt to provide orders to disperse multiple times, giving demonstrators ample
time to leave the area. Unless there is an immediate risk to public safety or significant property damage is occurring,
reasonable time will be allowed for a crowd to comply with commands before enforcement action is taken. If a threat
or harm needs to be immediately addressed, then one order for dispersal will suffice. The determination to give
the order to disperse is the responsibility of the IC upon consultation with the on-scene lieutenant. Isolated, nonviolent,
unlawful activity by individuals should not automatically form the basis to declare an assembly unlawful; those acts
should be addressed independently.

The order should be publicly announced as follows:

“This is the Las Vegas Metropolitan Police Department. You are committing the unlawful act of (describe
unlawful action, i.e. blocking travel lanes, assault, etc.). This gathering has been declared an unlawful assembly
per Nevada Revised Statute 203.020. The statute requires you to disperse immediately upon this order. You
may disperse by (give most convenient routes of dispersal). If you fail to disperse, you will be subject to police
action, which may include the use of force and/or tear gas. This will cause pain and discomfort. Failure to
disperse will result in your arrest.”

If a contingent of the crowd are Spanish-speaking, consideration should be given to having a certified Spanish-
speaking officer announce orders to disperse in Spanish (IAPs addressing protests will include a Spanish translation
of the order to disperse).

Protesters should be given guidance and continued direction regarding how to disperse. The order to disperse will be
logged by the IC and the Communications Bureau channel dispatcher.

Members of the press and/or legal observers perform an important function in a free society and have a constitutional
right, provided they are not interfering with police operations or violating a law, to report on a newsworthy event; the
Department respects this right. Once an order to disperse is announced, professional members of the media or legal
observers must witness the event from a distance outside the area of the dispersal order that does not interfere with
police operations. Officers should attempt to give direction and warnings to professional members of the media and
legal observers (or their liaisons or organizers) prior to making detentions, arrests, or issuing citations. The failure to
comply with a lawful order to disperse can transform otherwise legal conduct into a violation of the law.

ARRESTS DURING A PROTEST

Arrests during a protest will be made to address clear violations of laws or ordinances, coupled with the need to
mitigate threats to public safety and to defuse a potential riot. Violent or felony crimes will require urgent or immediate
response. Persons with a prohibited weapon or in possession of items prohibited at a protest (e.g., improvised weapon,

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filled balloon, stick, baseball bat, PVC pipe, brick, glass bottle, shield, etc.) will be either advised, cited, or arrested.
When enforcement action is warranted in protests, selective arrests are preferred over mass arrests.

The on-scene lieutenant will authorize arrests, and time permitting, will coordinate with the IC. The IC will be made
aware of all arrests.

In making an arrest, supervisors will:


1. Consider timing, location, and method of the arrest and resources available.
2. If circumstances allow, assemble an arrest team, comprised of a minimum of a supervisor and multiple
officers. Individual officers are not precluded from making arrests when there is a clear violation of law and
the arrest will defuse the situation.
3. Not interfere or arrest professional members of the media or legal observers performing their respective
functions (observing, capturing, and/or reporting on protests or events) so long as they are performed in a
safe and legal manner. If a professional member of the media or legal observer is arrested, the IC will be
advised as soon as possible.

For documenting an arrest, an officer will:


1. Make certain that their P#, location, and time of arrest have been communicated to any unit that is assisting
in the booking process at the time the arrestee is transferred to another officer’s care.
2. Ensure individualized probable cause for the arrest and the elements of a crime for each arrestee are clearly
articulated in the DOAR.
3. Citations and Class II citations should be evaluated as options to bookings for some misdemeanor offenses
(Per LVMPD 5/202.04, Misdemeanor Citation and/or Arrest, supervisor approval is required for arrests).
4. For felony arrests (or other unusual reporting circumstances), the arresting officer will generate a separate
event number from the protest to ensure that BWC and other reports are easily connected to that specific
arrest.

The IC will:
1. Coordinate and direct the process for the booking of an arrestee and their prisoner transport with DSD
personnel to ensure it is completed in an efficient and timely manner.
2. Assign additional officers to assist in the booking process if needed and verify all required documentation
for arrests has been completed and collected.
3. Request prisoner transport vehicles to assist if mass arrests occur.

USE OF FORCE DURING A PROTEST

The Department strictly manages use of force during protests. LVMPD’s Use of Force policy (see LVMPD 6/002.00,
Use of Force) and its reporting procedures do not change during periods of protest. Uses of force occurring during
enforcement actions will be documented and the IC will be notified as soon as practical. Officers should generate
separate event numbers from the overall protest event for reporting a use of force (SWAT exception: In circumstances
where multiple applications against several subjects or a hostile crowd are used, SWAT may create an additional
blanket event number to report incidences that have occurred in a close proximity of time).

The use of aerosol irritants (e.g., tear gas, pepper ball, devastator) is intended to stop or disrupt unlawful activities and
to reduce or eliminate physical confrontations between police and demonstrators. In situations where a threat of harm
exists and orders to disperse have been given, aerosol irritants may be used to assist in the dispersal of the crowd when
individuals pose a threat of harm to officers or another person; are actively attempting to loot, ransack, or destroy
property; or attempting to take over or commandeer property where there is a threat to public safety, such as a freeway.
Deployment of aerosol irritants will only be used at the direction of the IC, and only after clear warning has been
given and when avenues of egress are available to the crowd. Whenever possible, aerosol irritants should be used
upwind and relatively close to targeted subject(s). Due to the volume of agent dispersed, officers will assess the effect
that high-capacity OC spray has on subjects in the vicinity.

The use of force and the application of force tools will not be indiscriminate; aerosol irritants deployed pursuant to a
dispersal order are an exception. In situations where aerosol irritants have been used to disperse the crowd, any

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subsequent use of force or an application of a force tool must be used in compliance with LVMPD 6/002.00, Use of
Force, and will be articulated separately from the dispersal. Force will not be used on compliant subjects or on non-
threatening people who are attempting to disperse or unable to move. Officers will only target individuals who pose a
threat.

FIELD FORCE EXTRICATIONS

During a protest where demonstrators have intentionally utilized a device that physically or mechanically connects a
person or animal to a stationary object, officers will initially use de-escalation efforts, such as verbal persuasion,
warnings, and dispersal orders, as alternatives to extrication or reasonable uses of force. When subjects refuse to
release themselves from these protester devices, each individual protester will be advised they are under arrest and
given an additional chance to comply before force is used to remove the devices.

For field force extrications, it is the responsibility of the IC to request HSST to respond. The HSST supervisor will
give tactical options for extrication of locked protester(s) to resolve the incident.

Dispatch will:
1. Dispatch a patrol supervisor and the area lieutenant (or watch commander in their absence) to the scene after
officers confirm locked protesters are present.
2. Notify the on-call HSST to respond when requested by the IC and advise the IC via radio once the
notifications have been made.
3. Provide a dedicated radio channel for the incident when requested by the IC.
4. Make additional notifications as needed and requested by the IC (e.g., Office of Public Information, medical,
fire department, Fusion Watch).

Officer will:
1. Confirm protesters are locked in devices.
2. Make contact with the locked protesters, gather information (protester’s cause, organizer/spokesperson) and
relay to Dispatch.
3. Contact Special Investigations Section (SIS) if the protest is determined to be related to an organized labor
union.
4. Assess unlawful acts and evaluate police response.
a. Determine laws or criminal offenses that are being violated (e.g., person in a roadway or trespassing).

IC will:
1. Establish ICS.
2. Arrive at scene, determine if a criminal offense has occurred, and assess the need to have protesters
immediately removed from the area.
a. Request the locked protesters to release themselves and disperse. If they refuse, issue the dispersal order.
b. If protesters still refuse to release and disperse, request the HSST through Dispatch.
3. Direct officers to create and maintain a buffer zone, ensuring inbound foot and vehicle traffic is diverted.
4. Designate an arrest team to take custodial arrest and complete booking of protesters once released from their
devices by HSST (consider notification to DSD if multiple arrests).
Homeland Security Saturation Team will:
1. Proceed directly to the scene and make contact with the IC.
2. Upon communicating with IC at the scene, the HSST supervisor will direct tactics and deployment of officers
to safely extricate locked protesters.

Unit supervisors will:


1. Ensure all reports are completed and send copies to the HSST supervisor who will submit the after-action
report. (8/20, 9/20)■

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5/208.18 FIREARMS RANGE USE AND SAFETY PRACTICES

RANGE USE

The Las Vegas Metropolitan Police Department primary range is the John Moran Firearms Facility located at 7600 E.
Carey which is staffed by the Firearms Training & Tactics Unit (FTTU). The department also has limited use of the
Desert Sportsman’s Rifle and Pistol Club located at 12201 W. Charleston for qualification and training purposes.
While the Desert Sportsman’s location is not staffed by the FTTU, a storage container for range equipment has been
established there. However it is prohibited to store ammunition or firearms in this container.

GENERAL RANGE PROCEDURE


1. Persons desiring to use the range must contact the Range Master to ensure that there is not a conflict with
another agency or group. All after-hours use of the range must be approved by the Range Master.
2. All personnel must check in with the range staff prior to utilizing any part of the range. Prior to leaving the
range all personnel must check out with the range staff.
3. All non-uniformed personnel must display a badge and/or identifying credentials while at the range.
4. Two persons must be present at all times when the range is in use, one of which must be a member of the
range staff or a department approved Firearms Instructor, except when approved by the Range Master or
during scheduled training sessions conducted by other duly constituted law enforcement agencies.
5. Non-police individuals may use the range as a guest of an accompanying officer. Officers may have only
one guest on the range at any time.
6. All guests must sign a waiver of liability and sign in a register log prior to shooting.
7. Children under 12 are not permitted to use the range.
8. Smoking at the range is only allowed in the designated areas.
9. No alcoholic beverages or controlled substances, nor any persons who have been drinking alcoholic
beverages, or are under the influence of controlled substances, are permitted on the range.

Approved Firearms Instructors wishing to utilize either of these ranges must adhere to the following procedures:
1. Contact the FTTU to schedule a date and time.
2. Ensure a training outline is sent to the range at least one week prior to the scheduled date. The training
outline must include the following:
a. Safety Briefing
b. Training to be conducted
c. Number of students
d. Number of instructors
e. Weapon calibers and ammunition needs
f. Equipment required
g. Range cleanup/Debriefing
3. FTTU will approve the training outline and contact the instructor to schedule a time to pick up range access
keys.
4. If the training outline is not approved, the FTTU will contact the instructor and assist with the correction of
any deficiencies.
5. Instructor will sign out keys and be given an access code. The instructor(s) assume all responsibility for the
training and range.
6. Instructor will return keys within three (3) days.

RANGE SAFETY

Firearm training is inherently dangerous due to the nature of the activities and materials employed. Establishing a safe
range environment depends upon the careful control of deadly weapons by its members, and such control depends
upon the cooperation of all members to abide by range safety practices. Safety is the responsibility of the individual.
Range personnel are responsible for operational safety and the reporting and correction of unsafe practices or
conditions. Therefore, at any time, use may be terminated by the Range Master/Instructor if an unsafe condition exists
or members are not observing range safety practices. At a minimum all personnel will adhere to the following
procedures during any range operation:

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FOUR GENERAL FIREARM SAFETY RULES


1. All firearms will be considered loaded at all times.
2. Never point a firearm at anything you are not prepared to destroy.
3. Never put the trigger finger on the trigger until on target and ready to fire.
4. Always be able identify and isolate the target and its surroundings.

RANGE SAFETY PROCEDURES

1. Personal protection equipment consisting of both eye and hearing protection are required for everyone on the
five firing ranges during any firing. Earplugs alone are not authorized. Earplugs may be used in conjunction
with ear muffs. The use of hearing protection is highly recommended for anyone who is near the range house
or in the bleacher areas.
2. A firearm will only be considered “SAFE” when the ammunition and/or magazine are removed, the chamber
is empty, the action or cylinder is open and any safety is on.
3. No loaded firearms are allowed in the range building unless holstered or in a “SAFE” condition.
4. No firearms will be handled off the firing line unless specifically instructed and supervised.
5. All firearms will be unloaded and holstered, if available, before departing the firing line or made safe and
carried maintaining muzzle awareness and control.
6. No ammunition will be allowed in the cleaning area.
7. No one will be allowed downrange when firing is occurring.
8. No unqualified department personnel or visitor will be allowed to fire without direct supervision by a trained
and qualified firearm carrier or an approved instructor.
9. Rifles will be restricted to the rifle range and range #1 unless specific approval is obtained from the Range
Master or his designee.
10. Steel targets are not to be used without approval and supervision of the Range Staff. Under no circumstances
will any member engage a steel target at a range of less than 15 yards.
11. Any firearm needing to be inspected or repaired will be given to the FTTU in a “SAFE” condition, magazine
removed, chamber empty, action open, with safety on.
12. All injuries will be immediately reported to the Range Master or a member of the FTTU staff.
13. All shooters are required to clean up their brass and targets and leave the range in an orderly condition.
14. All commands from the Range Master, FTTU staff member or authorized Firearms Instructor will be
immediately obeyed.
15. On the “CEASE FIRE” command, all firing will stop immediately. All weapons will be made “SAFE” and
/or holstered until the command to resume firing has been given.
16. No rounds will be fired over the berm.

SAFETY PRACTICES DURING ROLE PLAYING, PRACTICAL PROBLEM OR DEFENSIVE TACTICS


TRAINING

There will be NO LIVE WEAPONS used during role playing, practical problems or defensive tactics training. Only
red plastic weapons, simunition weapons or certified blank guns which are designed not to accept live ammunition
are authorized during these training sessions.

Prior to the beginning of the training session, the training area will be designated as a “live weapons free” zone and
will be marked using crime scene tape. No personnel will be allowed to enter the training area in the possession of
any live rounds, magazines or live weapons of any type. Instructors will conduct an inspection of each participant and
any vehicles used in the training to insure no live rounds or weapons are introduced into the training area. Instructors
will be responsible for ensuring that participants leaving the training area are rechecked prior to reentering. (1/75,
1/02)■

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5/200.01 SEARCH AND SEIZURE

Section 1 Policy Statement and the Fourth Amendment


Section 2 Law Enforcement Investigative Functions
Section 3 Non-Criminal Investigations
Section 4 Criminal Investigations
Section 5 Traffic Stops
Section 6 Types of Seizures
Section 7 Types of Searches
Section 8 Obtaining a Search Warrant
Section 9 Search Warrant Classifications
Section 10 Preparation and Service of a Search Warrant
Section 11 Post Service and Documentation of a Search Warrant
Section 12 DFL & GPS Search Warrants
Section 13 Training

Section 1 Policy Statement and the Fourth Amendment

It is the policy of this Department to strictly adhere to the Constitution of the United States. The Fourth Amendment
states:

The right of the people to be secure in their persons, houses, papers and effects against
unreasonable searches and seizures shall not be violated and no Warrants shall issue but upon
probable cause supported by Oath or affirmation and particularly describing the place to be
searched and the persons or things to be seized.

The Fourth Amendment protects an expectation of privacy that must be both: (1) reasonable and (2) legitimate.

The rules in this policy apply to all interactions between police and persons within the United States, regardless of
citizenship status.

DEFINITIONS

60-Minute Rule An investigative detention based on reasonable suspicion is strictly limited to 60


minutes, NRS 171.123(4). Any detention beyond the 60 minutes is a de facto
arrest and requires probable cause to justify.
abandonment Objective words or actions which clearly show that a person has disclaimed
ownership, dominion and control over real or personal property.
administrative checkpoint These are “policy justified” searches which do not require reasonable suspicion
or probable cause; however, the intrusion in such cases must be brief and slight,
and the determination of who to stop must be made according to some articulable,
non-arbitrary standard and comply with NRS 484B.570.
administrative search warrant A warrant issued by a judge on the application of an administrative agency.
Administrative agencies with enforcement powers seek administrative warrants
to search for contraband or other evidence of non-compliance with the law.
arrest The taking of a person into custody in a manner allowed by law. An arrest may
made by a peace officer or by a private person (see NRS 171.104). It is a show
of authority by an officer, in words or actions or both, which would cause a
reasonable person to think that they were being deprived of their liberty more
than temporarily (i.e., more than an investigative detention), and involves either
1. Submission by the subject to the officer’s show of authority, or
2. An actual physical touching which places the subject under the control
of the officer.

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blood draw The collection of a blood sample to determine the presence of drugs or alcohol
when submitted for laboratory analysis. This sample may be obtained with
consent, a search warrant or, on rare occasions, without a search warrant if
exigent circumstances exist.
body cavity search Any search involving the internal physical examination of the body. The search
must be performed with a search warrant and by a physician or other medically
trained personnel. NRS 179.063 defines a body cavity search as a touching or
probing of the rectum or vagina of a female person, or the rectum of a male
person, regardless of whether or not there is actual penetration. LVMPD further
defines a body cavity as any internal organ.
community caretaking A common law exception to the Fourth Amendment based on the public’s
doctrine expectation that law enforcement may take action to save life or render aid.
community caretaking search A non-investigative entry into a vehicle, structure, or curtilage to satisfy a
legitimate community concern for life safety.
consensual encounter A completely voluntary police interaction with members of the public, requiring
no legal justification for the interaction, where a reasonable person would feel
free to disregard the police and go about their business.
consensual entry Entry by invitation by a person with standing.
consent Agreement, approval, or permission to act. A person giving consent must do so
freely and voluntarily. A person consenting must: (1) be informed (tell the
subject what is being searched for); (2) not be coerced; (3) have actual authority
or apparent authority (“standing”); and (4) have the ability to revoke consent at
any time during the search.
curtilage Area(s) near a residence where the residents have a reasonable expectation of
privacy. Considerations in determining whether an area is curtilage and subject
to the protections of the Fourth Amendment are: (1) proximity of the area to the
home; (2) whether the area is included in an enclosure which surrounds a home;
(3) nature of uses to which an area is put; (4) steps taken to protect the area from
observation from passers-by. The legal protection associated with curtilage is
always determined in favor of the property owner, not law enforcement.
duplicate original search An order used in conjunction with a Telephonic Search Warrant Application and
warrant Affidavit directing officers to search particular places and/or seize persons or
things.
electronic search warrant A method for obtaining a search warrant which uses the internet to send and
receive a Search Warrant Application and Affidavit to/from a judge. For security
purposes, only LVMPD approved method of transmission is permitted.
evidentiary blood sample A sample of blood which is obtained to determine the presence of drugs, or
alcohol, to obtain DNA, or conduct communicable disease testing. This sample
may be obtained with consent or a search warrant, or when the officer can
articulate exigent circumstances.
exigent circumstance A time critical exception to the search warrant requirement for the purpose of
acting on an investigative emergency, based on probable cause for a criminal
investigation. Police cannot create the exigent circumstance or use a ruse to affect
a warrantless search.
forced entry Entry into a structure or vehicle which requires a tool or use of force to gain entry
and may cause damage to the structure or vehicle. A “tool” includes, but is not
limited to, a ram, Halligan tool, etc.
forced evidentiary blood A sample of blood which is obtained using reasonable force and is used to
sample determine the presence of drugs, alcohol, to obtain DNA, or to conduct
communicable disease testing. This type of blood draw will occur only with a
search warrant and after a person has refused to provide samples in compliance
with a search warrant and has been informed the search warrant authorizes the
use of reasonable force to collect the blood sample.

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fresh pursuit Occurs when there is probable cause that a person who is wanted for a serious
felony is inside a home or other private place and is about to flee. (Not to be
confused with hot pursuit.)
frisk of a person See pat down
GPS covert deployment The surreptitious installation and use of a GPS device, pursuant to a search
warrant.
GPS historical data The collection of past GPS data for a designated time period.
GPS live monitoring Receiving GPS and/or RF data in real-time.
GPS tracker An electronic device designed to provide approximate geographic location
information.
hot pursuit A sub-category of “exigent circumstances” allowing entry into a structure when
there is probable cause to believe a dangerous person has committed a serious
felony. The suspect is fleeing from law enforcement and the officer has direct
knowledge of the suspect’s location. (Not to be confused with fresh pursuit.)
investigative detention Reasonable suspicion stop, also known as a “Terry stop,” is a seizure of a person
for no more than 60 minutes, with the limited scope and purpose of conducting
an investigation and for which a police officer must have reasonable suspicion
that a person is committing, has committed, or is about to commit a crime (NRS
171.123).
investigative emergency A warrantless search which requires probable cause to: (1) prevent the destruction
search of evidence of a serious felony offense, or; (2) effect a warrantless arrest of a
violent or dangerous suspect who officers have probable cause to believe
committed a serious felony or violent offense and may escape if not immediately
apprehended, or; (3) hot or fresh pursuit.
judge shopping An act, prohibited by this policy (Section 3), described as soliciting a second
judge after an initial judge refuses to authorize a search warrant.
motor vehicle Any vehicle operating or capable of operating on public streets or highways,
including automobiles, trucks, trailers, recreational vehicles, mobile homes,
motor homes, motorcycles, and any other type of vehicle, whether self-propelled
or towed.
nighttime service request A request for an order contained within the body of a search warrant that
authorizes an affiant to serve a search warrant at any time of the day or night.
open view What a person knowingly exposes to the public is not protected by the Fourth
Amendment no matter where the exposure takes place. It does not justify a
warrantless seizure. (Not to be confused with plain view.)
pat down An open hand contact of a subject’s outer clothing to detect weapons on a person
or contained within items “immediately associated with a person” (e.g., purse,
backpack, etc.). The “pat down” is based on reasonable suspicion or articulable
facts that the person may be armed with a dangerous weapon and is a threat to
the safety of the officer.
personal property inventory A search conducted of items that are transported to a detention facility as personal
property. An inventory is not a search for evidence of crime but is justified to
protect an owner’s property while it is in custody of the police to ensure against
claims of lost or stolen property, and to ensure officer and institutional safety.
Inventories must be done to standardized criteria which limits officer discretion
and ensures that it is not a guise for a general exploratory search.
piggyback warrant An additional warrant acquired following or during the service of a primary
warrant. It is based on evidence found during the execution of the primary warrant
that would exceed the scope of the primary warrant if seized.
plain feel If during a pat down the officer feels an item that is not suspected to be a weapon,
but is immediately apparent without manipulation from the mass and shape that
the item is probably contraband, the officer can legally seize the item.
plain view An exception to the search warrant requirement that must satisfy these conditions:

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(1) the officer must be in a position in which he has a legal right to be; (2) the
items must be immediately recognizable as contraband or evidence; and (3) the
seizure must be made without substantial addition intrusion. (Not to be confused
with open view.)
premises freeze Entry into premises, with probable cause but without a search warrant, for the
purpose of clearing persons and securing the premises in anticipation of obtaining
a search warrant. No search or seizure of items will occur prior to the search
warrant being issued. A premises freeze will not be used as a pre-planned
investigative technique.
probable cause to arrest Exists when the facts and circumstances known to an officer would warrant a
prudent man in believing that a crime had been committed and that the accused
had committed it.
probable cause to search A “fair probability” that the items sought to be seized will be contained in the
premises sought to be searched.
protective sweep A quick and limited search of premises conducted for the safety of officers and
others. It must be narrowly confined to a cursory visual inspection of those places
in which a person might be hiding.
radio frequency (RF) tracker An electrical or mechanical device capable of transmitting general location
information via radio frequency.
reasonable suspicion Specific and articulable facts or circumstances which would lead a reasonable
person to believe a crime has been, is being, or is about to be committed.
sealing order A court order issued upon a showing of “good cause” to protect the contents of
an application and affidavit for a search warrant until a criminal complaint or
indictment is filed or a court otherwise orders the application and affidavit for a
search warrant unsealed.
search A police intrusion on a reasonable and legitimate expectation of privacy. See
also “trespass by government agent.”
search incident to arrest of a A complete search of the arrestee. The search of the arrestee must be conducted
person at the time of arrest or immediately thereafter when the officer deems it safe to
do so. The search should be more thorough than a pat down and will consist of
removing all items from the arrestee’s pockets, shoes, socks, etc.
search warrant An order used in conjunction with a written application and affidavit directing
officers to search particular places and/or seize persons or things.
search warrant application and A sworn statement presented to a judge (written or verbal) supporting the
affidavit issuance of a search warrant.
search warrant return of An inventory of items seized pursuant to the execution of a search warrant and
service returned to the court within ten calendar days of the court’s authorization.
search warrant return of An inventory of a biological specimen containing DNA seized from a person
service – DNA pursuant to the execution of a search warrant. Must be returned to the court
within six (6) months of the court’s authorization.
seizure A police interference with an individual’s freedom of movement by means of
physical force or show of authority or meaningful interference with an
individual’s possessory interests in property.
standing Authority, apparent authority, dominion, control and access to the place or items
searched.
strip search A search of an individual requiring the removal of clothing to permit the visual
inspection of private areas of the body.
telephonic search warrant A search warrant supported by a verbal statement via telephone, given under oath.
Terry stop See “investigative detention”
trespass by government agents A search by a government agent, without justification, that constitutes an
unreasonable intrusion into an area protected by the Fourth Amendment
including a person’s residence, curtilage, vehicle, papers, or effects.
turn over order An order obtained in conjunction with a search warrant which authorizes an
affiant to “turn over” property seized during service of a search warrant to another

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jurisdiction (e.g., task force partner or law enforcement officers from outside of
Clark County).
unoccupied structure No person is reasonably believed to be present when officers enter the structure.
The affiant will be prepared to articulate what investigative means were utilized
to determine the structure was reasonably believed to be unoccupied.
vehicle frisk The frisk of a vehicle is based on reasonable suspicion or articulable facts that a
person may have immediate access to a dangerous weapon and is a threat to the
safety of the officer. The frisk must be confined to the areas of the vehicle where
the person has access, and the officer may only enter unlocked compartments or
areas where a weapon may be present.
vehicle search An examination of all or a portion of a vehicle with either an investigatory motive
(e.g., for the purpose of discovering fruits, instrumentalities, evidence of a crime,
contraband, or to enter the vehicle to examine the vehicle identification or
determine ownership of the vehicle), or done without an investigatory motive as
in inventories of personal property conducted in conjunction with an
impoundment of the vehicle.

Section 2 Law Enforcement Investigative Functions

Searches without a warrant are unlawful, per se; however, given the criminal and non-criminal investigative missions
of a police officer, there are exceptions to the application of the Fourth Amendment.

An exception related to non-criminal investigations where the Fourth Amendment does not apply is special
needs/administrative searches for weapons at airports, in secured areas.

Exceptions related to criminal investigations where the Fourth Amendment does not apply are:
1. Open view
2. Person has no standing to assert a legal right (property right or constitutional right)
3. Trash searches outside the curtilage
4. Detention facilities
5. Abandoned property
6. Searches by a private citizen not acting as an agent of the government

Section 3 Non-Criminal Investigations

Courts recognize “check the welfare” situations as a distinct non-criminal investigative function of law enforcement.
These interactions are justified under the Community Care Taking Doctrine (Emergency Aid Doctrine). They are
totally divorced from the detection, investigation, or acquisition of evidence relating to the violation of a criminal
statute. The officer’s intent and motivation must be to save life or render aid. The facts and circumstances must
objectively support the officer’s belief that someone is in distress. If the investigation reveals facts to indicate a crime
has been committed, the officer may transition to a criminal investigation.

An entry into a structure conducted under the Community Care Taking Doctrine is limited in scope. If the search
reveals that no life safety issue exists, officers must stop searching immediately. LVMPD values life and expects
officers and supervisors to conduct investigations by talking to the person reporting, obtaining witness statements, and
evaluating these situations based on the facts and circumstances to ensure the need for life-saving assistance. The
non-criminal nature of this type of investigation allows officers to enter on to curtilage and/or make entry into a
structure. Officers who enter a structure will update details in CAD.

Prior to an officer making entry into a structure for a welfare check under the Community Care Taking Doctrine, the
officer will:
1. Ensure a preliminary investigation has been conducted.
2. Determine the need for other resources (i.e., additional officers and use of a catchpole and/or animal control
for potential vicious animals).
3. If needed, ensure medical has been requested.

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4. Broadcast over the radio the intent to make entry into a structure.
5. Notify an area sergeant before utilizing the services of a locksmith or their personal lock picking device.

When notified, the area sergeant will:


1. Acknowledge the call over the radio, and if feasible, respond to the scene.
2. Ensure the preliminary investigation has been conducted by the officer.
3. Confirm the need for the Community Caretaking Search.
4. Determine if the use of a locksmith or the use of an officer’s personal lock-picking device is appropriate.
5. Ensure additional units, resources, and medical have been requested, if needed.

While some courts have taken a more expansive view of the Community Care Taking Doctrine, it is the policy of
LVMPD to limit this doctrine to welfare checks and certain traffic stops (e.g., officer stops someone for driving slow
because of the suspicion that the driver may be in medical distress).

If officers damage property, officers must complete an Officer’s Report and photograph the damage.

Section 4 Criminal Investigations

There are three levels of police interaction for the purpose of criminal investigation: (1) consensual encounter, which
is completely voluntary and for which a police officer needs no justification; (2) the investigative detention or Terry
stop, which is a seizure of no more than 60 minutes (NRS 171.123), with limited scope and purpose for conducting
an investigation and for which a police officer must have reasonable suspicion the person being detained is
committing, has committed, or is about to commit a crime, and; (3) the arrest for which a police officer must have
probable cause.

LEVELS OF CONTACT LEVELS OF JUSTIFICATION


consensual encounter no justification
investigation detention/Terry stop reasonable suspicion
arrest probable cause

A court reviewing an officer’s level of contact is objective. The intentions of the officer are not relevant; however, the
action(s) of the officer is what will be evaluated. The totality of the circumstances will determine the level of contact.
An officer must be aware that an investigative detention and/or arrest is supported by specific and articulable facts
justifying the level of contact.

1. Consensual encounters require:


a. No legal justification.
b. A person must feel free to leave at any time, and an officer must honor the person’s right not to stop or
engage in conversation.
c. A person’s freedom of movement cannot be impeded in any way by the officer’s actions.
d. A person who has engaged in a consensual encounter may revoke consent at any time.

A consensual encounter may become an investigative detention if an officer can articulate specific facts demonstrating
reasonable suspicion that the person being detained has committed, is committing, or is about to commit a crime.

2. Investigative detentions, also known as a reasonable suspicion stops or Terry stops allow an officer to stop a
person to ascertain his or her:
a. Identity
b. Purpose

Officers can ask for identification; however, a person is not required to provide government-issued ID. If a person
only provides a name, officers may require additional personal identifying information such as date of birth or social
security number in order to verify identity. Once a person’s identity and purpose have been ascertained, and the
officer’s reason for the stop is satisfied, detention must end, and the person must feel free to leave.

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Section 5 Traffic Stops

LVMPD officers may conduct traffic stops as part of their routine duties. Traffic laws are covered under NRS 484A-
484E. Traffic laws are designed to address behavior that endangers the public. Officers conducting a traffic stop are
allowed to minimally detain drivers and passengers to address the unlawful driving behavior through a warning,
citation, or in specific cases, arrest.

If during a traffic stop a driver becomes non-compliant when asked to provide identification and/or other requested
documentation with no other actions, the driver will be considered an obstructive subject (See LVMPD 6/002.01, Use
of Force). A supervisor will be notified and respond to determine how to proceed.

There are two types of traffic offenses – primary and secondary. Probable cause to believe that a primary offense has
been committed is required to conduct a traffic stop. Officers can demand, and drivers are required, to provide a
driver’s license, registration, and proof of insurance. Officers can also run a records check to determine the status of
the driving privilege. The detention on a traffic stop (unless the officer develops reasonable suspicion or probable
cause for an arrest or the officer receives consent from the occupants) must remain minimal. Officers will not detain
drivers or passengers for longer than is necessary to confirm the driving privilege status and to issue the citation or
give a warning. In no event can the detention exceed sixty (60) minutes pursuant to NRS 171.123 (60-Minute Rule).
A secondary offense is not sufficient for a traffic stop (e.g., no seat belt).

Section 6 Types of Seizures

LVMPD officers may seize persons, residences/structures, vehicles, and property as part of their routine duties.
Officers can seize with the following legal justifications:

1. Persons:
1. Investigative Detention (60-Minute Rule)
2. Vehicle stops (driver and passengers)
3. Arrest
4. Legal 2000

2. Residences/Structures:
1. Premises freeze
2. Search warrant

3. Vehicles:
1. Vehicle stops
2. Impound
3. Search warrant

4. Property:
1. Plain view
2. Abandoned.
3. Premises freeze (electronic storage devices)
4. Search warrant
5. Safekeeping (Protecting an item from theft or to determine ownership)
5. Safekeeping of firearms – The right to bear arms is protected by the United States Constitution. The
determination to impound a firearm for safekeeping should be for life safety or to determine ownership (e.g.,
found firearm). The determination to impound a firearm for safekeeping will be documented and articulated
in the narrative portion of the Property Report (LVMPD 67a).

When a firearm is taken for safekeeping it could take in excess of 30 days to be returned.

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Section 7 Types of Searches

WARRANTLESS SEARCHES OF PERSONS

1. Consent Search:
Officers can ask for consent to search a person. Consent must be freely and voluntarily given. The consenting
person must know what the officer is searching for and have the ability to revoke consent at any time.

2. Pat Down:
A pat down (frisk of a person) is limited to the recovery of weapons which may pose a risk to officer safety.
It may be conducted by any officer who has reasonable suspicion to believe that the person, who has been
detained pursuant to an investigative detention, may be armed and dangerous. If the pat down discloses the
presence of a weapon, the weapon shall be seized. If the pat down discloses an item that is immediately
identifiable as probable contraband, the item may be seized (plain feel).

Whenever practical, a pat down should be conducted by officers of the same gender as the subject.

3. Search Incident to Arrest of a Person:


The search of the arrestee must be conducted at the time of arrest or immediately thereafter when the officer
deems it safe to do so. The search should be more thorough than a pat down and will consist of removing all
items from the arrestee’s pockets, shoes, socks, etc. Personal property immediately associated to the arrestee
will not be searched incident to arrest.

Whenever practical, a search should be conducted by officers of the same gender as the subject.

4. Personal Property Inventory Search During Arrest

For officer and institutional safety, items that are transported to a detention facility as personal property will
be thoroughly searched prior to entering the detention facility. Contraband will be removed and documented
on a Property Report (LVMPD 67a) by the arresting/transporting officer. Non-contraband items will be
transferred to detention personnel for safekeeping and completion of the inventory documentation.

STRIP SEARCHES

All strip searches will be conducted by officers of the same gender as the subject.
1. Field Strip Searches:
Field strip searches of prisoners shall be conducted only in the rarest of circumstances where the life of
officers or others may be placed at risk and only with the explicit approval of a lieutenant and only in the
presence of a supervisor.

Field Strip Searches of Confidential Informants (CI) will be conducted in the presence of two officers before
and after the operation.
2. Detention Strip Searches:
a. Administrative Strip Search:
All persons placed into general population at the Clark County Detention Center are subject to a strip
search to ensure that no contraband enters the custodial housing units. Strip searches will not be
performed on persons who are subject to release without ever entering a general population. Pretrial
detainees are allowed a reasonable amount of time to secure bond before being placed in general
population.
1) Strip searches include a visual body search. A strip search does not include a physical body cavity
search.
2) The search will be conducted in a professional manner in an area of privacy so that the search cannot
be observed by persons not participating in the search.
3) Strip searches are done by corrections officers of the same gender as the person who is being
searched.

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4) Corrections officers will adhere to DSD standard operating procedures regarding strip searches.
b. Reasonable Suspicion Strip Search:
Where reasonable suspicion exists to conduct a strip search, the arresting officer will request the search
by contacting a corrections supervisor and clearly articulating the basis for suspicion. Individuals
arrested for traffic violations and other minor offenses of a nonviolent nature will not be subject to strip
searches unless the arresting officer has reasonable suspicion to believe that the individual is concealing
contraband or weapons. Following a strip search, regardless of whether or not contraband was found,
the arresting officer will include the following details in the Declaration of Arrest Report (DOAR) or
Impaired Driving Report:
1) Justification for requesting the search
2) Date and place of the search
3) Identity of the officer conducting the search
4) Identity of the individual searched
5) Those present during the search
6) A detailed description of the nature and extent of the search
7) Any weapons, evidence or contraband found during the search

SEARCHES OF PERSONS WITH A WARRANT

A search warrant may be sought to obtain an evidentiary blood draw.

Evidentiary Blood Draw

It is the policy of the Department that the collection of blood samples may be obtained either with consent or a search
warrant. If the need arises for a blood sample to be obtained for evidentiary purposes, an officer must first request
consent of the subject to do so. If the subject will not provide consent, a search warrant will be obtained to collect the
blood sample. A voluntary breath sample is the preferred method to collect evidence for a DUI (alcohol) offense,
unless a blood draw is required by NRS.

1. Corrections officer will:


a. Ensure the subject is held in an isolated area and under continuous supervision.
b. Once the subject has refused to give consent, make no further attempts to obtain consent.

2. Police officer will:


a. If a subject refuses to give consent, obtain a search warrant.
b. When a search warrant has been obtained, take the subject to the medical intake area of the detention
facility for the collection of the blood sample.
c. Inform the subject that a search warrant has been requested and authorized by a judge to obtain a blood
sample.
1) If the subject refuses to comply with the search warrant and physically resists, make a reasonable
number of attempts to obtain the subject’s voluntary compliance with the search warrant. If the
subject refuses to comply, inform the Corrections supervisor and a sample will be obtained using
reasonable force procedures.

DNA (BUCCAL SWAB)

It is the policy of the Department that the collection of DNA (buccal swab) may be obtained either with consent or a
search warrant. If the subject will not provide consent, a search warrant will be obtained to collect the DNA (buccal
swab). (See DNA [Buccal Swab] Search Warrant [LVMPD 455]).

For collection of DNA (Buccal Swab) at CCDC see DSD SOP 17.01.14, Booking – Intake and Holding.

BODY CAVITY SEARCHES

It is the policy of the Department that subjects cannot consent to a body cavity search. A search warrant containing

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specific authorization to perform a body cavity search and the necessity for the search will be obtained. Additionally,
any body cavity search or physical examination of an orifice of the human body or organ, such as the stomach cavity,
will be performed by a physician or other medically trained personnel. These types of searches are highly invasive of
personal privacy and are only reasonable when there is a risk of serious bodily injury or death to the subject if the
suspected contraband is not removed. If an officer believes that a medical emergency exists, the subject will be
immediately transported to a medical facility. Corrections personnel will ensure the subject is held in an isolated area
and under continuous supervision until medical personnel arrive to assist.

The only exception to this search warrant requirement is a Buccal Swab that is obtained by consent.

MOTOR VEHICLE SEARCHES

Pursuant to a lawful stop, vehicles may be searched under the following circumstances:

P/C EVIDENCE IS CONTAINED IN VEHICLE NO P/C EVIDENCE IS CONTAINED IN


VEHICLE
Search pursuant to a search warrant Protective Frisk for officer safety
vehicle is readily mobile Inventory
Consent search Consent search
VIN inspection

1. Searches with a Warrant – When serving a search warrant, officers may search all areas of the vehicle
including locked or unlocked containers that could contain the items sought pursuant to the warrant.

2. Exceptions to Search Warrant Requirement – All searches without a warrant are illegal per se unless there is
a valid Fourth Amendment exception. The following are common exceptions to the warrant requirement:
a. Consent Searches – Consent must be freely and voluntarily given. Officers do not need probable cause
or reasonable suspicion to initiate a request for consent from a person with standing; however, a
consenting person shall be told what the object of the search is and the search may not exceed the scope
of the consent given. During a consent, search containers may be opened, provided that the terms of the
consent expressly permit or reasonably imply that containers may be opened. Consent must be
documented in one of the following forms: (1) electronically recorded, (2) written, or (3) verbal. Consent
may be revoked at any time by the consenting party. (An officer must be within a reasonable distance so
consent may be verbally revoked.) If anyone who is present and has standing objects to a search, a search
warrant must be obtained.
1) Electronically Recorded – The recording must include the date, time, event number, name of person
giving consent, the type of investigation and a description of the location of the search. The
recording must be preserved. (BWC recordings include date, time and event numbers when tagged).
2) Written – If the consent is in written form, it will be documented on the Consent to Search, (LVMPD
79 or 79a – both forms include a Spanish version on the back). The original form shall be scanned
into OnBase.
3) Verbal – Either electronically recorded or written consent is preferable; however, consent may be
given verbally. A witness officer is preferred for verbal consent. For officer safety concerns, it is
the policy of the department that two officers must be present when the search is conducted.

If no Officer’s Report or DOAR is generated, the officer will document the consent given for the search in CAD prior
to clearing the call.

3. Probable Cause Vehicle Search – If a vehicle is readily mobile and probable cause exists to believe it contains
contraband or evidence, the Fourth Amendment permits officers to search the vehicle. The search may
include all locked or unlocked containers located inside the vehicle where the item may be found.

4. Vehicle Search Incident to Arrest – Officers will not search a vehicle Incident to Arrest.

5. Frisk of a Vehicle for Weapons – Prior to allowing persons to re-enter a vehicle on a traffic or vehicle stop,

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an officer may conduct a frisk of the vehicle for weapons. The officer must be able to articulate reasonable
suspicion that a weapon is contained inside the vehicle. The frisk must be confined to the area of the vehicle
where any person may have immediate access. The officer may only search unlocked compartments or areas
where a weapon may be present. Areas not immediately accessible to the vehicle’s occupants such as a locked
glove box or other locked containers shall not be frisked.

6. Entry to Examine Vehicle Identification Numbers – Federal law requires vehicles to carry a vehicle
identification number (VIN) visible from the outside of the vehicle. When a vehicle is lawfully stopped, an
officer may enter the vehicle to look for and examine the VIN if the VIN in the front window is obscured.
The intrusion must be limited to actions reasonably necessary to accomplish these goals.

7. Inventories – An inventory is not a search for evidence of crime but is justified to protect an owner’s property
while it is in custody of the police to ensure against claims of lost or stolen property and to guard the police
from danger. Inventories must be done to standardized criteria which limits officer discretion and ensures
that it is not a guise for a general exploratory search. When a vehicle is lawfully impounded in accordance
with LVMPD 5/207.05, Motor Vehicle Towing and Impound Procedures Sections - 1 and 2, an officer will
conduct an inventory of that vehicle and containers found therein and record all personal property on the
LVMPD 503, Vehicle Impound Report. If the inventory is part of a vehicle seizure, see LVMPD 5/207.05,
Motor Vehicle Towing and Impound Procedures - Section 4, the personal property will be impounded and
placed in the evidence vault.

8. Vehicle Holds – Holds on impounded vehicles to obtain search warrants must be approved by the appropriate
investigative unit. Approval may be granted by radio, telephone, or in person. The approving detective’s
personnel number shall be indicated in the “Holds” section of the Vehicle Impound Report. Investigative
Units will release “Holds” when no longer required and check monthly to ensure vehicle holds have not been
overlooked and accruing fees.

STRUCTURES/RESIDENCES

1. Searches With a Warrant – When serving a search warrant, officers may search all areas of the residence and
vehicles or structures contained within the curtilage of the property that could contain items sought to be
seized pursuant to the search warrant. The nature and size of the items sought to be seized will dictate where
officers may search for that item (i.e., officers may not look for a bicycle in a dresser drawer, etc.). Once all
items sought to be seized have been recovered, the search must immediately cease.

2. Absent Exigent Circumstances or Consent, officers are required to have either an arrest warrant or a search
warrant to enter a structure for the purpose of making a probable cause arrest (the Payton Rule).

3. Absent Exigent Circumstances or Consent, officers are required to obtain a search warrant to enter a structure
owned by a third-party for the purpose of serving an arrest warrant or to make a probable cause arrest. The
search warrant requires: (1) that officers have probable cause to believe the suspect is located within the
structure; and (2) a showing of why it is reasonable to make entry into the structure instead of waiting for the
suspect to exit (the Steagald Rule).

4. Exceptions to Search Warrant Requirement – All searches without a warrant are illegal per se unless there is
a valid Fourth Amendment exception. The following are common exceptions to the warrant requirement:
a. Consent Searches – Consent must be freely and voluntarily given. Officers do not need probable cause
or reasonable suspicion to initiate a request for consent from a person with standing; however, a
consenting person shall be told what the object of the search is and the search may not exceed the scope
of the consent given. During a consent search all areas of the property may be searched, provided that it
is within the scope of the consent. Consent must be documented in one of the following forms: (1)
electronically recorded, (2) written, or, (3) verbal. Consent may be revoked at any time by the consenting
party. (An officer must be within a reasonable distance so consent may be verbally revoked.) If anyone
who is present and has standing objects to a search, a search warrant must be obtained.
1) Electronically Recorded – The recording must include the date, time, event number, name of person

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giving consent, the type of investigation and a description of the location of the search. The
recording must be preserved. BWC recordings include date, time, and event numbers when tagged.
2) Written – If the consent is in written form, it will be documented on the Consent to Search, (LVMPD
79 or 79a - both forms include a Spanish version on the back). The original form shall be scanned
into OnBase.
3) Verbal – Either electronically recorded or written consent is preferable; however, consent may be
given verbally. A witness officer is preferred for verbal consent. For officer safety concerns, two
officers must be present when the search is conducted.
If no Officer’s Report or DOAR is generated, the officer shall document the consent given for the search in CAD
prior to clearing the call.
b. Frisk for Weapons – An officer who is legally present in a structure may conduct a limited protective
search for weapons in the subject’s area of immediate access.
c. Protective Sweep – An officer who is legally present in a structure may conduct a protective sweep if he
has reasonable suspicion to believe there is a threat to his safety from a person in the structure. The
search is only for persons. Items of an evidentiary nature inadvertently discovered during a protective
sweep may be potentially seized under plain view; however, officers are strongly encouraged to obtain
a search warrant.
d. Exigent Circumstances – This exception to the warrant requirement involves balancing a number of
factors. It is a time-critical exception to the search warrant requirement that requires probable cause to
justify a warrantless entry to:
1) Prevent the destruction of evidence of a serious felony offense; or
2) Effect a warrantless arrest of a violent or dangerous suspect who officers have probable cause to
believe committed a serious felony or violent offense and may escape if not immediately
apprehended.
When the exigent circumstances cease the search must stop immediately. Police cannot create the
exigent circumstance or use a ruse to affect a warrantless search.

Section 8 Obtaining a Search Warrant

There are three methods for obtaining a search warrant – written, telephonic, and electronic.

WRITTEN SEARCH WARRANTS

A written search warrant consists of the following parts:


1. Search Warrant Application and Affidavit – (1) an officer’s probable cause statement supported by oath or
affirmation; (2) particularly describing the place to be searched, and; (3) particularly describing the items or
things to be seized. The affidavit must also include:
a. The affiant’s identity and experience
b. The crime alleged and why the items sought to be seized are evidence of the crime
c. Statement of probable cause establishing a nexus or link between the items sought to be seized and the
place to be searched
d. And may include a request and justification for a(n):
1) Sealing Order (LVMPD 360)
2) Turn Over Order (LVMPD 562)
3) Nighttime service request and/or
4) Search of persons present.
2. The Search Warrant – A court order issued upon: (1) an officer’s probable cause statement supported by oath
or affirmation; (2) particularly describing the place to be searched, and; (3) particularly describing the items
or things to be seized. If requested and good cause found, a court may include nighttime service request and
issue a separate sealing order and/or turn over order as applicable.
3. Search Warrant Return of Service – A list of the items seized during the execution of the search warrant. A
copy is left with the search warrant and the original is returned to the court within ten days.
4. Sealing Order (when applicable) – A court order issued upon a showing of good cause to protect the contents
of an application and affidavit for a search warrant until a criminal complaint or indictment is filed or a court
otherwise orders the application and affidavit for a search warrant unsealed.

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5. A Turn Over Order (when applicable) – A court, pursuant to its own inherent jurisdiction, may issue an order
acknowledging and authorizing officers from other jurisdictions to be given custody of property seized.

Obtaining A Written Search Warrant

If an officer determines the need for a search warrant, the officer will confer with a supervisor to determine if a search
warrant is the appropriate course of action. If the determination is made that a search warrant is to be sought, the
affiant/officer will:
1. De-conflict the investigation by notifying RISSafe per LVMPD 5/106.30, Using the RISSafe Nevada Watch
Center. Additionally, if during the investigation the officer discovers a conflict with another investigating
section/detail, the investigating officer will contact the investigative section/detail associated with the crime
being investigated to further de-conflict.
2. Draft the application and affidavit for search warrant establishing a probable cause nexus between the place
to be searched and the items sought to be seized. To seize an item the affiant must have facts supporting why
it is evidence.
3. If applicable, corroborate information received from informants, identifying their reliability, source of
knowledge and motivation per LVMPD 5/206.24, Informants and Associated Funds Management.
4. Obtain and verify the address or location of the place to be searched and provide a detailed description.
5. Corroborate and verify all information that will be put into the application and affidavit for a search warrant.
6. If applicable, the following factors will be included in the application and affidavit for a search warrant:
a. The names of:
1) Persons who can reasonably be expected to be inside the premises at the time the warrant is to be
served.
2) Persons with previous arrests for violence or intelligence stating a propensity for violence.
b. Threats of violence toward police made by the suspect to a covert officer, undercover officer,
confidential informant, or other witness.
c. If the target location is fortified with bars, walls, or shrubbery, or guarded by animals or surveillance
cameras.
4) Likelihood that evidence will be destroyed.
5) The justification for the use of SWAT during the service/execution of the search warrant.
6) The justification for a nighttime clause, sealing order, and/or turn over order.
7. Once the application and affidavit for a search warrant is completed, ensure the pertinent information is
identical in the Search Warrant (address of the place to be searched and the items to be seized). A second
officer will review the search warrant application and affidavit for accuracy prior to being given to a
supervisor for review. The name and personnel number (P#) of the second officer and the supervisor who
reviewed the application and affidavit for a search warrant will be noted in the Officer’s Report regarding
the service of the search warrant.
8. The supervisor will:
a. Ensure the investigating officer has de-conflicted the investigation by notifying RISSafe per LVMPD
5/106.30, Using the RISSafe Nevada Watch Center. Additionally, when required, ensure the
investigating officer contacted the investigative section/detail associated with the crime being
investigated to further de-conflict.
b. Read the application and affidavit for a search warrant, ensuring the officer has established a probable
cause nexus between the place to be searched and the items sought to be seized.
c. If applicable, ensure the officer corroborated information received from informants, identifying their
reliability, source of knowledge and motivation per LVMPD 5/206.24, Informants and Associated Funds
Management.
d. Verify all information that will be put into the application and affidavit for search warrant by reviewing
all supporting documentation in the case file and the attached Incident Action Plan (if applicable).
e. Verify that all other “officer responsibilities” have been completed.
f. After review, authorize affiant to contact a representative of the District Attorney’s Office for review
and approval.
9. Once the application and affidavit for a search warrant has been approved by LVMPD supervision, the
affiant/officer will:
a. In all search warrants except for a buccal swab, contact a representative of the District Attorney’s Office

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to review the probable cause. The name and telephone number of the on–call representative can be
obtained from the Communications Bureau. The name of the Assistant District Attorney who
reviewed/approved the application and affidavit for a search warrant will be noted in the Officer’s Report
regarding the service of the search warrant.
10. Once the application and affidavit for a search warrant has been approved by a representative of the District
Attorney’s Office, the affiant/officer will:
a. Obtain the name and contact information of the on-call “signing judge” from the Communication
Bureau.
b. Present the application and affidavit for a search warrant, search warrant, and any other applicable orders
(sealing and/or turn over order), to the judge for authorization.
c. If the judge refuses to issue the search warrant, the officer:
1) Will NOT attempt to find another judge (i.e., judge shopping).
2) Will immediately notify the supervisor and a district attorney’s representative who approved the
warrant. The supervisor and the district attorney may review the option of finding another judge
Family Court judges do not have jurisdiction to authorize search warrants; therefore, officers shall not utilize
Family Court judges to sign search warrants.

TELEPHONIC SEARCH WARRANTS

A telephonic search warrant consists of the following parts:


1. Search warrant application and affidavit
2. Duplicate original search warrant
3. Recording of telephone conversation with the judge
4. Recording transcription
5. Search Warrant Return
6. Sealing order (when applicable)
7. Turn over order (when applicable)
Obtaining a Telephonic Search Warrant

A telephonic search warrant should be requested only when exigent circumstances exist and as determined by the
supervisor. All telephonic search warrants will comply with NRS 179.045.
1. The affiant/officer will:
a. De-conflict their investigation by notifying RISSafe (LVMPD 5/106.30, Using the RISSafe Nevada
Watch Center). Additionally, if during the investigation the officer discovers a conflict with another
investigating section/detail, the investigating officer will contact the investigative section/detail
associated with the crime being investigated to further de-conflict.
b. Draft the application and affidavit for a telephonic search warrant establishing a probable cause nexus
between the place to be searched and the items sought to be seized. To seize an item, the affiant must
have facts supporting why it is evidence.
c. If applicable, corroborate information received from informants, identifying their reliability, source of
knowledge and motivation (see LVMPD 5/206.24, Informants and Associated Funds Management).
d. Obtain and verify the address or location of the place to be searched and provide a detailed description.
e. Corroborate and verify all information that will be dictated into the application and affidavit for a
telephonic search warrant.
f. If applicable, dictate into the application and affidavit for a search warrant:
1) The names of persons who can reasonably be expected to be inside the premises at the time the
warrant is to be served, and persons with previous arrests for violence or intelligence stating a
propensity for violence.
2) Threats of violence toward police made by the suspect to a covert officer, undercover officer, or
confidential informant.
3) If the target location is fortified with bars, walls, or shrubbery, or guarded by vicious animals or
surveillance cameras.
4) The likelihood that evidence will be destroyed.
5) The justification for the use of SWAT during the service/execution of the search warrant;
6) The justification for a nighttime clause, sealing order, or turn over order.

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g. Verify requirements for the application and affidavit for a telephonic search warrant and duplicate
original search warrant:
1) The name and title of the applicant;
2) A statement that there is probable cause to believe that the specific items subject to seizure under
the NRS may be found in or upon a specific designated or described place, person, or thing;
3) Allegations of facts supporting the statement, specifically setting forth the facts and circumstances
establishing probable cause to believe that items are at the places, persons, or things to be searched;
and
4) A request that the court issue a search warrant directing search for and seizure of the items in
question.
h. Draft the duplicate original search warrant which will include: (1) an officer’s probable cause statement
supported by oath or affirmation incorporating by reference the application and affidavit for a telephonic
search warrant; (2) particularly describing the place to be searched; and (3) particularly describing the
items or things to be seized. NOTE: numbers 2 & 3 will exactly match what was dictated in the
application and affidavit for a telephonic search warrant. If requested and good cause exists, a court may
include a nighttime service request.
i. When practicable, a second officer will review the probable cause details for accuracy prior to being
given to a supervisor for review.
j. The name and P# of the second officer (if applicable) and supervisor, who approved the telephonic search
warrant affidavit will be noted in the Officer’s Report regarding the service of the search warrant.
2. The supervisor will:
a. Ensure the investigating officer has de-conflicted the investigation by notifying RISSafe (LVMPD
5/106.30, Using the RISSafe Nevada Watch Center). Additionally, when required, ensure the
investigating officer contacted the investigative section/detail associated with the crime being
investigated to further de-conflict.
b. Read the application and affidavit for a search warrant, ensuring the officer has established a probable
cause nexus between the place to be searched and the items sought to be seized.
c. If applicable, ensure the officer corroborated information received from informants, identifying their
reliability, source of knowledge and motivation (LVMPD 5/206.24, Informants and Associated Funds
Management).
d. Verify all information that will be put into the application and affidavit for a telephonic search warrant
by reviewing all supporting documentation in the case file and the attached Incident Action Plan (if
applicable).
e. Verify that all other “officer responsibilities” have been completed.
f. After review, authorize affiant to contact a representative of the District Attorney’s Office for
review/approval.
3. Once the application and affidavit for a telephonic search warrant has been approved by LVMPD supervision:
a. In all search warrants except for a buccal swab, the affiant/officer will contact a representative of the
District Attorney’s Office to review the probable cause. The name and telephone number of the on–call
representative can be obtained from the Communications Bureau. The name of the assistant district
attorney who reviewed/approved the application and affidavit for a telephonic search warrant will be
noted in the Officer’s Report regarding the service of the search warrant. Consulting the district attorney
for the application of a telephonic search warrant is at the discretion of the bureau commander (e.g.,
Homicide, FIT, SWAT, ARMOR, and CNT).
4. Once the application and affidavit for a search warrant has been approved by a representative of the District
Attorney’s Office, the affiant/officer will:
a. Obtain the name and contact information of the on-call “signing judge” from the Communications
Bureau.
b. Contact the judge and inform them you are requesting authorization for a telephonic search warrant and
you will be recording the conversation.
c. With the recorder on, request permission to audio record the conversation and ask to be placed under
oath.
d. Read the Application and Affidavit for Telephonic Search Warrant, and any other applicable orders
(Sealing and/or Turn Over Order) to the judge for authorization.
e. Ask the judge if they would like to have the Duplicate Original Search Warrant read to them as well.

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f. If the judge refuses to issue the Search Warrant, the officer:


1) Will NOT attempt to find another judge (“judge shopping”); and
2) Will immediately notify the supervisor and district attorney’s representative who approved the
warrant. The supervisor and the district attorney may review the option of finding another judge.

Family Court Judges do not have jurisdiction to authorize search warrants; therefore, officers will not utilize
Family Court Judges to sign search warrants.

Obtaining a Telephonic Search Warrant for Evidentiary Blood Sample

It is the policy of this Department that a telephonic search warrant must be obtained when an officer has probable
cause to believe a subject was under the influence of intoxicating liquor or prohibited substance(s) while driving or in
actual physical control of a motor vehicle, and when the subject has refused consent for an evidentiary blood sample.
Exception: When exigency exists, an evidentiary blood sample may be taken without a warrant. For example, in the
event a subject needs emergency surgery and concerns exist that medical personnel will introduce narcotics and/or
saline, an officer may request for the immediate withdrawal of an evidentiary blood sample prior to surgery.

All telephonic search warrants will comply with NRS 179.045. Officers who have attended the required training
(Section 9) may obtain the telephonic search warrant to obtain evidentiary blood sample(s). Officers who do not have
the training to obtain a search warrant will request a trained officer or traffic supervisor to assist with obtaining a
telephonic search warrant.

When the arresting officer is obtaining the telephonic search warrant the officer will:
1. Articulate a probable cause nexus between the criminal offense and the subject for whom the blood sample
is sought to be collected. To seize evidentiary blood sample, the affiant must have facts supporting why it is
evidence.
2. Verify the location of the facility where the collection of evidentiary blood sample will occur.
3. Obtain all information that will be dictated into the application and affidavit for search warrant.
4. Verify requirements for the application and affidavit for search warrant and duplicate original search warrant:
a. The name and title of the applicant.
b. A statement that there is probable cause to believe that the blood sample is subject to seizure under NRS.
c. Allegations of facts supporting the statement, specifically setting forth the facts and circumstances
establishing probable cause to believe the collection of the blood sample(s), when submitted to
laboratory analysis, would establish an illegal level of alcohol or prohibited substance:
1) Description of driving or actual physical control.
2) Signs/symptoms of the subject’s impairment (bloodshot/watery eyes, slurred speech, odor of an
alcoholic beverage, etc.).
3) Administration of Standardized Field Sobriety Tests given and the description of the results.
4) Subject’s refusal to provide a voluntary evidentiary breath or blood sample or belief the consent
may be deemed invalid.
d. A request that the court issue a search warrant directing the collection of up to three blood samples.
e. A request that the court authorize the use of reasonable force to collect the blood samples if the subject
refuses to comply voluntarily.
f. If applicable, include the justification for a nighttime service of the search warrant.
g. If applicable, include a turn over order.
5. Draft the duplicate original search warrant that will include:
a. An officer’s probable cause statement supported by oath or affirmation incorporating by reference the
application and affidavit for search warrant;
b. Subject description (name and DOB, indicate if the subject is a juvenile);
c. The location of the facility where the collection of evidentiary blood sample(s) will occur, and;
d. The number of blood samples sought to be obtained.
e. If applicable, a nighttime service request.
6. Contact an authorized supervisor to review the search warrant application.
7. Contact the “on-call” judge:
a. Any misdemeanor DUI within the city contact Las Vegas Municipal Judges at (702) 274-4598.

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b. Any misdemeanor DUI within the county and all felony DUIs contact LVMPD Communications for the
on call “signing judge.”
8. Once in contact with the judge, immediately request permission to record the conversation before reading the
telephonic application:
a. If the judge refuses to issue the search warrant, the officer:
1) Will NOT attempt to find another judge (“judge shopping”).
2) Will immediately notify the reviewing supervisor and the District Attorney’s Vehicular Crimes
Unit.
9. Once the warrant is approved it must be served and witnessed in the presence of another Nevada peace officer.
Exception: evidentiary blood draws may be witnessed by the medical personnel executing the blood draw at
a hospital.
10. At the conclusion of the evidentiary blood sample withdraw:
a. Complete the Search Warrant Return and Property Report (LVMPD 67a), describing the items seized
pursuant to the search warrant.
b. Request for forensic examination (property connect).
c. Leave a copy of the duplicate original search warrant and return with the subject’s property at the
detention or medical facility.
d. Document in the Impaired Driving Report (LVMPD 295), where a copy of the duplicate original search
warrant and return were left.
Photos are not required of the search warrant documents for evidentiary blood samples.

When the arresting officer is not obtaining the search warrant, the affiant officer will:
1. Obtain a probable cause statement from the arresting officer which will include a nexus between the criminal
offense and the subject for whom the blood sample(s) is sought to be collected. To seize evidentiary blood
sample the affiant must have facts supporting why it is evidence.
2. Verify the address or location of the facility where the collection of evidentiary blood sample will occur.
3. Obtain all information that will be dictated into the application and affidavit for search warrant.
4. Verify requirements for the application and affidavit for search warrant and duplicate original search warrant:
a. The name and title of the applicant.
b. The name and title of the arresting officer who has provided the probable cause statement.
c. A statement that there is probable cause to believe that the blood sample is subject to seizure under the
NRS.
d. Allegations of fact supporting the statement, specifically setting forth the facts and circumstances
establishing probable cause to believe the collection of the blood sample, when submitted to laboratory
analysis, would establish an illegal level of alcohol or prohibited substance.
e. A request that the court issue a search warrant directing the collection of up to three blood samples.
f. A request that the court authorize the use of reasonable force to collect the blood sample if the subject
refuses to comply voluntarily.
g. If applicable, include the justification for a nighttime service of the search warrant.
5. Draft the duplicate original search warrant that will include:
a. An officer’s probable cause statement supported by oath or affirmation incorporating by reference the
application and affidavit for search warrant;
b. Description of the subject (name and DOB, indicate if the subject is a juvenile);
c. The location of the facility where the collection of evidentiary blood sample(s) will occur, and;
d. The number of blood samples sought to be obtained.
e. If applicable, a nighttime service request.
6. Contact their supervisor to review the search warrant application.
7. Contact the “on-call” judge and immediately request permission to record the conversation before reading
the telephonic application. If the judge refuses to issue the search warrant, the officer:
a. Will NOT attempt to find another judge (“judge shopping”); and,
b. Will immediately notify the supervisor and district attorney’s representative.
8. At the conclusion of the evidentiary blood sample withdraw:
a. Complete the Search Warrant Return and Property Report (LVMPD 67a), describing the items seized
pursuant to the search warrant.
b. Leave a copy of the duplicate original search warrant and return with the subject’s property at the

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detention or medical facility.


c. Document in the DOAR where a copy of the duplicate original search warrant and return were left.
Photos are not required of the search warrant documents for evidentiary blood samples.

The supervisor will:


9. Review the search warrant application to ensure it is supported with probable cause for an evidentiary blood
sample, when notified by Communications that an officer is:
a. Making an arrest with probable cause to believe the subject is under the influence of intoxicating liquor
or prohibited substance while driving or in actual physical control of a motor vehicle.
b. In need of a search warrant to obtain the blood sample(s).
c. In need of an available traffic or authorized officer to obtain the search warrant.

ELECTRONIC SEARCH WARRANTS

An electronic search warrant consists of the following parts:


1. Search warrant application and affidavit – (1) an officer’s probable cause statement supported by oath or
affirmation; (2) particularly describing the place to be searched; and (3) particularly describing the items or
things to be seized. The affidavit must also include:
a. The affiant’s identity and experience.
b. The crime alleged and why the items sought to be seized are evidence of the crime.
c. Statement of probable cause establishing a nexus or link between the items sought to be seized and the
place to be searched.
d. And may include a request and justification for a:
1) Sealing Order (LVMPD 360)
2) Turn Over Order (LVMPD 562)
3) Nighttime service request and/or
4) Search of persons present.
2. The Electronic Search Warrant – A court order issued through secure electronic transmission based upon: (1)
an officer’s Probable Cause statement supported by oath or affirmation; (2) particularly describing the place
to be searched; and (3) particularly describing the items or things to be seized. If requested and good cause
found, a court may include nighttime service request and issue a separate sealing order and/or turn over order
as applicable.
3. Search Warrant Return of Service – A list of the items seized during the execution of the search warrant. A
copy is left with the search warrant and the original is returned to the court within ten days.
4. Sealing Order (when applicable) – A court order issued upon a showing of “good cause” to protect the
contents of an Application and Affidavit for a Search Warrant until a criminal complaint or indictment is
filed or a court otherwise orders the Application and Affidavit for a Search Warrant unsealed.
5. A Turn Over Order (when applicable) – A court, pursuant to its own inherent jurisdiction, may issue an order
acknowledging and authorizing officers from other jurisdictions to be given custody of property seized.

Obtaining an Electronic Search Warrant

If an officer determines the need for a search warrant, the officer shall confer with a supervisor to determine if an
electronic search warrant is the appropriate course of action. If the determination is made that an electronic search
warrant is to be sought, the following actions shall be taken:
1. The affiant/officer will:
a. De-conflict their investigation by notifying RISSafe (LVMPD 5/106.30, Using the RISSafe Nevada
Watch Center). Additionally, if during the investigation the officer discovers a conflict with another
investigating section/detail, the investigating officer will contact the investigative section/detail
associated with the crime being investigated to further de-conflict.
b. Draft the application and affidavit for search warrant establishing a probable cause nexus between the
place to be searched and the items sought to be seized. To seize an item the affiant must have facts
supporting why it is evidence.
c. If applicable, corroborate information received from informants, identifying their reliability, source of
knowledge and motivation (LVMPD 5/206.24, Informants and Associated Funds Management).

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d. Obtain and verify the address or location of the place to be searched and provide a detailed description.
e. Corroborate and verify all information that will be put into the application and affidavit for search
warrant.
f. If applicable, the following factors will be included in the application and affidavit for search warrant:
1) The names of:
a) Persons who can reasonably be expected to be inside the premises at the time the warrant is to
be served.
b) Persons with previous arrests for violence or intelligence stating a propensity for violence.
2) Threats of violence toward police made by the suspect to a covert officer, undercover officer,
confidential informant, or other witness.
3) The target location is fortified with bars, walls, or shrubbery, or guarded by vicious animals or
surveillance cameras.
4) Likelihood that evidence will be destroyed.
5) The justification for the use of SWAT during the service/execution of the search warrant.
6) The justification for a nighttime clause, sealing order, and/or turn over order.
g. Once the application and affidavit for search warrant is completed, ensure the pertinent information is
identical in the search warrant (address of the place to be searched and the items to be seized). A second
officer will review the search warrant application and affidavit for accuracy prior to being given to a
supervisor for review. The name and P# of the second officer and the supervisor who reviewed the
application and affidavit for search warrant will be noted in the Officer’s Report regarding the service
of the search warrant.
2. The supervisor will:
a. Ensure the investigating officer has de-conflicted the investigation by notifying RISSafe (LVMPD
5/106.30, Using the RISSafe Nevada Watch Center). Additionally, when required, ensure the
investigating officer contacted the investigative section/detail associated with the crime being
investigated to further de-conflict.
b. Read the application and affidavit for search warrant, ensuring the officer has established a probable
cause nexus between the place to be searched and the items sought to be seized.
c. If applicable, ensure the officer corroborated information received from informants, identifying their
reliability, source of knowledge and motivation (LVMPD 5/206.24, Informants and Associated Funds
Management).
d. Verify all information that will be put into the application and affidavit for search warrant by reviewing
all supporting documentation in the case file and the attached Incident Action Plan (if applicable).
e. Verify that all other “officer responsibilities” have been completed.
f. After review, authorize affiant to contact a representative of the district attorney’s office for review and
approval.
g. Once the application and affidavit for search warrant has been approved by LVMPD supervision, in all
search warrants except for a buccal swab, the affiant/officer will contact a representative of the District
Attorney’s Office to review the probable cause. The name and telephone number of the on–call
representative can be obtained from the Communications Bureau. The name of the assistant district
attorney who reviewed/approved the application and affidavit for search warrant will be noted in the
Officer’s Report regarding the service of the search warrant.
3. Once the application and affidavit for search warrant has been approved by a representative of the District
Attorney’s Office, the affiant/officer will:
a. Load the application and affidavit for electronic search warrant along with the electronic search warrant
and other orders (i.e. sealing order, turn over order) as applicable in the LVMPD electronic search
warrant system.
b. Place a contact phone number into the electronic search warrant system so the judge can call the affiant
when ready to complete the swear-in process:
1) Judge will contact affiant to complete the “oath” or “swearing in” Process. Affiant may also need
to call the signing judge to ensure judge has received the electronic search warrant application
notice. Affiant will ensure that the “oath or swearing in process” box is checked in the electronic
search warrant system.
2) If approved, affiant will wait for electronically signed electronic search warrant and other pertinent
documents to load into the electronic search warrant system. Officer will print copies of the

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application and affidavit for electronic search warrant, electronic search warrant, and any applicable
orders and follow normal procedures for search warrant service.
3) If judge denies requesting further information, affiant will update application and affidavit for
electronic search warrant with requested information and reload into electronic search warrant
system.
4) If judge denies, affiant will make no further attempts to obtain a search warrant and call the District
Attorney’s Office to report denial.
5) Once service is complete, affiant will load the electronic search warrant return into the electronic
search warrant system. Once a judge approves an electronic search warrant, all pertinent documents
are immediately sent through secure electronic transmission to the court of record for filing.
Likewise, when the electronic search warrant return is loaded into the electronic search warrant
system, the document is immediately sent via secure electronic transmission to the court of record
for filing. The electronic search warrant return must be loaded into the electronic search warrant
system within ten days of search warrant authorization.

Family Court judges do not have jurisdiction to authorize search warrants; therefore, officers will not utilize
Family Court judges to sign search warrants.

Section 9 Search Warrant Classifications

It is the policy of the Department that there are only two classifications of search warrants: (1) non-SWAT and (2)
SWAT. It is preferred to utilize SWAT in the service of search warrants. If equipment is needed beyond what is
provided to a patrol officer or forced entry is required, SWAT will be utilized to serve the search warrant.

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IAP requirements for service of search warrant are described in the chart above. The chart is in a linear structure; the
affiant and supervisors will review each number to determine the need for an IAP and SWAT or non-SWAT service:

1. 1-12 no IAP is required.


2. 13-15 will require a SWAT service and a Search Warrant IAP-SWAT (LVMPD 289D), and notifications to
section lieutenant and bureau captain.
3. 16-20 A non-SWAT service may be authorized with approval from the section lieutenant or lieutenant
designee of equal rank and will require an LVMPD 289E, Non-SWAT Service IAP notification to bureau
captain.

The use of bodily force, a key or bolt cutters to enter an unoccupied storage facility or a structure reasonably believed
to be unoccupied would not require an IAP or SWAT service.

Community Policing and Tourist Safety Division officers may only serve non-SWAT warrants, reference 1-12 listed
within the search warrant service chart. Additionally, patrol detectives may additionally serve non-SWAT warrants
reference 16-20 listed within the search warrant service chart with bureau commander or designee approval.

No-knock search warrants are prohibited except in limited circumstances for life safety and when other tactical options
have been considered and deemed unsafe. It is the policy of LVMPD for SWAT to obtain a search warrant prior to
making entry under exigent circumstances when time allows. A no-knock forced entry made to immediately address

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a threat to life safety may be authorized, with or without a warrant, at the direction of the on-scene tactical commander.
A planned no-knock tactical entry must be approved by the deputy chief of the Homeland Security Division or
designee of equal rank. No-knock search warrants will not be used for the preservation of evidence.

Any search warrant that has not been served within ten days shall be marked as “not served” in bold letters on the top
of the search warrant and will be scanned into OnBase.

Requests for “keep the peace” at an administrative search warrant service by an administrative agency must be
approved by a lieutenant and notification made to the watch commander.

ADMINISTRATIVE SEARCH WARRANT

Examples of the types of administrative agencies requesting assistance include:


1. Animal Control
2. Attorney General
3. Constable
4. Gaming Control
5. Health Administration
6. Child Protective Services
7. Taxi-Cab Authority

LVMPD may assist an administrative agency in its service of an administrative search warrant under certain
circumstances. The purpose of LVMPD officers assisting is to provide a safe and secure environment for
administrative officers and the public. Officers may assist with clearing a structure and will focus on locating people
and officer safety concerns. Officers will not search for contraband or evidence to a crime. LVMPD officers will not
participate in any administrative warrant service which by LVMPD policy would require SWAT service.

Patrol sergeant will:


1. Respond to the scene of all requests for assistance in serving an administrative warrant.
2. Review the content of the administrative warrant, ensuring a judge’s signature is affixed.
3. Based on the size and design of the structure, ensure the appropriate number of uniformed officers are present
to search the structure.
4. Ensure a marked police unit is placed in view of the structure.
5. Prior to entering the structure, officers should announce their presence, the existence of a warrant to enter the
structure, and give occupants a reasonable amount of time to exit the structure (consider utilizing the P/A
system, if applicable).
6. Before entering the structure, ensure dispatch is aware officers are entering (Code Red is not required).
7. After securing the structure, ensure control is turned over to the administrative agency. The sergeant and
administrative agency personnel will confer to determine if LVMPD officers need to remain on-scene.
8. Ensure an officer receives a copy of the warrant, write the LVMPD event number on the warrant and scan
the warrant into OnBase.

CRIMINAL SEARCH WARRANT

All requirements to serve an outside agency search warrant must fulfill the LVMPD standard set forth in this policy.
1. Federal Task Force.
2. Law Enforcement agency from an outside:
a. State
b. County
c. City

Section 10 Preparation and Service of a Search Warrant

SERVICE PREPARATION OF A NON-SWAT WARRANT (SWAT is not serving the warrant)

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1. The officer will:


a. Draft the Search Warrant Incident Action Plan Non-SWAT Service (LVMPD 289E), not required for
numbers 1-12 reference the chart above.
b. For an unoccupied structure, notify the Communications Bureau that a search warrant will be served in
the area.
c. Conduct a mandatory pre-operational briefing. The following information must be recorded on either a
white board or other media:
1) Event number
2) Location
3) Sector, beat, area command
4) Case officer
5) Intelligence data (known threats to the operation are not present; e.g., dogs, weapons, children,
elderly, medical issues of resident)
6) Route to target location
7) A diagram of the residence
d. Ensure a photograph is taken of all diagrams (white board or other media) and placed in the case file and
uploaded into OnBase.
2. The immediate supervisor will:
a. Ensure that Search Warrant and Search Warrant Incident Action Plan is complete and accurate.
b. Approve and sign the IAP, thus indicating that the supervisor has an understanding of the investigation
and investigative strategy.
c. Ensure that briefing is conducted and that entry team members have the proper certification and
equipment.
d. Determine entry team and search team assignments.
e. Ensure the area command and Communications supervisors are notified of the service of the search
warrant (see LVMPD 5/209.14, Voice Radio Communications).
f. When necessary, coordinate with the area command supervisor for uniformed officer presence, K9 and
the Air Unit to provide scene security until the event is secure.
g. Consider the need for the presence of medical personnel on stand-by prior to the search warrant service
and have a downed officer rescue plan in place.
h. When feasible, establish surveillance 30 minutes prior to search warrant service.
i. Ensure the warrant is being served between 7 a.m. and 7 p.m., unless a nighttime service request was
authorized by the judge allowing officers to search at any time of the day or night.
j. Consider the use of a trick or ruse to cause the occupants to exit the premise; this is lawful to do as long
as the ruse does not endanger the occupants or create an impression that they are endangered. Once the
subjects exit the premises, the officers will announce their authority and identify themselves before
entering.
k. Contact the section lieutenant or authorized lieutenant designee of equal rank to approve non-SWAT
search warrant service.
3. The section lieutenant or authorized lieutenant designee of equal rank will:
a. Ensure that the search warrant and search warrant incident action plan non-SWAT service is complete
and accurate.
b. Approve and sign the IAP, indicating non-SWAT service.
c. Ensure bureau commander has been notified of non-SWAT service of the search warrant.
4. Communications will:
a. Upon notification that a search warrant will be served, generate an event number.
b. Obtain the location and approximate time of service of the search warrant.
c. Notify the area command supervisor and watch commander via administrative message and via
telephone, except when informed by the officer, as approved by the supervisor, that the search warrant
service is sensitive in nature. In that case, only contact the area command supervisor via administrative
message or telephone. All information on who was contacted needs to be entered into the event.

SERVICE OF A NON-SWAT SEARCH WARRANT

1. Search Warrant Service Team will:

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a. Prior to service and during the subsequent search phase, supervisor(s), detectives and officers will wear
a polo shirt, vest, or jacket with LVMPD markings on the front, back, and sides. A hang badge or badge
holder will be clipped onto their belt and clearly visible, unobstructed by clothing or equipment.
b. Establish a perimeter around the target location and place a marked patrol vehicle in plain sight of the
target premises, when possible.
1) If a marked patrol vehicle cannot be placed in plain sight of the target premises (i.e., target premises
is an apartment located in the interior of the complex), a marked patrol vehicle will, nonetheless, be
placed in a conspicuous location as nearby as practical to the target premises.
c. Give appropriate notice of IDENTITY AND PURPOSE to the person(s) to be searched or the persons
in actual or apparent control of the premises to be searched before entering the premises:
1) If it is unclear whether anyone is present, officers must give the notice in a manner to be heard by
anyone who is present (i.e.: bull horns or vehicle public address system will be used to ensure that
persons in the premises can hear the announcement).
d. Upon entering a structure, use the minimal amount of force necessary to serve the warrant.
e. Once area is secure:
1) Carry out all assignments pursuant to the Search Warrant Incident Action Plan.
2) Ensure photographs are taken of the interior of the structure.
3) Ensure photographs are taken documenting evidence and damage that may have occurred.
f. At conclusion of search:
1) Complete the Search Warrant Return and Property Report (LVMPD 67a) describing the items seized
pursuant to the search warrant.
2) Leave a copy of the search warrant, application and affidavit for search warrant, or seal and return
at the location of the search.
3) Complete exit photos to include search warrant documents left at location of search.
2. The supervisor will:
a. Participate in the service phase of the search warrant. If multiple search warrants are being served
simultaneously or consecutively, ensure additional supervisors are assigned and briefed for each
location.
b. When feasible, the supervisors will be inside the residence to ensure detectives/officers complete
assigned tasks and handle/document evidence appropriately.
c. Ensure, upon the conclusion of the search, that:
1) The Search Warrant Return and Property Report (LVMPD 67a) describing the items seized pursuant
to the search warrant has been properly completed.
2) All evidence/confiscated property has been collected by the search teams and properly documented.
3) Copies of the search warrant, application and affidavit for search warrant or seal and return are left
at the location of the search.
4) Complete exit photos have been taken to include search warrant documents left at location of search.
5) All team members’ personal and Department-issued equipment is removed from the location of
search.
6) Search team members do not make statements regarding liability for repairs. Such determination
will be handled through the risk manager. If applicable, contact the on-call Risk Management
representative regarding unusual circumstances. The name and telephone number of the on-call
representative can be obtained from the Communications Bureau.
d. Coordinate the securing of the premises in a manner so as not to appear open to passersby.

SERVICE PREPARATION OF A SWAT WARRANT (SWAT is serving the warrant)

1. The officer will:


a. Determine the need for SWAT to serve the warrant.
b. Draft the Search Warrant Incident Action Plan SWAT Service Request (SWAT IAP) (LVMPD 289D).
2. The immediate supervisor will:
a. Ensure the SWAT IAP is complete and accurate.
b. Approve and sign the SWAT IAP, indicating the need for SWAT service.
c. Inform the section lieutenant of the need for SWAT service of the search warrant and coordinate the
review and approval of the SWAT IAP.

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3. The section lieutenant or authorized lieutenant designee of equal rank (no acting lieutenants) will:
a. Ensure that the SWAT IAP is complete and accurate.
b. Approve and sign the SWAT IAP, indicating the need for SWAT service.
c. Inform the bureau commander when SWAT will be serving the search warrant and coordinate the review
and approval of the SWAT IAP.
d. Be responsible for coordinating a Tier I response of the Tiered Response Incident Protocol (TRIP) as
identified in the Watch Commander Manual with the respective area command no later than 24 hours
after the warrant is served.
4. The bureau commander or authorized designee of equal rank (no acting bureau commanders) will:
a. Ensure the SWAT IAP is complete and accurate.
b. Physically sign the SWAT IAP indicating approval and the need for SWAT service.
c. When a warrant service is denied by the SWAT lieutenant, discuss further options with SWAT bureau
commander.

SERVICE OF A SWAT SEARCH WARRANT

1. The officer will provide to SWAT as soon as possible:


a. The Search Warrant Incident Action Plan SWAT Service (LVMPD 289D) or federal operations plan
pursuant to a federal search warrant.
b. The application and affidavit for search warrant and the search warrant:
1) For written warrants, a copy (either signed or unsigned) will be e-mailed to the “SWAT
WARRANTS” mailbox. A signed copy will be provided to the SWAT supervisor prior to service
of the search warrant.
2) For telephonic warrants, the affiant/officer will identify the target location and share all pertinent
information with a SWAT representative. A signed copy of the duplicate original search warrant
and a transcribed copy of the application and affidavit will be sent via interoffice mail to the assigned
SWAT supervisor.
2. The supervisor will:
a. Ensure that all information has been provided by the affiant/officer to SWAT.
b. Prior to service and during the subsequent search phase, supervisor(s), detectives and/or officers will
wear a polo shirt, vest, or jacket with LVMPD markings on the front, back, and sides. A hang badge or
badge holder will be clipped onto their belt and clearly visible, unobstructed by clothing or equipment.
c. Ensure the area command and Communications Supervisors are notified of the search warrant (see
LVMPD 5/209.14, Voice Radio Communications).
d. After entry by SWAT and premises is secured, place a marked patrol vehicle in view of the target
premises, when possible, for scene security.
1) If a marked patrol vehicle cannot be placed in view (e.g., target premises is an apartment located in
the interior of the complex), a marked patrol vehicle will be placed in a conspicuous location as
nearby as practical.
2) In the absence of an LVMPD supervisor, detectives assigned to task forces will be responsible for
ensuring a marked patrol vehicle is placed in view of the target premises for scene security.
e. When feasible, the supervisor will be inside the residence to ensure detectives/officers complete assigned
tasks and handle/document evidence appropriately.
3. In all search warrants served by SWAT, the SWAT tactical commander must approve nighttime service (7
p.m. to 7 a.m.).

ADMINISTRATIVE REVIEW

1. The Search and Seizure Committee, chaired by the Internal Oversight and Constitutional Policing (IOCP)
bureau commander, will convene quarterly to review and discuss search and seizure policy and training.
2. Any proposed changes to the search and seizure procedure must be reviewed by the Search and Seizure
Committee prior to implementation.

Section 11 Post Service and Documentation of a Search Warrant

1. The affiant/officer will:

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a. Impound all evidence pursuant to LVMPD 5/210.02, Booking Evidence and Property.
b. Complete a detailed Officer’s Report including, but not limited to:
1) Location
2) Items seized, their location and who located it
3) All persons present during service of search warrant (if applicable)
4) Damage to structure or other property (if applicable)
5) How structure was secured at conclusion of service of search warrant (if applicable)
Search warrants for blood draws may document the above information in the DOAR.
c. Have the search warrant documents scanned into OnBase or maintained within a section/detail case file.
The event number must be included on all information scanned into OnBase.
d. Send the original search warrant, application and affidavit for search warrant, return, and when
applicable, a sealing and/or turn over order to the originating court within ten calendar days pursuant to
NRS 179.075: (exception: DNA search warrants for the collection of a biological specimen from a person
will be returned to the originating court within six [6] months).
1) When a telephonic search warrant is obtained the transcript of the recorded application and a disc
of the recorded application must be provided.
2. The supervisor will:
a. Ensure that all officers’ responsibilities have been completed.
b. Coordinate the securing of the premises in a manner so as not to appear open to passersby.
c. If damage to the structure or property has occurred, ensure a copy of the Officer’s Report has been
forwarded to the Risk Management Section.
The supervisor present at the service of the search warrant is responsible for the above listed responsibilities and
approval of the Officer’s Report.
3. The application and affidavit for search warrant, the search warrant and the return will be left at the place of
the search or a copy may be given to the person having authority over the property.
4. When a sealing order has been approved, only the sealing order, the search warrant and the return will be left
at the place of the search or a copy may be given to the person having authority over the property.

SPECIAL CIRCUMSTANCES FOR TASK FORCE OFFICERS

Memorandums of Understanding (MOUs) creating task forces determine what policy task force officers must follow.
Telephonic search warrants can only be completed pursuant to state law. Task force officers must be familiar with
turn over orders and understand what circumstances require officers to request that such an order be included in a
search warrant (See LVMPD 378 and definition of turn over order). No LVMPD IAP is required when a federal
operations plan is generated.

Section 12 Digital Forensics Lab (DFL) & Global Positioning System Search (GPS) Warrants

SEARCHES OF DIGITAL STORAGE DEVICES

Forensic examination of all digital storage devices such as computers, cell phones, digital video recorders, and GPS
will be completed by the DFL.

This policy does not apply to the recovery of data from crash data recorders or event data recorders, which are
commonly affixed to motor vehicles.

Preliminary Provisions
1. Digital storage devices, whether obtained through consent, arrest, or search warrant service, will be
impounded into the LVMPD Evidence Vault. Evidence will not be taken directly to DFL personnel, unless
approved by the DFL supervisor and immediate preview is required.
2. All forensic examinations will require a DFL search warrant specific to the device and the crime under
investigation unless an exception is approved by the DFL supervisor. The Internet Crimes Against Children
(ICAC) detail will have special requirements.
3. The requesting officer will:
a. Complete the DFL examination package:

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1) The DFL Request for Service Form.


2) The DFL search warrant affidavit, search warrant, and return. Affiant should complete DFL search
warrant return within ten days after getting warrant signed and ensure it is filed with the court.
3) Include copies of the Property Report (LVMPD 67a) used to impound the items.
4) Include copies of the original search warrant or consent to search.
b. Deliver the DFL examination package either via email, fax, in person or by inter-department mail to the
DFL supervisor for assignment.
4. The DFL examiner will:
a. Review the affidavit to determine the scope of the exam.
b. Obtain the items from the Evidence Vault and start the examination.
c. Return, upon completion of the examination or confirmation of obtaining a good working evidence file,
the items to the Evidence Vault.
d. Complete a Forensic Exam Report with cover sheet. This may include a description of the media
examined, forensic tools utilized, examiner’s qualifications, and findings.
e. Forward the Forensic Exam Report to the requesting officer.

GLOBAL POSITIONING SYSTEM TRACKING DEVICES

Only specific sections will be authorized to purchase, maintain, and deploy GPS technology. These sections are:
1. TASS
2. CAT/ROP
3. VIPER
4. Narcotics HIDTA Task Force

TASS will facilitate GPS installation and removal for all Department sections not authorized to possess GPS
equipment.

Obtaining a GPS Search Warrant


Department members will obtain a District Court search warrant before deploying GPS equipment in investigations
where individuals have a reasonable expectation of privacy.
1. The officer will:
a. De-conflict their investigation by notifying RISSafe per LVMPD 5/106.30, Using the RISSafe Nevada
Watch Center.
b. Complete Application and Affidavit for GPS Search Warrant, and the GPS Search Warrant Order
(LVMPD 517).
c. Obtain approval from their immediate supervisor.
d. Contact a deputy district attorney for approval. This must be a specific deputy from the list authorized
to review pen registers, trap and trace devices, and GPS tracker warrants. The on-call district attorney
phone number will not be used for approval of GPS search warrants. The approving district attorney’s
name must be printed on the application and affidavit for search warrant.
e. Present the search warrant to a judge for issuance.
f. Return of service for GPS trackers is a two-part process:
1) The Initial Return (LVMPD 517), along with the application and affidavit for search warrant, and
the GPS Search Warrant Order, must be completed and filed with the court within ten days of
authorization of the warrant.
2) The Final Return (LVMPD 517), must be completed and filed with the court within ten days of
concluding GPS tracking and removal of the device.
Unlike traditional search warrants, the paperwork is not left behind at the place of search or with a responsible
party.
g. All other policies and procedures pertaining to obtaining traditional search warrants will be adhered to
excluding the following:
1) No IAP is required for the installation or removal of a GPS tracker.
2) No after service Officer’s Report is required for the service of a GPS tracker warrant.
3) A sergeant does not need to be present for the actual installation or removal (service) of the tracker.

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Post GPS Search Warrant Service Requirements

1. The affiant of GPS search warrants will be responsible for and must maintain a record of the track history
from the entire duration of the warrant. Department members have two options to preserve the track history:
a. A printed or electronically stored copy of the track history may be impounded as evidence.
b. A printed or digitally stored copy of the track history may be maintained in the case file.

Section 13 Training

Requirements for Obtaining and Serving Search Warrants

1. Officers, sergeants, and lieutenants are required to complete the following training prior to the application,
approval, and service of a SWAT or Non-SWAT search warrant:
a. Informant Management Class.
b. Search Warrant Preparation & Execution Class.
2. Officers, sergeants, and lieutenants are required to complete the DUI Telephonic Search Warrant Hybrid
Course prior to the application, approval and service of search warrants for a DUI evidentiary blood sample.
3. Specialized units who conduct their own annual AOST will incorporate basic room clearing
techniques/training. (9/19, 10/20)■

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5/111.12 CONTRACT EMPLOYEES AND WORKERS

OVERVIEW

It is the policy of this department to comply with the FBI’s “CJIS Security Policy” which requires that contractors
employed by a business or who are independent contractors performing work at an LVMPD facility unescorted, or
who remotely access LVMPD information technology assets, or temporary occupants (See LVMPD 5/111.08,
Physical Access and Security to LVMPD Facilities), will complete a background check according to the type of work
performed. The background check will be performed by the Internal Affairs Section for Privileged Contract Workers
(see below) and by the Fingerprint Bureau for all others. Upon successful completion of the background check, receipt
of CJIS Security Awareness Training acknowledgement page, and receipt of the CJIS Security Addendum certification
page (if applicable), the worker will be issued a one year LVMPD contractor badge by the Fingerprint Bureau.
Contract workers found to have a background that, at the discretion of the LVMPD, is found to be incompatible with
the service to be performed, shall be prohibited from providing services to LVMPD.

CONTRACT WORKER TYPES

The following table defines the types of contract workers who perform work at LVMPD facilities and the background
check required for each.

TYPE OF CONTRACT DEFINITION REQUIRED


WORKER BACKGROUND
Privileged An individual who is contracted to provide regular, complex or Personal History
analytical tasks that would regularly expose the contract worker Questionnaire to
to Law Enforcement Sensitive and/or Criminal Justice include National
Information (such as data from J-Link, NCIC, SCOPE, etc). Fingerprint-Based
Records Check
Remote Support An individual who is contracted to work on specific projects or National
tasks for extended periods of time, such as contracted IT Fingerprint-Based
professionals, who will never physically be on-site at any Records Check
LVMPD facilities, instead will virtually provide support,
typically through VPN access.
Regular An individual who is contracted to work unescorted on specific National
projects or tasks within an LVMPD facility for extended periods Fingerprint-Based
of time, such as custodians, vending machine operators, or Records Check
contracted IT professionals working at an LVMPD facility.
Intermittent An individual who is contracted to work on a specific task for a None. Signs in as a
very brief period of time, usually one day, such as a copier visitor and escort
repair person, air conditioning technician, plumber, etc. required at all times
while in LVMPD
Intermittent contract workers will not be issued Contract Cards facility.
and can be allowed to immediately attend to their duties.
However, while on LVMPD premises, they must be escorted at
all times, when practical. For example, it is impractical to follow
an air-conditioning technician onto the roof of a facility.
Bureau/area commanders must use their best judgment in each
case. The escort will remain as close in proximity as possible.

BACKGROUND AND CARD REQUESTS AND PROCESSING

Privileged Contract Workers Process

Bureau Commander will:


1. Contact the IAB lieutenant via e-mail to request the initiation of the background investigation.

HB 00189
Las Vegas Metropolitan Police Department
Partners with the Community

2. Provide in the e-mail the company name, employee names, dates of birth, and telephone numbers of each
contract worker.

IAB Lieutenant will:


3. Confirm with the bureau commander the contract worker meets the criteria for a privileged level
investigation.
4. Assign an investigator.

Investigator will:
5. Make contact with the contract worker.
6. Provide them with the fingerprint referral, personal history questionnaire, CJIS Security Awareness Training,
and LVMPD CJIS Security Addendum.
7. Schedule the background interview.
8. Once the criminal history check and investigation is complete, notify the bureau commander.
9. If satisfactory, refer the contract worker to the Records and Fingerprint Bureau for issuance of a card valid
for one year.

Records and Fingerprint Bureau will;


10. Run the contract worker through SCOPE and JLink for warrants and prior criminal history.
11. Create a new SCOPE ID number for those with no prior criminal history.
12. Capture the contract worker’s fingerprints and photo.
13. Accept the signed CJIS Security Awareness Training acknowledgement page and CJIS Security Addendum,
and forward to Office of the Terminal Agency Coordinator.
14. Forward the FBI criminal history return to IAB.
15. Upon final referral from IAB, issue a card valid for one year.
16. Update the MetroWeb Contract Worker site.

Regular Contract Worker Process

Bureau commander will:


1. Contact the Records and Fingerprint Bureau for an application and CJIS Security Addendum (if applicable)
by e-mail (fingerprint@lvmpd.com) or by contacting a Work Card Supervisor. (Proxy card access should be
requested through Facilities, once the appropriate background check has been completed).
2. Provide the application to the contract worker to complete and sign.
3. Verify the application is complete, and that the contract worker meets the bureau’s standards.
4. Sign the completed application.
5. Provide the CJIS Security Awareness Training and CJIS Security Addendum (if applicable) to the contract
worker to complete and sign:
a. A CJIS Security Addendum is needed if the contract worker will be at any time exposed to or handle
Criminal Justice Information (CJI) either in paper or electronic format and/or provide information
technology (IT) duties.
6. Refer the applicant to the Records and Fingerprint Bureau.

Contract Worker will:


7. Appear at the Records and Fingerprint Bureau.
8. Present photo identification and one other form of identification, as noted on the back of the application form.
9. Present the completed and signed application, CJIS Security Awareness Training acknowledgement page,
and CJIS Security Addendum (if applicable).

Records and Fingerprint Bureau will:


10. Run the contract worker through SCOPE and JLink for warrants and prior criminal history.
11. Create a new SCOPE ID number for those with no prior criminal history.
12. Capture the contract worker’s fingerprints and photo.

HB 00190
Las Vegas Metropolitan Police Department
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13. If contract worker has no prior criminal history, issue a 90 day temporary card.
14. Update MetroWeb Contract Worker site.
15. Upon receipt of the FBI return:
a. If no prior criminal history, issue a card valid for one year (two years for temporary occupants assigned
to the SNCTC Fusion Center).
b. If any prior criminal history exists, notify the bureau commander for a determination.
16. Forward CJIS Security Awareness Training acknowledgement page and CJIS Security Addendum (if
applicable) to the Office of the Terminal Agency Coordinator.
17. Update MetroWeb Contract Worker site.

Remote Contract Worker Process

Bureau Commander will:


1. Contact the Records and Fingerprint Bureau for an application, fingerprint submission cards, and CJIS
Security Addendum by e-mail (fingerprint@lvmpd.com) or by contacting a Work Card Supervisor.
2. Mail the contract worker packet to the contracting company.
3. Receive packet via return mail and verify all information on the application is complete, and that the contract
worker meets the bureau’s standards.
4. Sign the completed application.
5. Send the complete packet to the Records and Fingerprint Bureau.

Remote Contract Worker will:


6. Complete and sign the application and CJIS Security Addendum, and print the CJIS Security Awareness
Training acknowledgement page.
7. Appear at either a local law enforcement agency or private fingerprint facility to obtain fingerprint submission
cards.
8. Mail the complete packet to the bureau commander overseeing the contract worker.

Records and Fingerprint Bureau will:


9. Receive the complete packet from the bureau commander.
10. Run the contract worker through SCOPE and JLink for warrants and prior criminal history.
11. Create a new SCOPE ID number for those with no prior criminal history.
12. Submit the fingerprint cards electronically to the FBI.
13. Upon receipt of the FBI return, notify the bureau commander of the results.
14. Forward CJIS Security Awareness Training acknowledgement page and CJIS Security Addendum to the
Office of the Terminal Agency Coordinator.
15. Update MetroWeb Contract Worker site.

IT Bureau will:
16. Create and manage remote worker accounts in accordance with the ITB remote access bureau policy. All
VPN access provided to contracted remote workers will be enabled strictly for specific incidents and will be
tracked through the ITB Help Desk.

ANNUAL REVIEW
Contract workers or temporary occupants are required to report to the Records and Fingerprint Bureau for a renewal
card with a new, signed contract worker application form, and CJIS Security Awareness Training acknowledgement
page at least two weeks prior to the expiration date on their current card.

The CJIS Security Addendum (if applicable) is effective throughout the contract worker’s or temporary occupant’s
term; therefore, this does not have to be re-submitted. The sponsoring bureau is responsible for ensuring the contract
worker or temporary occupant completes the renewal process prior to the expiration of the ID card.

HB 00191
Las Vegas Metropolitan Police Department
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LOST/STOLEN BADGES

Contract workers and temporary occupants must follow LVMPD 5/103.28, Reporting Damage/Loss to Department
Property and Equipment. Once appropriate notifications are made, the contract worker or temporary occupant may
report to the Records and Fingerprint Bureau with a new, signed contract worker application form to obtain a new
contract worker ID card.

ONLINE BADGE LIST

A list of all temporary occupants, their contract worker type, and the expiration date of their ID badge is available on
the Records and Fingerprint Bureau MetroWeb site. This list may be used by HQ visitor booths and all employees
monitoring restricted access areas to check the contractor’s status prior to admission into those areas, if they do not
have a proxy card. Sponsoring bureaus may also use the list to ensure all contract workers or temporary occupants
under their supervision have current, unexpired cards.

OVERSIGHT

Once a contract worker or temporary occupant has received a contract card, the worker may be allowed on LVMPD
premises unescorted to attend to their duties only. All contract workers and temporary occupants must display their
cards at all times. Bureau/area commanders are responsible for verifying that a contract worker’s or temporary
occupant’s card is valid, as well as the legitimacy of the presence of any individual in LVMPD facilities. Supervisors
should pay particular attention to the activities and work product of contract workers or temporary occupants who
have been issued a 90-day temporary card while criminal history checks are ongoing. The bureau/area commander
will also ensure that the contract worker or temporary occupants takes the CJIS Security Awareness training, as
directed by the Office of the Terminal Agency Coordinator.

BADGE REVOCATION

When a temporary occupant is no longer assigned to an LVMPD facility, a contract with a vendor expires or is
terminated, or a specific contract worker no longer meets the department’s standards for suitability, the bureau
commander will:
1. Collect all outstanding contract worker ID cards and/or Proxy Cards.
2. Notify the Records and Fingerprint Bureau by memo or e-mail to fingerprint@lvmpd.com to update the
MetroWeb site and return the ID cards to Fingerprint for destruction.
3. Notify Facilities to remove Proxy Card access and return collected Proxy Cards by interoffice mail.
(5/13, 9/14)■

HB 00192
Las Vegas Metropolitan Police Department
Partners with the Community

5/111.08 PHYSICAL ACCESS AND SECURITY TO LVMPD FACILTIES

HEADQUARTERS AND OFFSITE FACILITIES ACCESS

All secured doors may be opened with either an issued key or access control card. Department members will carry
and use their key or access card to move throughout facilities. Members shall ensure that unauthorized persons do not
follow any member through a security door. All members remain responsible for the security of their assigned work
areas and for locking doors to those areas as necessary. Deputy Chiefs and above have authorized, unrestricted access
to all areas of the department except where otherwise stated.

HEADQUARTERS SECURITY SYSTEMS

The monitoring and use of the security systems will be at the direction of the supervisor of the LVMPD Headquarters
Police Detail. System maintenance and support will be provided by the appropriate department member.

SECURED ACCESS

PUBLIC ENTRANCE

Visitors Information Station officers and/or other designated department members are responsible for properly
securing headquarters and offsite location public-entrance doors. Following normal business hours, the Visitor
Information Station officers and/or other designated department members shall ensure access doors are secure. Any
citizen(s) requesting entrance after business hours who do not have legitimate business are not permitted to enter. If
access is granted by supervisory personnel, the citizen’s name(s) must be placed on the LVMPD 518, Visitor Log,
and the citizen will be issued a visitor badge. The citizen must be escorted within all facilities at all times by a
department member, and the visitor must be segregated from sensitive areas, viewing Criminal Justice Information
(CJI)/Criminal History Record Information (CHRI), or accessing terminals or printouts that contain or access
CJI/CHRI.

LVMPD HEADQUARTERS PARKING GARAGE

All department members have access to the headquarters parking garage with a proximity access card. All department
members assigned to headquarters will park all personal and department-owned vehicles in the parking garage. The
speed limit in the headquarters garage is five miles per hour.

The first level of the parking garage has reserved parking spaces identified by placard and/or stencil that are assigned
to a designated department member through the Office of the Sheriff. The remainder of the parking spaces on the first
level and all parking spaces on the second and third levels (including the ramp from the third to fourth level) are
designated for on-duty department members’ personal vehicles on a first-come, first-served basis. The fourth and fifth
floors of the parking garage are designated for all department-owned vehicles. Unless the member is assigned a
reserved parking space on the first level, all LVMPD-owned vehicles (i.e., marked vehicles, take-home vehicles, pool
cars, etc.) must park on the fourth or fifth level of the parking garage.

Department members who are not assigned to headquarters, but are visiting headquarters (i.e., training classes, etc.)
will park in the headquarters parking garage (subject to the same parking parameters listed above). LVMPD members
are prohibited from parking in the surface lots east or south of headquarters.

HEADQUARTERS PUBLIC RESTROOMS

Visitors Information Station personnel and/or other designated department member shall monitor access to the public
restrooms in the lobby.

HB 00193
Las Vegas Metropolitan Police Department
Partners with the Community

ALL OTHER INTERIOR HEADQUARTERS DOORS

Access doors to restricted areas within LVMPD facilities will remain locked and secured at all times. An interior
secure access door that cannot be secured is to be monitored until it can be secured.

VISITORS

Headquarters facility – All visitors (including those employed by other criminal justice agencies) to the headquarters
facility will be required to check-in at the Visitor’s Information Station. They will be checked against the banned
visitor list and their information will be recorded in the LVMPD Visitor Log at the Visitor Information Station to
receive a visitor’s badge.

The banned visitor list will be created, disseminated and maintained by the Headquarters Police Detail supervisor.
The duration a subject remains on the list will be based on individual circumstances. These logs will be destroyed
after one year.

Plain-clothes law enforcement officers will display their issued LVMPD ID badge or their LVMPD hang-badge
credentials. General visitors will wear a temporary visitor’s badge. Visitor badges will be designated with a large
“A,” “B,” or “C” for their respective buildings. Training class visitors will wear a building “A” visitors badge and
will be allowed access to only the training areas without an escort. Any person inside the headquarters secure area
that is not a department member should display a visitor’s badge, must be escorted by a department member, must be
segregated from sensitive areas, and from viewing CJI/CHRI, or accessing terminals or printouts that contain or access
CJI/CHRI.

Every member should report unknown individuals without identification to the Headquarters Police Detail.
Exceptions can only be authorized by the supervisor of the Headquarters Police Detail, a Deputy Chief or above.
Suspects and persons of interest will be escorted by a detective through the suspect entrance at the rear of building C.
All other visitors will be escorted by a volunteer or the member the visitor(s) are there to meet.

Visitors will be checked-out when their visitor badge is returned.

To expedite visitor check-in, the Visitor Information Station should be notified of expected visitors with their name,
time, and whom they are to visit. The Visitor Information Station will be provided a listing of all meetings and classes
scheduled in the building, along with a list of the attendees prior to the meeting or class, when possible.

SECURE NETWORK COMMUNICATION/IDF ROOM

Each LVMPD Intermediate Data Facility (IDF) room is considered a secure facility and only to be accessed when
necessary for the operation and maintenance of LVMPD network and infrastructure. This room cannot be used as a
storage room, nor can the equipment contained within be altered or modified by any unauthorized personnel.

In accordance with Nevada Criminal Justice Information Systems (NCJIS) and Information Technologies Bureau
(ITB) security compliance requirements, every LVMPD facility’s secure IDF room requires separate access control
and personnel access and area will be limited to select ITB and facilities support personnel, the bureau/area
commander, administrative assistant, administrative lieutenant, or other principal manager of that facility or area under
their direct command.

Any additional access requests must be expressly approved by the ITB Director and LVMPD CJIS Local Area Security
Officer (LASO) as an exception to this policy and will be considered on a case-by-case basis.

All individuals with IDF access must agree to and have a signed ITB IDF Access Agreement on file.

Contact and coordinate through facilities for any IDF access for fire alarm or phone support as required. Contact ITB
for computer-related issues associated with the IDF.

HB 00194
Las Vegas Metropolitan Police Department
Partners with the Community

OTHER LVMPD FACILITIES

All visitors to the facility will be required to check in and their information will be recorded in the LVMPD Visitor
Log prior to being granted access. At all times, visitors must be escorted by a department member, and must be
segregated from sensitive areas, and from viewing CJI/CHRI, or accessing terminals or printouts that contain or access
CJI/CHRI.

VENDORS / CONTRACTORS

A vendor who is contracted to work in an LVMPD facility (who has been background checked and issued a LVMPD
contractors badge) may be allowed in a facility unescorted to attend to their duties only.

All other vendors who are not issued LVMPD contractor badges must be treated as a visitor to include being recorded
in the LVMPD Visitor Log, escorted by a department member at all times, and remain segregated from sensitive areas,
and from viewing CJI/CHRI, or accessing terminals or printouts that contain or access CJI/CHRI.

VISITOR LOGS

All LVMPD Visitor Logs must be retained at the facility where they were used for a period of no less than four years.

ESCORTS

At all times, authorized personnel must escort visitors, inmate workers, maintenance persons, non-employees or any
unauthorized personnel to areas where CJI/CHRI is viewable or accessible. An unauthorized person being escorted
in a physically secure area must be escorted by a person who is sufficiently familiar with the equipment in the area
and the tasks being performed. The escort must be able to identify an unauthorized act and alert security personnel.
If the escort does not have this set of knowledge and skills, then the unauthorized person is not considered escorted.

TEMPORARY OCCUPANTS

Temporary occupants include extended training, contractors, vendors, and employees from other agencies assigned to
the Fusion Center. These occupants will be required to sign a waiver and successfully pass a criminal history check
(See LVMPD 5/111.12, Contract Employees and Workers). In all cases where workers will be accessing sensitive
and restricted areas of this facility this check must be conducted prior to allowing access to these areas even when
escorted.

ACCESS CONTROL (PROXY) CARDS

ISSUANCE OF CARDS

The Facilities Section will issue and log all access control cards through a computer database system located within
the Facilities Section. All sworn and civilian police department members and those non-members designated will be
issued an access control card. These cards must be carried with the department identification card at all times within
the facility.

TRANSFERS/TERMINATIONS

When a department member terminates employment, the member is required to turn in their issued ID card and access
control card to their supervisor. Transfer and access changes to the control card will be updated in the Facilities
computer database only upon presentation of the written orders or directives changing the assignment. Terminations
require immediate notification by the bureau/area commander or Labor Relations to the Facilities Section so access
can be removed. The member will not be completely removed from the system until the actual card is received in the
Facilities Section.

HB 00195
Las Vegas Metropolitan Police Department
Partners with the Community

REPLACEMENT PROCESS

MAINTENANCE OF ACCESS CARD

The department member is responsible for the condition of the access card. The card is not to be altered, defaced,
punctured, trimmed or exposed to extreme heat. Replacement of the damaged card, or one that no longer operates,
shall be completed by presenting the damaged card and the temporary card (if obtained) to the Facilities Section
System Administrator. A member may be held accountable, if the damage was caused by the member through
negligence. Damage may result in discipline or replacement costs based upon the circumstances.

LOST CARDS

Lost or stolen access cards must be reported immediately to the Facilities Section system administrator to protect and
secure the integrity of department facilities. Once the card is reported missing, it can be rendered “unusable” by the
system administrator. Access cards that are lost or stolen after normal business hours, (0700-1600 M-F), must be
reported to the Communications Bureau (who will disable the card) via the non-emergency number. The Facilities
Section will not issue a new access card without a missing/found property event number being issued. An event
number can be obtained by reporting the lost/stolen card to the Communications Bureau or any area command.

ACCESS CARD OPERATION

The access control cards will allow members to hold the card within a 4-6 inch distance from the card reader to activate
the unlocking mechanism. Should the card reader not be functional, contact the Facilities Section in a timely manner.
Once the card has been “read,” the member’s information will be maintained in a database, to include which door was
activated and the date and time of entry. All members shall be held responsible for the activity attributed to their
cards, and for this reason, access cards will not be loaned out.

KEY SYSTEMS AND SECURITY

PERSONAL KEY SECURITY

Individually issued keys for headquarters will be issued and logged by the key control coordinator within the Facilities
Section.

Members are responsible for all issued facility keys they are issued. Keys to the facility will be secured at all times.
Any lost or damaged keys will be handled in the same manner as lost or damaged access cards. (Refer to the
REPLACEMENT PROCESS section above.)

MASTER KEY SECURITY

Bureau/area commanders and administrative assistants will be issued sub-master keys that will open the doors in their
area. Master keys will be documented on a log and stored in a locked key safe that is maintained by the Facilities
Section.
LOCKSMITHS

Any locksmiths that are contracted to work within the facility will be required to sign a waiver, and must pass a
criminal history check, as with any other vendor. Locksmiths will be coordinated through the Facilities Section and
will be provided an escort, who will take control of any duplicate keys or locks.

HEADQUARTERS VIDEO SURVEILLANCE

The entire perimeter of the headquarters facility and some access areas are equipped with security cameras monitored
by the Headquarter Police Detail. These cameras provide additional security and protection for members at
headquarters. Members may contact the Visitor Information Station to verify security status or conditions around the
perimeter of the building and at the Visitors Information Stations.

HB 00196
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MEMBER IDENTIFICATION

Members will display their LVMPD identification on their person above the waist line on the outermost garment, and
will ensure that it is plainly visible. Temporary occupants assigned to the Fusion Center must display the “SNCTC”
ID badge issued by the Records and Fingerprint Bureau.

OPCON CHANGES: OPERATIONAL CONTROLS

In the event that a change to the national or local operational conditions occurs, the Headquarters Police Detail will
direct changes to the security levels of the facility. The implementation and adherence to the changes will be at the
direction of a captain or above. Executive Staff will be briefed to the extent possible and will be kept notified of any
changes. (9/18, 5/19)■

HB 00197
1 Elizabeth J. Bassett, Esq. (NV Bar No. 9013)
Associate Counsel
2
Nevada Commission on Ethics
3 704 West Nye Lane, Suite 204
Carson City, Nevada 89703
4 (775) 687-5469
Email: ebassett@ethics.nv.gov
5

6 Attorney for Ross E. Armstrong, Esq.


Executive Director
7
STATE OF NEVADA
8

9 BEFORE THE COMMISSION ON ETHICS


10

11
In re Joseph M. Lombardo,
Sheriff of Clark County, Consolidated Ethics Complaint
12 State of Nevada, Case Nos. 21-062C, 21-082C
13 Subject /
14

15 MOTION FOR SUMMARY JUDGMENT

16 Ross E. Armstrong, Esq., Executive Director of the Nevada Commission on


17 Ethics (“Commission”), through the Commission’s Associate Counsel, Elizabeth J.
18 Bassett, Esq., submits this Motion for Summary Judgment pursuant to NAC 281A.265
19 and NRCP 56(c).
20 POINTS AND AUTHORITIES
21 The consolidated Ethics Complaints (“Complaints”) at issue in this matter
22 involve the alleged conduct of Joseph M. Lombardo (“Lombardo” or “Subject”), former
23 Sheriff of the Las Vegas Metropolitan Police Department (“LVMPD”), Clark County,
24 State of Nevada, in violating the Ethics Law, NRS 281A.
25 I. INTRODUCTION
26 Public officers and employees have a responsibility to commit themselves to
27 avoid conflicts between their private interests and the public they serve under the
28 Ethics Law. NRS 281A.020. “In particular, a public officer or employee must not use a
Page 1 of 22

HB 00198
1 public position in government to secure unwarranted campaign advantages for
2 themselves . . . Simply, public officers and employees are not entitled to take
3 advantage of public resources to support their own campaign.” In re Antinoro,
4 Comm’n Op. Nos. 18-031C/18-052C (2019) (emphasis added).
5 As the elected Sheriff of the LVMPD, Lombardo was a public officer with the
6 express responsibility to put the public good first and avoid any conflicts between his
7 private interests and the public that he serves. NRS 281A.020. The Ethics Law and the
8 Commission’s precedent have been clear for many years that the use of a uniform and
9 other accoutrements of office—including a badge—to support one’s campaign
10 constitute violations of NRS 281A.400(2) and (7).
11 Nonetheless, Lombardo posted numerous photographs of himself wearing his
12 Sherriff’s uniform and badge on his campaign social media accounts in support of his
13 campaign to be elected to the position of the Governor of Nevada. Summary judgment
14 finding that Lombardo committed multiple violations of the Ethics Law is therefore
15 warranted.
16 II. ISSUES PRESENTED
17 1. Whether Lombardo violated NRS 281A.400(2) by using his public position,
18 namely his uniform, badge, equipment and other accoutrements of his LVMPD
19 office, while campaigning for the office of Governor of Nevada.
20 2. Whether Lombardo violated NRS 281A.400(7) by using his uniform and other
21 accoutrements of his LVMPD office while campaigning for the office of
22 Governor of Nevada.
23 III. APPLICABLE LAW
24 A. Summary Judgment Standard of Review
25 Summary judgment should be granted where the pleadings and evidence in the
26 record demonstrate that no genuine issue of material fact exists, and the moving party
27 is entitled to judgment as a matter of law. NRCP 56(c); Cervantes v. Health Plan of
28 Nevada, 127 Nev., Adv. Op. 70 at 3, 263 P.3d 261, 264 (2011). The substantive law
Page 2 of 22

HB 00199
1 controls which factual disputes are material and will preclude summary judgment;
2 other factual disputes are irrelevant. Wood v. Safeway, Inc., 121 Nev. 724, 729, 121
3 P.3d 1026, 1029 (2005). Where, as here, the parties have stipulated to a set of facts,
4 Nevada courts have held that “there is obviously no issue of material fact presented
5 and summary judgment is proper.” Farmers Ins. Exch. v. Young, 108 Nev. 328, 330,
6 832 P.2d 376, 377 (1992).
7 B. Standard of Proof
8 The standard of proof in an administrative proceeding before the Commission is
9 a preponderance-of-the-evidence standard. NRS 281A.480(9). Preponderance of the
10 evidence refers to “the greater weight of the evidence.” McClanahan v. Raley’s, Inc.,
11 117 Nev. 921, 925-26, 34 P.3d 573, 576 (2001) (quoting Black’s Law Dictionary 1201
12 (7th ed. 1999)). Thus, the factual findings of an administrative decision will only be
13 overturned if they are not supported by substantial evidence, which is evidence that a
14 reasonable mind could accept as adequate to support a conclusion. NRS 233B.135(4);
15 Nassiri v. Chiropractic Physicians’ Bd., 130 Nev., Adv. Op. 27, 327 P.3d 487, 489
16 (2014).
17 The Executive Director respectfully submits that he is entitled to summary
18 judgment because the parties have stipulated to all the facts necessary to prove the
19 violations at issue and the preponderance of evidence shows that the Subject violated
20 NRS 281A.400(2) and NRS 281A.400(7).
21 IV. RELEVANT FACTUAL BACKGROUND
22 A. Lombardo Campaigned Using His Uniform, Badge and Other
23 Accouterment of His Public Office
24 Lombardo was elected to the position of Sheriff of the LVMPD in 2014 after
25 beginning his career with the Department in 1988. On June 28, 2021, Lombardo
26 announced his candidacy for the office of Governor of Nevada. Lombardo made the
27 announcement of his candidacy live on Fox News wearing a LVMPD Sheriff’s badge
28 on his lapel. See Stipulated Fact (“SF”) Nos. 6, 9 and 11; Stipulated Exhibit (“SE”) 1.
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HB 00200
1 As he campaigned for office of Governor, Lombardo made the visual imagery of
2 his position as Sheriff his central campaign theme. His profile pictures for his social
3 media accounts highlight him in his Sheriff’s uniform and wearing his badge. The tweet
4 announcing his candidacy for the office of Governor of Nevada included a video
5 featuring Lombardo in his Sheriff uniform, showing his Sheriff badge and other
6 accouterment of his office. See SE 2.
7 Even the Nevada media took notice of Lombardo’s use of his uniform and
8 badge to promote his candidacy:
9 It’s no secret Joe Lombardo is running for governor on his record
as Clark County sheriff.
10

11 When he kicked off his gubernatorial campaign last month, he said


he would distinguish himself from his Republican primary opponents by
12 taking the “law and order lane.” A biography on Lombardo’s campaign
website emphasizes his more than 30 years of experience in law
13
enforcement. A campaign video touts that his life’s work has been to
14 “serve and protect.”

15 It’s common for candidates to talk on the campaign trail about how
their day jobs and prior elected offices would shape their approach in
16
office. But Lombardo has made the fact he is the current Clark County
17 sheriff all but impossible to ignore in the first month of his campaign. A
photo on his website shows him grinning broadly in uniform. The
18 campaign video features clips with Lombardo in full uniform walking and
talking with constituents. A pamphlet handed out during a meet-and-greet
19 displays Lombardo, hands on his hips, with a sheriff ’s badge prominently
20
placed on his chest.

21 See Executive Director’s Exhibit 36, Newspaper Article, Tabitha Mueller, The Nevada
22 Independent, July 19, 2021.
23 Lombardo had several campaign social media accounts, including the twitter
24 account @JoeLombardoNV and the Facebook page, “Joe Lombardo for Governor”.
25 See SF Nos. 14-15 and 42-43. The tweets and posts on both of these social media
26 accounts were issued in support of Lombardo’s campaign for Governor of Nevada. Id.
27 Between June 28, 2021, when he announced his candidacy for Governor of
28 Nevada, and September 15, 2021, the date he was provided notice of the first of the
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HB 00201
1 two Complaints in these consolidated matters, 26 tweets were posted to
2 @JoeLombardoNV featuring pictures or videos of Lombardo wearing a combination of
3 his LVMPD badge and/or uniform. See SF Nos. 14-41; SE 2-27. During this same time
4 period, 8 pictures and videos were posted to the “Joe Lombardo for Governor”
5 Facebook page featuring Lombardo wearing a combination of his LVMPD badge
6 and/or uniform. See SF Nos. 42-50; SE 28-34.
7 Lombardo’s campaign website–www.joelombardofornv.com–links to a Flickr
8 page containing numerous pictures of Lombardo wearing his LVMPD uniform,
9 including his LVMPD badge, handcuffs and other items typically worn on the belt of
10 police officers. See SF No. 12 and SE 2. There are also images of Lombardo with a
11 protective vest with a patch stating “Police” across the front and a LVMPD badge. Id.
12 The campaign website also links to a Vimeo video hosting site, featuring two videos
13 both of which show Lombardo in his LVMPD uniform and with his LVMPD badge and
14 gun. See https://vimeo.com/user143013087.
15 Even after he received notice of the Complaints in these matters, Lombardo
16 continued to post hundreds of pictures and videos to his campaign twitter and
17 Facebook page, showing him wearing his LVMPD uniform and badge.1
18 V. STIPULATED FACTS AND DOCUMENTS
19 The parties have jointly stipulated to the following facts and documents:
20 A. STIPULATED FACTS
21 1. Joseph M. Lombardo (“Lombardo”) was the elected Sheriff of the Las
22 Vegas Metropolitan Police Department (“LVMPD”) in 2014 and 2018.
23 2. Sheriff is a public officer as defined in NRS 281A.160. Sheriff is the only
24 uniformed public office in the State of Nevada. A sheriff is never “off duty,” and must
25 always be required to respond to a law enforcement emergency.
26 3. Clark County is a political subdivision as defined in NRS 281A.145.
27

28 1The Executive Director is not currently seeking violations for any posts after September 15, 2021, the
date Lombardo received notice of the first of these two Complaints.
Page 5 of 22

HB 00202
1 4. The LVMPD is a local agency as defined in NRS 281A.119. LVMPD
2 receives funding from the federal government of the United States of America.
3 5. LVMPD’s Policy Manual is publicly available. See Exhibit “35.” Section
4 2/114.00 sets forth LVMPD’s Political Activities Policy and allows LVMPD employees
5 to appear in uniform for their own campaign photographs since their doing so “does
6 not constitute an endorsement.”
7 6. Lombardo announced his candidacy for the office of Governor of Nevada
8 on or about June 28, 2021.
9 7. Lombardo campaigned as a candidate for the office of Governor of
10 Nevada from on or about June 28, 2021 to on or about election day, November 8,
11 2022.
12 8. Because the Nevada Legislature declined to make the position of sheriff a
13 “resign to run” position, Lombardo remained a public officer as defined in NRS
14 281A.160 throughout his gubernatorial campaign.
15 9. The video located at https://youtu.be/9E-NjOsJKN8, Exhibit 1, features
16 Lombardo announcing his candidacy for the office of Governor of Nevada on June 28,
17 2021.
18 10. Exhibit 1 was filmed at the office of Lombardo’s campaign manager, not
19 his LVMPD office. Exhibit 1 does not depict any LVMPD employees, LVMPD insignia,
20 or anything else that would give viewers a reason to believe Lombardo was in his
21 LVMPD office.
22 11. Lombardo is wearing a LVMPD Sheriff’s badge on his lapel in Exhibit 1.
23 12. During the course of Lombardo’s partisan political campaign, he created
24 certain photographs and videos. At issue below is one campaign video, a still shot
25 from that same campaign video, and two photographs. As set forth in greater detail
26 below, the foregoing images depict Lombardo in his Sheriff’s uniform and/or wearing
27 his Sheriff badge or lapel pin. The firearm depicted in these images is that which he is
28

Page 6 of 22

HB 00203
1 required to carry as Sheriff, and is Lombardo’s personal property (as opposed to
2 LVMPD property).
3 13. The creation of the foregoing images (i) did not interfere with Lombardo’s
4 duties as Sheriff, (ii) did not violate any LVMPD policy, and (iii) to the extent they
5 posed any cost to LVMPD or the public, such cost was nominal.
6 14. The twitter account belonging to Lombardo’s campaign for Governor of
7 Nevada is @JoeLombardoNV.
8 15. Tweets posted to @JoeLombardoNV were posted in support of
9 Lombardo’s campaign for Governor of Nevada
10 16. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
11 Sheriff’s badge in Exhibit 2, which is a video posted on @JoeLombardoNV on June
12 28, 2021.
13 17. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
14 Sheriff’s badge in Exhibit 3, which is a picture posted as part of a tweet on
15 @JoeLombardoNV on June 28, 2021.
16 18. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
17 Sheriff’s badge in Exhibit 4, which is a video posted on @JoeLombardoNV on July 1,
18 2021.
19 19. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
20 Sheriff’s badge in Exhibit 5, which is a tweet posted on @JoeLombardoNV on July 7,
21 2021.
22 20. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
23 Sheriff’s badge in Exhibit 6, which is a tweet posted on @JoeLombardoNV on July 8,
24 2021.
25 21. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
26 Sheriff’s badge in Exhibit 7, which is a tweet posted on @JoeLombardoNV on July 14,
27 2021.
28

Page 7 of 22

HB 00204
1 22. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
2 Sheriff’s badge in Exhibit 8, which is a video posted on @JoeLombardoNV on July 18,
3 2021.
4 23. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
5 Sheriff’s badge in Exhibit 9, which is a tweet posted on @JoeLombardoNV on July 18,
6 2021.
7 24. Lombardo was wearing his LVMPD Sheriff’s badge in Exhibit 10, which is
8 a tweet posted on @JoeLombardoNV on July 22, 2021.
9 25. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
10 Sheriff’s badge in Exhibit 11, which is a video posted on @JoeLombardoNV on July
11 23, 2021.
12 26. Lombardo was wearing his LVMPD Sheriff’s badge in Exhibit 12, which is
13 a tweet posted on @JoeLombardoNV on July 27, 2021.
14 27. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
15 Sheriff’s badge in Exhibit 13, which is a video posted on @JoeLombardoNV on July
16 30, 2021.
17 28. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
18 Sheriff’s badge in Exhibit 14, which is a tweet posted on @JoeLombardoNV on August
19 3, 2021.
20 29. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
21 Sheriff’s badge in Exhibit 15, which is a tweet posted on @JoeLombardoNV on August
22 5, 2021.
23 30. Lombardo was wearing his LVMPD Sheriff’s uniform, his LVMPD Sheriff’s
24 badge in Exhibit 16, which is a video posted on @JoeLombardoNV on August 8, 2021.
25 31. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
26 Sheriff’s badge in Exhibit 17, which is a tweet posted on @JoeLombardoNV on August
27 12, 2021.
28

Page 8 of 22

HB 00205
1 32. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
2 Sheriff’s badge in Exhibit 18, which is a second tweet posted on @JoeLombardoNV on
3 August 12, 2021.
4 33. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
5 Sheriff’s badge in Exhibit 19, which is a tweet posted on @JoeLombardoNV on August
6 13, 2021.
7 34. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
8 Sheriff’s badge in Exhibit 20, which is a second tweet posted on @JoeLombardoNV on
9 August 13, 2021.
10 35. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
11 Sheriff’s badge in Exhibit 21, which is a tweet posted on @JoeLombardoNV on August
12 18, 2021.
13 36. Lombardo was wearing his LVMPD Sheriff’s uniform, his LVMPD Sheriff’s
14 badge in Exhibit 22, which is a video posted on @JoeLombardoNV on August 19,
15 2021.
16 37. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
17 Sheriff’s badge in Exhibit 23, which is a tweet posted on @JoeLombardoNV on August
18 20, 2021.
19 38. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
20 Sheriff’s badge in Exhibit 24, which is a tweet posted on @JoeLombardoNV on
21 September 9, 2021.
22 39. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
23 Sheriff’s badge in Exhibit 25, which is a tweet posted on @JoeLombardoNV on
24 September 10, 2021.
25 40. Lombardo was wearing his LVMPD Sheriff’s badge in Exhibit 26, which is
26 a second tweet posted on @JoeLombardoNV on September 10, 2021.
27 ///
28 ///
Page 9 of 22

HB 00206
1 41. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
2 Sheriff’s badge in Exhibit 27, which is a video posted on @JoeLombardoNV on
3 September 14, 2021.
4 42. The Facebook account belonging to Lombardo’s campaign for Governor of
5 Nevada is entitled “Joe Lombardo for Governor”.
6 43. Posts to the Facebook page “Joe Lombardo for Governor” were made in
7 support of Lombardo’s campaign for Governor of Nevada.
8 44. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
9 Sheriff’s badge in Exhibit 28, which is a Facebook post on “Joe Lombardo for
10 Governor” on July 8, 2021.
11 45. Lombardo was wearing his LVMPD Sheriff’s badge in Exhibit 29, which is
12 a Facebook post on “Joe Lombardo for Governor” on July 27, 2021.
13 46. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
14 Sheriff’s badge in Exhibit 30, which is a Facebook post on “Joe Lombardo for
15 Governor” on August 5, 2021.
16 47. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
17 Sheriff’s badge in Exhibit 31, which is a Facebook post on “Joe Lombardo for
18 Governor” on September 9, 2021.
19 48. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
20 Sheriff’s badge in Exhibit 32, which is a Facebook post on Joe Lombardo for Governor
21 on July 7, 2021.
22 49. Lombardo was wearing his LVMPD Sheriff’s uniform and his LVMPD
23 Sheriff’s badge in Exhibit 33, which is a Facebook post on Joe Lombardo for Governor
24 on July 14, 2021.
25 50. Lombardo was wearing his LVMPD Sheriff’s badge in Exhibit 34, which is
26 a Facebook post on Joe Lombardo for Governor on July 22, 2021.
27 ///
28 ///
Page 10 of 22

HB 00207
1 B. STIPULATED DOCUMENTS
2 Exhibit 1: The video located at https://youtu.be/9E-NjOsJKN8 features Lombardo
3 announcing his candidacy for the office of Governor of Nevada on June
4 28, 2021.
5 Exhibit 2: A video posted to @JoeLombardoNV on June 28, 2021 as part of a
6 tweet announcing Lombardo’s candidacy for the office of Governor of
7 Nevada.
8 Exhibit 3: A tweet posted on @JoeLombardoNV on June 28, 2021.
9 Exhibit 4: A video posted on @JoeLombardoNV on July 1, 2021.
10 Exhibit 5: A tweet posted on @JoeLombardoNV on July 7, 2021.
11 Exhibit 6: A tweet posted on @JoeLombardoNV on July 8, 2021.
12 Exhibit 7: A tweet posted on @JoeLombardoNV on July 14, 2021.
13 Exhibit 8: A video posted on @JoeLombardoNV on July 18, 2021.
14 Exhibit 9: A tweet posted on @JoeLombardoNV on July 18, 2021.
15 Exhibit 10: A tweet posted on @JoeLombardoNV on July 22, 2021.
16 Exhibit 11: A video posted on @JoeLombardoNV on July 23, 2021.
17 Exhibit 12: A tweet posted on @JoeLombardoNV on July 27, 2021.
18 Exhibit 13: A video posted on @JoeLombardoNV on July 30, 2021.
19 Exhibit 14: A tweet posted on @JoeLombardoNV on August 3, 2021.
20 Exhibit 15: A tweet posted on @JoeLombardoNV on August 5, 2021.
21 Exhibit 16: A video posted on @JoeLombardoNV on August 8, 2021.
22 Exhibit 17: A tweet posted on @JoeLombardoNV on August 12, 2021.
23 Exhibit 18: A second tweet posted on @JoeLombardoNV on August 12, 2021.
24 Exhibit 19: A tweet posted on @JoeLombardoNV on August 13, 2021.
25 Exhibit 20: A second tweet posted on @JoeLombardoNV on August 13, 2021.
26 Exhibit 21: A tweet posted on @JoeLombardoNV on August 18, 2021.
27 Exhibit 22: A video posted on @JoeLombardoNV on August 19, 2021.
28 Exhibit 23: A tweet posted on @JoeLombardoNV on August 20, 2021.
Page 11 of 22

HB 00208
1 Exhibit 24: A tweet posted on @JoeLombardoNV on September 9, 2021.
2 Exhibit 25: A tweet posted on @JoeLombardoNV on September 10, 2021.
3 Exhibit 26: A second a tweet posted on @JoeLombardoNV on September 10, 2021.
4 Exhibit 27: A video posted on @JoeLombardoNV on September 14, 2021.
5 Exhibit 28: A Facebook post on “Joe Lombardo for Governor” on July 8, 2021.
6 Exhibit 29: A Facebook post on “Joe Lombardo for Governor” on July 27, 2021.
7 Exhibit 30: A Facebook post on “Joe Lombardo for Governor” on August 5, 2021.
8 Exhibit 31: A Facebook post on “Joe Lombardo for Governor” on September 9,
9 2021.
10 Exhibit 32: A Facebook post on “Joe Lombardo for Governor” on July 7, 2021.
11 Exhibit 33: A Facebook post on “Joe Lombardo for Governor” on July 14, 2021.
12 Exhibit 34: A Facebook post on “Joe Lombardo for Governor” on July 22, 2021.
13 Exhibit 35: LVMPD’s Policy Manual.
14 VI. LEGAL ANALYSIS
15 A. The Stipulated Facts Show that Lombardo Violated NRS 281A.400(2)
16 The undisputed facts show that Lombardo’s conduct violated NRS 281A.400(2).
17 Summary judgment should be granted against Lombardo and in favor of the Executive
18 Director finding that Lombardo committed 34 violations of NR 281A.400(2).
19 NRS 281A.400(2) provides:
20 A public officer or employee shall not use the public officer’s or employee’s
position in government to secure or grant unwarranted privileges,
21
preferences, exemptions or advantages for the public officer or employee.
22 As used in this subsection, “unwarranted” means without justification or
adequate reason.
23

24 1. Lombardo is a public officer


25 As the elected Sheriff of the LVMPD, Lombardo was at all relevant times a
26 public officer as defined in NRS 281A.160. See SF Nos. 1-2.
27 ///
28 ///
Page 12 of 22

HB 00209
1 2. Lombardo used his position as Sheriff to secure unwarranted
2 privileges for himself in his campaign
3 A violation of NRS 281A.400(2) occurs when a public officer (1) uses his
4 position in government, (2) to grant himself an unwarranted privilege. Lombardo’s use
5 of his uniform, badge and other accoutrements of his Sheriff position in support of his
6 campaign is the unwarranted privilege at issue.
7 The Commission previously determined in In re Antinoro, Comm’n Op. Nos. 18-
8 031C/18-052C (2019):
9 Public officers and employees have a responsibility to avoid conflicts
10
between their private interests and the public they serve. NRS 281A.020.
In particular, a public officer or employee must not use a public position in
11 government to secure unwarranted campaign advantages for themselves
. . . . In addition, public officers and employees must not use government
12 time, property or resources to benefit their own campaigns . . . . Simply,
13
public officers and employees are not entitled to take advantage of public
resources to support their own campaign.
14

15 The Commission has therefore definitively held that public officers, such as
16 Lombardo, may not use government property, such as uniforms or badges, in support
17 of their own campaigns.
18 In a prior advisory opinion, the Commission considered the Washoe County
19 Sheriff’s use of his office, title, employees, time, equipment and “physical
20 accoutrements” of the office in a televised political advertisement for a district judge.
21 See In re Kirkland, Comm’n Op. No. 98-41 (1999). The Commission found that the
22 Sheriff’s endorsement advertisement that showed his badge, uniform and official title
23 resulted in an “advantage” and the question then became whether the advantage was
24 “unwarranted” under NRS 281.481(2), the predecessor statute to NRS 281A.400(2).
25 The Commission held that an elected public officer’s use of name and title only were
26 not precluded by the Ethics Law, so long as their use complied with the established
27 written policies of the public entity.
28 ///
Page 13 of 22

HB 00210
1 In In Re Kuzanek, Comm’n Op. No. 14-61C (2014), the Commission found that
2 the use of the uniform and badge “as a visual endorsement, affirmation and, and
3 sanction of Kuzanek’s campaign for sheriff” provided him an unfair advantage at
4 government cost. Further, in a recent opinion, the Commission emphasized:
5 The Commission continues to caution against any attempt, even an
incidental one, to bolster a political endorsement by the use of a public
6
office and associated accouterments or any governmental property,
7 equipment or resources. Such uses provide the impression that the public
officer is acting in an official capacity implicating NRS 281A.400(2).
8

9 In re Public Officer, Comm’n Op. No. 19-124A (2020), at p. 6.


10 The Commission has therefore consistently held that the use of a uniform and
11 other accoutrements of office—such as a badge—by a public officer to support their
12 own campaign is an unwarranted benefit that violates NRS 281A.400(2). In this case,
13 the Stipulated Facts show that Lombardo is a public employee (SF Nos. 1-2), he was
14 campaigning for election to the position of Governor of Nevada (SF Nos. 6-7), and he
15 posted a total of 34photographs and videos to his campaign Twitter account and
16 Facebook page featuring him in his Sheriff uniform and badge. (SF Nos. 9-50; SE 1-
17 34). Therefore, under the existing precedent of the Commission, no genuine issues of
18 material fact exist as to whether Lombardo violated NRS 281A.400(2).
19 Summary judgment should therefore be entered in favor of the Executive
20 Director and against Lombardo as to 34 violations of NRS 281A.400(2)—one violation
21 for each of the photographs and videos at issue.
22 B. The Undisputed Facts Show that Lombardo Violated NRS 281A.400(7) and
23 that the Statute’s Limited-Use Exception Does Not Apply to His Conduct
24 The undisputed facts show that Lombardo violated NRS 281A.400(7).
25 Summary judgment should be granted against Lombardo and in favor of the Executive
26 Director finding that Lombardo committed 34 violations of NR 281A.400(7).
27 ///
28 ///
Page 14 of 22

HB 00211
1 NRS 281A.400(7) provides:
2 Except for State Legislators who are subject to the restrictions set forth in
subsection 8, a public officer or employee shall not use governmental time,
3
property, equipment or other facility to benefit a significant personal or
4 pecuniary interest of the public officer or employee. This subsection does
not prohibit:
5 (a) A limited use of governmental property, equipment or other facility
for personal purposes if:
6
(1) The public officer or employee who is responsible for and has
7 authority to authorize the use of such property, equipment or other facility
has established a policy allowing the use or the use is necessary as a
8 result of emergency circumstances;
(2) The use does not interfere with the performance of the public
9 officer’s or employee’s public duties;
10
(3) The cost or value related to the use is nominal; and
(4) The use does not create the appearance of impropriety;
11

12 1. Lombardo is a public officer


13 As shown above, Lombardo is a public officer.
14 2. Lombardo used governmental time, property, equipment or other
15 facility to benefit his significant personal or pecuniary interest
16 A violation of NRS 281A.400(7) occurs when a public officer (1) uses
17 governmental time, property, equipment or other facility, (2) to benefit his significant
18 personal or pecuniary interest.
19 Lombardo had a significant personal and financial interest in being elected
20 Governor of Nevada. See In re Public Officer, Comm’n Op. No.19-124A (2020), at p.
21 4; In re Antinoro, Comm’n Op. Nos. 18-031C/18-052C (2019); In re Matson, Comm’n
22 Op. No. 11-67C (2014). He used government property—his Sheriff uniform and
23 badge—in support of his efforts to be elected Governor. Lombardo therefore used
24 governmental property and equipment to benefit his significant personal or pecuniary
25 interest in being elected—a violation of NRS 281A.400(7).
26 Supporting this position is the education and outreach the Commission provided
27 to the Nevada Sheriffs’ and Chiefs’ Association in 2019—while Lombardo served as
28 Sheriff of the LVMPD—as a result of the stipulated agreement reached in In re

Page 15 of 22

HB 00212
1 Antinoro, Comm’n Op. Nos. 18-031C and 18-052C (2019). In a letter dated October 7,
2 2019, the Commission explained:
3 The Commission has now definitively concluded that no state or local
government law enforcement official, including an elected incumbent
4
official, may wear his/her uniform, badge or other physical accouterment of
5 office, . . . in support or opposition of a political campaign, including his/her
own campaign or as an endorsement. Such use constitutes a violation of
6 NRS 281A.400(7).
7 See Executive Director’s Exhibit 37. Lombardo works for a law enforcement agency
8 and wore his uniform and other physical accouterment of his office in support of his
9 own campaign. As this Commission has previously determined, “Such use constitutes
10 a violation of NRS 281A.400(7).” Id.
11 3. NRS 281A.400(7)(a)’s limited-use exception does not apply
12 NRS 281A.400(7)(a) does not prohibit a limited-use of governmental property,
13 equipment or other facility for personal purposes if the use meets all of the following
14 four factors:
15 (1) The public officer or employee who is responsible for and has
16
authority to authorize the use of such property, equipment or other
facility has established a policy allowing the use or the use is
17 necessary as a result of emergency circumstances;
(2) The use does not interfere with the performance of the public
18 officer’s or employee’s public duties;
(3) The cost or value related to the use is nominal; and
19
(4) The use does not create the appearance of impropriety;
20

21 NRS 281A.400(7)(a). Although Lombardo meets the first three of the exception’s
22 factors, he fails to meet the fourth. Thus, the limited-use exception does not apply to
23 excuse Lombardo’s conduct.
24 The Commission established a “hard line” in In re Kirkland, Comm’n Op. No.
25 98-41 (1999), clearly stating: “A public officer will create an appearance of impropriety
26 under NRS 281A.481(7)(a)(4) if, in the course of endorsing a person’s candidacy, he
27

28

Page 16 of 22

HB 00213
1 uses the physical accouterments of his office or position to bolster the endorsement.”2
2 See In re Cochran, Comm’n Op. No. 22-126C (2023); In re Coverley, Comm’n Op.
3 No. 22-055C (2022). Lombardo therefore cannot establish that he meets the
4 requirements of the limited-use exception under NRS 281A.400(7)(a) because his use
5 of his uniform and other physical accouterments of his position with LVMPD to
6 support his own campaign created an appearance of impropriety.
7 Summary judgment should therefore be entered in favor of the Executive
8 Director and against Lombardo as to 34 violations of NRS 281A.400(7)—one for each
9 use of the uniform and/or badge in Stipulated Exhibits 1 through 34.
10 WILLFULNESS DETERMINATION
11 C. The Undisputed Facts Show Lombardo’s Violations Were Willful
12 In determining whether a violation of the Ethics Law is a willful violation, NRS
13 281A.775(1) directs the Commission to consider:
14 (a) The seriousness of the violation or alleged violation, including, without
limitation, the nature, circumstances, extent and gravity of the violation
15
or alleged violation;
16
(b) The number and history of previous warnings, letters of caution or
17 instruction, deferral agreements or violations or alleged violations of
the provisions of this chapter relating to the public officer or employee;
18

19 (c) The cost to conduct the investigation and any meetings, hearings or
other proceedings relating to the violation or alleged violation;
20
(d) Any mitigating factors, including, without limitation, any self-reporting,
21
prompt correction of the violation or alleged violation, any attempts to
22 rectify the violation or alleged violation before any ethics complaint is
filed and any cooperation by the public officer or employee in resolving
23 the ethics complaint;
24
(e) Any restitution or reimbursement paid to parties affected by the
25 violation or alleged violation;
///
26
///
27

28 2The NRS cited in Kirkland is now NRS 281A.400(7)(a)(4).

Page 17 of 22

HB 00214
1 (f) The extent of any financial gain resulting from the violation or alleged
violation; and
2

3 (g) Any other matter justice may require.

4 Each of these factors is addressed below.


5 1. The seriousness of the violation
6 The Commission has determined that using a uniform and other accouterment
7 of a public officer’s public position to secure an advantage for themselves in a
8 campaign is a serious Ethics Law violation. In In re Antinoro, Comm’n Op. Nos. 18-
9 031C/18-052C (2019) the Commission determined:
10 Public officers and employees have a responsibility to avoid conflicts
between their private interests and public they serve. NRS 281A.020. In
11
particular, a public officer or employee must not use a public position in
12 government to secure unwarranted campaign advantages for themselves
. . . . Simply, public officers and employees are not entitled to take
13 advantage of public resources to support their own campaign.
14 The Commission’s holding is unequivocal—there are no circumstances under which it
15 is appropriate for public officers, such as Lombardo, to use public resources to support
16 their own campaign. This was recently confirmed by In re Cochran, Comm’n Op. No.
17 22-126C in which a fire chief’s use of his badge and uniform in a video posted to social
18 media was determined to be a willful violation of the Ethics Law. Lombardo’s conduct
19 is similar in nature to Cochran but the scope of the use in Cochran is dwarfed by
20 Lombardo’s. The vast number of times the uniform and badge were used in campaign
21 materials increases the seriousness of the violation. There are 34 distinct uses
22 attached to this case.
23 Adding to the seriousness of Lombardo’s violations of the Ethics Law is the
24 evidence that he committed them knowingly. In a July 19, 2021 article in The Nevada
25 Independent, Lombardo’s campaign strategist, Ryan Erwin, admitted that the strategy
26 of pushing Lombardo’s government-funded image in his LVMPD owned-uniform and
27 with his LVMPD-owned badge was purposeful in order to bring his position as Sheriff
28 to the forefront of voters’ attention, arguing,
Page 18 of 22

HB 00215
1 Lombardo is a police officer and sheriff, and Nevada voters are entitled to
know and see what he does for a living . . . Judges regularly appear in
2
robes, teachers in classrooms, and prosecutors in courtrooms as part of
3 their campaign materials - all are public employees in positions of trust.
Singling out law enforcement from other positions of public trust makes no
4 sense.
5 See Executive Director’s Exhibit 36, Newspaper Article, Tabitha Mueller, The Nevada
6 Independent, July 19, 2021. Lombardo therefore posted the photographs and videos at
7 issue knowing that they violated the Ethics Law.
8 2. The number and history of previous violations
9 Lombardo has no previous ethics violations.
10 3. The cost to conduct the investigation and hearing
11 This matter proceeded through an investigation, to a Review Panel, and
12 through dispositive motions. The parties were able to stipulate to all relevant facts
13 which reduced investigation costs.
14 4. Self-reporting or correction
15 There was no self-reporting or correction of the Ethics Law violations by
16 Lombardo, nor did he attempt to rectify the violations either before or after the
17 Complaints were filed in this matter. Lombardo maintained the images on his
18 campaign social media sites after receiving notification of the investigation. In order to
19 benefit from the self-correction prong of the willfulness test, Lombardo would have
20 needed to remove the images that used his uniform and accouterments. Not only did
21 he fail to do so but he continued to produce additional campaign content featuring the
22 use of his uniform, badge, and gun all the way through the end of the campaign.
23 5. Any restitution or reimbursement paid
24 Lombardo has not paid any restitution or reimbursement in this matter nor is
25 this a matter where restitution or reimbursement would be contemplated.
26 6. The extent of any financial gain
27 Lombardo was elected Governor. Accordingly, he has realized a financial gain
28 in the amount of the salary and benefits that he receives as Governor.
Page 19 of 22

HB 00216
1 PENALTY
2 The Commission has various remedies by law following a determination that a
3 violation of the Ethics Law has occurred. The Executive Director requests that the
4 following penalties be applied in this case should the Commission grant the Motion for
5 Summary Judgement:
6 A. A censure from the Commission. A censure is appropriate when the
7 Commission finds a willful violation and there is evidence that the violation
8 involved “bad faith, malicious intent or knowing or reckless disregard of the
9 law.” NRS 281A.785(2)(b). In this matter, Lombardo was a Sheriff and a
10 member of the Sheriffs and Chiefs Association when the Commission provided
11 that organization specific notice and instructions on the impropriety of using
12 uniforms and accouterments to benefit campaigns. In addition, the campaign
13 responses in the media indicate that they had no concern about the rules of
14 Nevada’s Ethics Law in highlighting Lombardo’s public officer position in the
15 campaign for Governor.
16 B. A requirement to designate an Ethics Officer within the Governor’s Office.
17 The Commission make “take any combination of such actions or any other
18 reasonable action that...will remedy the violation or alleged violation of deter
19 similar violation or conduct.” NRS 281A.785(1)(c). The Executive Director is
20 requesting that as a remedy, the Governor be required to designate an existing
21 Governor’s Office employee as an Ethics Officer. That Ethics Officer is to
22 receive training and technical assistance from the Executive Director with the
23 aim for the Governor’s Office to have internal capacity to prevent or mitigate
24 potential future ethics violations within the Governor’s Office.
25 C. A civil penalty of $1,665,000. The Commission can fine up to $5,000 for a first
26 willful violation of this chapter, $10,000 for a separate act that constitutes a
27 second willful violation of this chapter, and $25,000 for a separate act or event
28 that constitutes a third willful violation of this chapter. Each time Lombardo’s
Page 20 of 22

HB 00217
1 campaign posted an image, published a video, or otherwise caused a campaign
2 post to include Lombardo in his uniform, badge, or gun constitutes a separate
3 act. Therefore, as shown in the Penalty Matrix provided as Executive Director’s
4 Exhibit 38, a total fine of $1,665,000 is warranted in this matter.
5 VII. CONCLUSION
6 Based on the foregoing, summary judgment should be granted in favor of the
7 Executive Director and against Lombardo as follows:
8 • 34 violations of NRS 281A.400(2) and 34 violations of NRS 281A.400(7),
9 for a total of 68 Ethics Law violations;
10 • A censure from the Commission;
11 • A requirement to designate an Ethics Officer within the Governor’s
12 Office; and
13 • A $1,665,000 fine.
14

15 DATED this 22nd day of March, 2023.


16
NEVADA COMMISSION ON ETHICS
17

18
/s/ Elizabeth J. Bassett
19 Elizabeth J. Bassett, Esq.
20
Associate Counsel
Nevada Commission on Ethics
21

22

23

24

25

26

27

28

Page 21 of 22

HB 00218
1 CERTIFICATE OF SERVICE
2 I certify that I am an employee of the Nevada Commission on Ethics and that
3 on this day in Carson City, Nevada, I served via email, a true and correct copy of
4 the foregoing document in Ethics Complaint Nos. 21-062C and 21-082C to the
5 following:
6 Joseph M. Lombardo
c/o Donald J. Campbell, Esq.
7
Samuel R. Mirkovich, Esq.
8 Campbell & Williams
710 South Seventh St. Ste. A
9 Las Vegas, NV 89101
Email: srm@cwlawlv.com
10
Email: mmh@cwlawlv.com
11 Attorneys for Subject Joseph M. Lombardo

12

13
Dated: March 22, 2023 /s/ Elizabeth J. Bassett__________
14 Employee,
Nevada Commission on Ethics
15

16

17

18

19

20

21

22

23

24

25

26

27

28

Page 22 of 22

HB 00219
1 Elizabeth J. Bassett, Esq. (NV Bar No. 9013)
Associate Counsel
2
Nevada Commission on Ethics
3 704 West Nye Lane, Suite 204
Carson City, Nevada 89703
4 (775) 687-5469
Email: ebassett@ethics.nv.gov
5

6 Attorney for Ross E. Armstrong, Esq.


Executive Director
7
STATE OF NEVADA
8

9 BEFORE THE COMMISSION ON ETHICS

10

11
In re Joseph M. Lombardo,
12 Sheriff of Clark County, Consolidated Ethics Complaint
State of Nevada, Case Nos. 21-062C, 21-082C
13

14
Subject /

15
EXHIBITS IN SUPPORT OF EXECUTIVE DIRECTOR’S
16 MOTION FOR SUMMARY JUDGMENT
17
Ross E. Armstrong, Esq., Executive Director of the Nevada Commission on
18
Ethics (“Commission”), through the Commission’s Associate Counsel, Elizabeth J.
19 Bassett, Esq., hereby submits his Exhibits in Support of his Motion for Summary
20 Judgment in this matter:
21

22 Exhibit No. Exhibit

23

Newspaper Article, Tabitha Mueller, The Nevada Independent,


24 36
July 19, 2021
25

26
2019 Letter to the Sheriffs’ and Chiefs’ Association
37
27

28

Page 1 of 3

HB 00220
1

2
Executive Director’s Penalty Matrix
3 38
4

5 DATED this 22nd day of March, 2023.

6 NEVADA COMMISSION ON ETHICS

8 /s/ Elizabeth J. Bassett


Elizabeth J. Bassett, Esq.
9 Associate Counsel
10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Page 2 of 3

HB 00221
1 CERTIFICATE OF SERVICE
2 I certify that I am an employee of the Nevada Commission on Ethics and
3 that on this day in Carson City, Nevada, I served via email, a true and correct copy
4 of the foregoing document in Ethics Complaint Nos. 21-062C and 21-082C to the
5 following:
6 Joseph M. Lombardo
c/o Donald J. Campbell, Esq.
7
Samuel R. Mirkovich, Esq.
8 Campbell & Williams
710 South Seventh St. Ste. A
9 Las Vegas, NV 89101
Email: srm@cwlawlv.com
10
Email: mmh@cwlawlv.com
11 Attorneys for Subject Joseph M. Lombardo

12

13
Dated: March 22, 2023 /s/ Elizabeth J. Bassett
14 Employee, Nevada Commission on Ethics

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Page 3 of 3

HB 00222
EXECUTIVE DIRECTOR’S EXHIBITS
EXHIBIT 36

HB 00223
7/19/2021 As Lombardo campaigns for governor in sheriff’s uniform, state law, ethics commission guidance remain hazy on propriety of doing so - The Nevada Independent

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As Lombardo campaigns for governor in sheriff’s uniform, state law, ethics commission guidance
remain hazy on propriety of doing so
Tabitha Mueller July 19th, 2021 at 2:00 AM State Government
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Sheriff Joseph Lombardo, left, graduates new officers during Metro Police's graduation exercises on Thursday, Oct. 19, 2017. The

https://thenevadaindependent.com/article/as-lombardo-campaigns-for-governor-in-sheriffs-uniform-state-law-ethics-commission-guidance-remain-hazy-on-propriety-of-doing-so 1/5
HB 00224
7/19/2021 As Lombardo campaigns for governor in sheriff’s uniform, state law, ethics commission guidance remain hazy on propriety of doing so - The Nevada Independent
class graduated 38 officers. (Jeff Scheid/The Nevada Independent)

It’s no secret Joe Lombardo is running for governor on his record as Clark County sheriff.

When he kicked off his gubernatorial campaign last month, he said he would distinguish himself from his Republican
primary opponents by taking the “law and order lane.” A biography on Lombardo’s campaign website emphasizes his
more than 30 years of experience in law enforcement. A campaign video touts that his life’s work has been to “serve and
protect.”

It’s common for candidates to talk on the campaign trail about how their day jobs and prior elected offices would shape
their approach in office. But Lombardo has made the fact he is the current Clark County sheriff all but impossible to ignore
in the first month of his campaign. A photo on his website shows him grinning broadly in uniform. The campaign video
features clips with Lombardo in full uniform walking and talking with constituents. A pamphlet handed out during a
meet-and-greet displays Lombardo, hands on his hips, with a sheriff’s badge prominently placed on his chest. 

What isn’t quite as clear is whether Lombardo is actually allowed to use the imagery of his elected office — including his
uniform and badge — to campaign for another one. Existing decisions surrounding the topic only address cases in which a
sheriff was running for re-election, and even those are not etched in stone.

When reached for comment about the legal uncertainty surrounding the topic, Lombardo’s campaign strategist, Ryan
Erwin, told The Nevada Independent that Lombardo is a police officer and sheriff, and Nevada voters are entitled to know
and see what he does for a living. He also said that knowing a candidate’s work experience is vital when selecting a
governor.

“Judges regularly appear in robes, teachers in classrooms, and prosecutors in courtrooms as part of their campaign
materials - all are public employees in positions of trust,” Erwin said. “Singling out law enforcement from other positions
of public trust makes no sense.”

Erwin added that elections and rules governing them should always be fairly applied and politicians use photos from
events in campaign materials all the time.

Under state law, public officials and employees cannot use government time, property, equipment or other resources to
benefit themselves or anyone else. But the law is mum on whether an officer or other public official using their uniform or
badge while campaigning presents an actual conflict of interest. 

David Hall, executive director of the Nevada Commission on Ethics, declined to comment on Lombardo’s use of his badge
and uniform in his gubernatorial campaign, noting that it’s up to a public officer or employee to ask the commission for an
opinion detailing the compliance obligations associated with their own conduct.

https://thenevadaindependent.com/article/as-lombardo-campaigns-for-governor-in-sheriffs-uniform-state-law-ethics-commission-guidance-remain-hazy-on-propriety-of-doing-so 2/5
HB 00225
7/19/2021 As Lombardo campaigns for governor in sheriff’s uniform, state law, ethics commission guidance remain hazy on propriety of doing so - The Nevada Independent

Reviews by the Commission on Ethics, an eight-member body appointed by the governor and Legislative Commission
charged with interpreting and enforcing Nevada’s ethics laws, occur on a case-by-case basis to account for nuance and
different situations. Commission decisions can result in a letter of caution or a fine, but the consequences of any given
review are case-dependent.

“We encourage these public officers and public employees to utilize the advisory opinion process should they have
questions about their individual compliance obligations under the Ethics Law,” Hall wrote in an email.

Though there is no word on whether the commission has been asked to take up Lombardo’s case, this isn’t the first time
the issue of using the accoutrements of the sheriff’s office to campaign has come before the commission. The commission
has penned at least three orders over the last seven years relating to sheriffs’ abilities to use official uniforms, badges and
“other physical accouterments” of the office to support re-election campaigns — including one that prompted the
commission to reach out to the state sheriffs' association in an attempt to prevent the issue from arising again.

In 2014, the commission determined that then-Washoe County Deputy Sheriff Tim Kuzanek’s use of his uniform and
badge in his campaign for sheriff acted as a visual endorsement and provided an unfair advantage to Kuzanek at the
expense of the government. Kuzanek was not, however, punished for the use of his uniform and badge because the
commission concluded that Kuzanek’s actions were not a willful violation of the law in this particular case.

When the question again arose in 2016, during a commission investigation into then-Elko County Sheriff Jim Pitts, the
body dismissed the alleged violations because state law does not explicitly prohibit an officer from using uniforms or
badges in campaigns.

“The issue of whether an elected, incumbent sheriff may campaign in uniform is one of first impression for the State of
Nevada and the Commission, and has not been addressed by Nevada’s courts or Legislature,” the commission wrote in its
opinion. “Without State or local law governing or clarifying duties of elected incumbents regarding utilization of the
accoutrements of office, the parties stipulate to dismissal of the alleged violation.”

The commission’s most recent ruling on the matter was in 2018, when the panel investigated then-Storey County Sheriff
Gerald Antinoro’s decision to wear his sheriff uniform during debates and in photos used in campaign materials while
running for re-election. In that case, the commission decided the campaign had not violated ethics law based on prior
precedent and Antinoro’s lack of knowledge about rules and regulations. 

However, the commission noted in its decision that an elected sheriff’s use of official accouterments of office to support
re-election creates an “appearance of impropriety” and violates the state’s ethics law, a point it underscored by sending a
letter to the Nevada Sheriffs’ and Chiefs’ Association recommending the association inform its members of the ethics
commission’s position on the matter.

“Under the Ethics Law, public officers and employees have a duty to avoid conflicts of interest and protect the public’s
faith in the appropriate separation between the use of government resources and private endeavors,” the letter said.

https://thenevadaindependent.com/article/as-lombardo-campaigns-for-governor-in-sheriffs-uniform-state-law-ethics-commission-guidance-remain-hazy-on-propriety-of-doing-so 3/5
HB 00226
7/19/2021 As Lombardo campaigns for governor in sheriff’s uniform, state law, ethics commission guidance remain hazy on propriety of doing so - The Nevada Independent

“Specifically, a public officer or employee must not use official government resources in support of a political campaign.”

That ethics commission position isn’t, however, codified in state law, leaving the use of uniforms and badges in campaign
materials an open question.

During the most recent legislative session, Assemblywoman Robin Titus (R-Wellington) proposed a bill, AB218, that
would have allowed sheriffs to use physical accouterments in campaigns. Though the bill received a hearing, it died
without receiving a vote in its first committee.

The Nevada Independent is a 501(c)3 nonprofit news organization. We are committed to transparency and disclose all our
donors. The following people or entities mentioned in this article are financial supporters of our work:

David Hall - $120

Tabitha Mueller
Tabitha Mueller is a general assignment reporter at The Nevada Independent who also covers the Legislature.

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HB 00227
7/19/2021 As Lombardo campaigns for governor in sheriff’s uniform, state law, ethics commission guidance remain hazy on propriety of doing so - The Nevada Independent

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https://thenevadaindependent.com/article/as-lombardo-campaigns-for-governor-in-sheriffs-uniform-state-law-ethics-commission-guidance-remain-hazy-on-propriety-of-doing-so 5/5
HB 00228
EXECUTIVE DIRECTOR’S EXHIBITS
EXHIBIT 37

HB 00229
Cheryl A. Lau, Esq. Yvonne Nevarez-Goodson, Esq.
Chair Executive Director
(D) 775-687-4312
Keith A. Weaver, Esq. ynevarez@ethics.nv.gov
Vice-Chair
State of Nevada
COMMISSION ON ETHICS
704 W. Nye Lane, Suite 204
Carson City, Nevada 89703
(775) 687-5469 • Fax (775) 687-1279
http://ethics.nv.gov

October 7, 2019

Via U.S. mail and electronic mail:


eric@nvsca.com

Eric Spratley
Executive Director
Nevada Sheriffs’ and Chiefs’ Association
P.O. Box 17971
Reno, NV 89511

Re: Ethics Decisions Involving Sheriffs and Chiefs:


Uniforms/Badges/Letterhead During Campaigns

Dear Executive Director Spratley,

The Ethics in Government Law (“Ethics Law”) set forth in NRS Chapter 281A gives
the Nevada Commission on Ethics (“Commission”) jurisdiction over the conduct of state
and local government public officers 1 and public employees 2 regarding conflicts of
interest between public duties and private interests, including state and local government
law enforcement officers and employees.

The Commission has recently addressed several matters involving various state
and local government law enforcement positions, and the accompanying conflicts of
interest that have resulted in the context of political activity. As a courtesy, and as directed
pursuant to a stipulated agreement between the Commission and Storey County Sheriff,
Gerald Antinoro, I am contacting you to provide important guidance for state and local
government law enforcement officials who contemporaneously seek an appointed or
elected position. See In re Antinoro, Comm’n Op. Nos. 18-031C and 18-052C (2019),
enclosed. The Commission strongly encourages the Nevada Sheriffs’ and Chiefs’
Association to inform its members of this guidance. The Commission has determined that
it is a violation of the Ethics Law for a state or local government law enforcement officer
or employee to wear or use his/her uniform, badge or other physical accouterment of
office, or official letterhead or government email to support or oppose any political
campaign.

1 “Public officer” is a person serving in a position designated by NRS 281A.160 and 281A.182.
2 “Public employee” is defined as a person who performs public duties under the direction of a public officer
for compensation paid by the State or any county, city or other political subdivision. NRS 281A.150.

HB 00230
Page 2, October 7, 2019, Nevada Sheriffs’ and Chiefs’ Association Letter

Under the Ethics Law, public officers and employees have a duty to avoid conflicts
of interest and protect the public’s faith in the appropriate separation between the use of
government resources and private endeavors. Specifically, a public officer or employee
must not use official government resources in support of a political campaign. For
purposes of this matter, government resources include, without limitation, an official
uniform, badge or other physical accouterment of public office, or the official letterhead or
government-issued email account.

The Commission has previously determined that a public employee of a state or


local government law enforcement agency is prohibited from using a uniform, badge or
other physical accouterment of public office in support of his/her political campaign or as
part of a political endorsement, even if the property is purchased by the public officer or
employee. A public officer or employee has a significant personal and financial interest in
achieving or maintaining an elected position, or endorsing another candidate for an
elected position.

However, the Commission understands that there has been previous reliance by
elected, incumbent law enforcement officials on a 2012 advisory opinion issued by the
United States Office of Special Counsel (“OSC”) regarding application of the federal
Hatch Act, which restricts certain political activities of certain state and local government
employees. The OSC Opinion advised that elected sheriffs were permitted to wear
uniforms while campaigning for themselves or another candidate without violating the
Hatch Act. However, the Hatch Act and the OSC’s advisory opinions apply only to partisan
political activities and are not binding or determinative on state or local government laws
or policies that prohibit such use. Nevada has enacted the Ethics Law, which has been
interpreted by the Commission to prohibit such use.

A law enforcement uniform and badge signify the power and prestige of the office
and are considered governmental property for purposes of the Ethics Law. The
Commission has now definitively concluded that no state or local government law
enforcement official, including an elected, incumbent official, may wear his/her uniform,
badge or other physical accouterment of office, and may not use official letterhead or
government email, in support or opposition of a political campaign, including his/her own
campaign or as an endorsement. Such use constitutes a violation of NRS 281A.400(7).

The Commission has further opined that the public’s trust in government is
questioned when there is an appearance of government interference or influence during
an election. See In re Parish, Comm’n Op. No. 12-64C (2013) (“A representative
democracy guarantees the right of the people to govern through elected representatives,
the integrity of which is voiced through the electoral process where elected
representatives are held accountable … inherent in the electoral process are guarantees
of free, open and equal participation by the voters, including assurances that government
remains neutral in the process and allows all candidates a fair and equal chance to win,
free of manipulation from public money, power or influence. … While government
resources should not be used to support [or oppose] any candidate during an election,
the law specifically ensures that an incumbent candidate should not receive unwarranted
or unfair benefits … during an election through the use of public resources to promote his
candidacy. The Legislature secures government neutrality in elections by regulating the
conduct of public officers and employees who are entrusted with public resources to
ensure that the election process is not manipulated through the use of public resources
or other influence.”)

HB 00231
Page 3, October 7, 2019, Nevada Sheriffs’ and Chiefs’ Association Letter

The Commission’s interest in this matter is not intended to infringe upon the
operations of law enforcement. Instead, the Commission values and appreciates the
public’s reliance on law enforcement and balances those duties against the multitude of
concerns it has received in recent years questioning the appropriate separation between
the public duties and private political campaigns of state and local government law
enforcement officers. Consequently, the Commission has provided clear guidance, which
hereafter has precedential value and will be enforceable against all state and local
government law enforcement officers and employees.

The Commission’s decisions, as well as a link to NRS Chapter 281A and other
relevant informational guides for public officers, are available on the Commission’s
website, www.ethics.nv.gov.

If you have any questions or concerns, please do not hesitate to contact me. I am
also available to provide Ethics in Government Law training to your organization if further
education is desired on these matters.

Sincerely,

/s/ Yvonne M. Nevarez-Goodson__


Yvonne M. Nevarez-Goodson, Esq.
Executive Director

Enclosure

HB 00232
EXECUTIVE DIRECTOR’S EXHIBITS
EXHIBIT 38

HB 00233
1

3 STATE OF NEVADA

4 BEFORE THE COMMISSION ON ETHICS


5

6 In re Joseph M. Lombardo,
Sheriff of Clark County, Consolidated Ethics Complaint
7 State of Nevada, Case Nos. 21-062C, 21-082C
8
Subject /
9

10
PENALTY MATRIX
11
A. Violations of NRS 271A.400(2)
12
Stipulated Fine
Document
13 Exhibit No. Amount
The video located at https://youtu.be/9E-NjOsJKN8
14 1 features Lombardo announcing his candidacy for the $5,000
office of Governor of Nevada on June 28, 2021
15
A video posted to @JoeLombardoNV on June 28, 2021
16 2 as part of a tweet announcing Lombardo’s candidacy $10,000
for the office of Governor of Nevada
17 A tweet posted on @JoeLombardoNV on June 28,
3 $25,0000
18
2021
4 A video posted on @JoeLombardoNV on July 1, 2021 $25,0000
19
5 A tweet posted on @JoeLombardoNV on July 7, 2021 $25,0000
20 6 A tweet posted on @JoeLombardoNV on July 8, 2021 $25,0000
21 7 A tweet posted on @JoeLombardoNV on July 14, 2021 $25,0000
8 A tweet posted on @JoeLombardoNV on July 14, 2021 $25,0000
22
9 A video posted on @JoeLombardoNV on July 18, 2021 $25,0000
23
10 A tweet posted on @JoeLombardoNV on July 18, 2021 $25,0000
24
11 A video posted on @JoeLombardoNV on July 23, 2021 $25,0000
25
12 A tweet posted on @JoeLombardoNV on July 27, 2021 $25,0000
26
13 A video posted on @JoeLombardoNV on July 30, 2021 $25,0000
27
A tweet posted on @JoeLombardoNV on August 3,
14 $25,0000
28 2021

Page 1 of 4

HB 00234
1 A tweet posted on @JoeLombardoNV on August 5,
15 $25,0000
2021
2
A video posted on @JoeLombardoNV on August 8,
16 $25,0000
3 2021
A tweet posted on @JoeLombardoNV on August 12,
4 17 $25,0000
2021
A second tweet posted on @JoeLombardoNV on
5 18 $25,0000
August 12, 2021
6 A tweet posted on @JoeLombardoNV on August 13,
19 $25,0000
2021
7
A second tweet posted on @JoeLombardoNV on
20 $25,0000
8 August 13, 2021
A tweet posted on @JoeLombardoNV on August 18,
21 $25,0000
9 2021
A video posted on @JoeLombardoNV on August 19,
10 22 $25,0000
2021
11 A tweet posted on @JoeLombardoNV on August 20,
23 $25,0000
2021
12 A tweet posted on @JoeLombardoNV on September 9,
24 $25,0000
13 2021
A tweet posted on @JoeLombardoNV on September
25 $25,0000
14 10, 2021
A second a tweet posted on @JoeLombardoNV on
15 26 $25,0000
September 10, 2021
16 A video posted on @JoeLombardoNV on September
27 $25,0000
14, 2021
17 A Facebook post on “Joe Lombardo for Governor” on
28 $25,0000
18
July 8, 2021
A Facebook post on “Joe Lombardo for Governor” on
29 $25,0000
19 July 27, 2021
A Facebook post on “Joe Lombardo for Governor” on
20 30 $25,0000
August 5, 2021
21 A Facebook post on “Joe Lombardo for Governor” on
31 $25,0000
September 9, 2021
22 A Facebook post on “Joe Lombardo for Governor” on
32 $25,0000
July 7, 2021
23
A Facebook post on “Joe Lombardo for Governor” on
33 $25,0000
24 July 14, 2021
A Facebook post on “Joe Lombardo for Governor” on
25 34 $25,0000
July 22, 2021
26 Total Penalties For Violations of NRS 281A.400(2) $815,000
27

28

Page 2 of 4

HB 00235
1

2 B. Violations of NRS 271A.400(7)


3 Stipulated Fine
Document
Exhibit No. Amount
4 The video located at https://youtu.be/9E-NjOsJKN8
5
1 features Lombardo announcing his candidacy for the $25,000
office of Governor of Nevada on June 28, 2021
6 A video posted to @JoeLombardoNV on June 28, 2021
2 as part of a tweet announcing Lombardo’s candidacy $25,000
7 for the office of Governor of Nevada
A tweet posted on @JoeLombardoNV on June 28,
8 3 $25,0000
2021
9 4 A video posted on @JoeLombardoNV on July 1, 2021 $25,0000
10 5 A tweet posted on @JoeLombardoNV on July 7, 2021 $25,0000
11 6 A tweet posted on @JoeLombardoNV on July 8, 2021 $25,0000
7 A tweet posted on @JoeLombardoNV on July 14, 2021 $25,0000
12
8 A tweet posted on @JoeLombardoNV on July 14, 2021 $25,0000
13
9 A video posted on @JoeLombardoNV on July 18, 2021 $25,0000
14 A tweet posted on @JoeLombardoNV on July 18, 2021
10 $25,0000
15
11 A video posted on @JoeLombardoNV on July 23, 2021 $25,0000
16
12 A tweet posted on @JoeLombardoNV on July 27, 2021 $25,0000
17 13 A video posted on @JoeLombardoNV on July 30, 2021 $25,0000
18 A tweet posted on @JoeLombardoNV on August 3,
14 $25,0000
2021
19 A tweet posted on @JoeLombardoNV on August 5,
15 $25,0000
20
2021
A video posted on @JoeLombardoNV on August 8,
16 $25,0000
21 2021
A tweet posted on @JoeLombardoNV on August 12,
22 17 $25,0000
2021
23 A second tweet posted on @JoeLombardoNV on
18 $25,0000
August 12, 2021
24 A tweet posted on @JoeLombardoNV on August 13,
19 $25,0000
2021
25
A second tweet posted on @JoeLombardoNV on
20 $25,0000
26 August 13, 2021
A tweet posted on @JoeLombardoNV on August 18,
27 21 $25,0000
2021
28
22 A video posted on @JoeLombardoNV on August 19, $25,0000

Page 3 of 4

HB 00236
1 2021
A tweet posted on @JoeLombardoNV on August 20,
2 23 $25,0000
2021
3 A tweet posted on @JoeLombardoNV on September 9,
24 $25,0000
2021
4 A tweet posted on @JoeLombardoNV on September
25 $25,0000
5
10, 2021
A second a tweet posted on @JoeLombardoNV on
26 $25,0000
6 September 10, 2021
A video posted on @JoeLombardoNV on September
7 27 $25,0000
14, 2021
8 A Facebook post on “Joe Lombardo for Governor” on
28 $25,0000
July 8, 2021
9 A Facebook post on “Joe Lombardo for Governor” on
29 $25,0000
July 27, 2021
10
A Facebook post on “Joe Lombardo for Governor” on
30 $25,0000
11 August 5, 2021
A Facebook post on “Joe Lombardo for Governor” on
12 31 $25,0000
September 9, 2021
13 A Facebook post on “Joe Lombardo for Governor” on
32 $25,0000
July 7, 2021
14 A Facebook post on “Joe Lombardo for Governor” on
33 $25,0000
July 14, 2021
15
A Facebook post on “Joe Lombardo for Governor” on
34 $25,0000
16 July 22, 2021

17 Total Penalties For Violations of NRS 281A.400(7) $850,000

18

19
Total Penalties For All Violations $1,665,000
20

21

22

23

24

25

26

27

28

Page 4 of 4

HB 00237
1 CAMPBELL & WILLIAMS
J. COLBY WILLIAMS, ESQ. (5549)
2 jcw@cwlawlv.com
PHILIP R. ERWIN, ESQ. (11563)
3
pre@cwlawlv.com
4 SAMUEL R. MIRKOVICH, ESQ. (11662)
srm@cwlawlv.com
5 710 South Seventh Street, Suite A
Las Vegas, Nevada 89101
6 Telephone: (702) 382-5222
Facsimile: (702) 382-0540
7

8 Attorneys for Defendant Joseph Lombardo

9 STATE OF NEVADA
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 BEFORE THE COMMISSION ON ETHICS


11 In re Joseph M. Lombardo, Sheriff of Clark Consolidated Ethics Complaint
Phone: 702.382.5222 • Fax: 702.382.0540

12 County, State of Nevada, Case Nos. 21-062C, 21-082C


www.campbellandwilliams.com

13 JOSEPH LOMBARDO’S RESPONSE TO


MOTION FOR SUMMARY JUDGMENT
14

15

16 POINTS AND AUTHORITIES


17 I. INTRODUCTION1
18
As Governor Lombardo predicted in his opening brief, the Motion for Summary Judgment
19
(the “Motion”) submitted by the Executive Director exhibits a staggering amount of administrative
20

21 overreach combined with several glaring legal errors. Take, for example, the Executive Director’s

22 contention that the Commission has the power to impose fines on Governor Lombardo in the eye-

23 watering amount of $1.665 million based on his use of the same four Images on social media during
24
his gubernatorial campaign. Notwithstanding that such a fine would clearly violate the Excessive
25
Fines Clause in the United States and Nevada Constitutions, the Executive Director flatly ignores
26

27
1
For ease of reference, Governor Lombardo will use the same capitalized terms from his Motion for
28 Summary Judgment (“Lombardo MSJ”).

Page 1 of 8
HB 00238
1 that the plain language of NRS 281A.790 only permits the Commission to impose civil penalties for

2 three willful violations. The Executive Director then compounds that legal error by advancing the
3
specious position that the Commission can impose duplicative fines for the same “act or event” if it
4
allegedly violates multiple sub-sections of NRS 281A.400. Simply put, the Executive Director’s
5
request for civil penalties in the unprecedented amount of $1.665 million is plainly unconstitutional,
6
premised on multiple errors of statutory interpretation, and contrary to the legislature’s unequivocal
7

8 directive in NRS 281A.775(3) that the Commission “treat comparable situations in a comparable

9 manner.”
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 The Executive Director’s unlawful attempt to extract a seven-figure fine from Governor
11
Lombardo should serve as a glaring red flag to the Commission about the other positions that are
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

advanced in the Motion. Indeed, the Executive Director flatly misrepresents the Commission’s
13
decisional history in a misguided attempt to prove Governor Lombardo violated NRS 281A.400(2)
14

15 even though his use of the Images on social media indisputably did not violate any applicable law or

16 policy. Similarly, the Executive Director’s contention that the Commission established a “hard line”

17 in Kirkland that a sheriff’s use of his uniform and badge in support of his own political campaign
18 violates the limited-use exception in NRS 281A.400(7) is directly contradicted this body’s
19
inconsistent prior rulings on the issue. The Commission should take considerable pause before
20
accepting the Executive Director’s dogmatic positions at face value and imposing civil penalties to
21
the tune of $1.665 million in violation of Nevada law.
22

23 II. ARGUMENT

24 A. The Executive Director’s Depiction Of The Commission’s Application Of NRS


281A.400(2) Is Plainly Inaccurate.
25
In support of his contention that Governor Lombardo’s use of the Images violated NRS
26

27 281A.400(2), the Executive Director represents that “[t]he Commission has therefore consistently

28 held that the use of a uniform and other accoutrements of office—such as a badge—by a public

Page 2 of 8
HB 00239
1 officer to support their own campaign is an unwarranted benefit that violates NRS 281A.400(2).”

2 See Mot. at 14:10-12. Suffice it to say, the Executive Director’s representation regarding the
3
Commission’s application of 281A.400(2) to a sheriff’s use of his uniform and badge in a political
4
campaign could not be further from the truth as the Commission has, in fact, consistently reached
5
the opposite result.
6
Nowhere is the Executive Director’s misleading approach more evident than his reliance on
7

8 the Kirkland and Antinoro decisions. Beginning with the latter, the Commission in Antinoro

9 expressly stated that “[a] preference or advantage is unwarranted, in part, if the public officer’s
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 conduct was contrary to any applicable code or policy.” Id. at *5. This finding comports with the
11
Commission’s interpretation of NRS 281A.400(2) in Kirkland where it held that the Washoe County
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

Sheriff’s use of his uniform and badge in a political endorsement for a judicial candidate did not
13
confer an “unwarranted” advantage or preference because it did not violate Nevada or Washoe
14

15 County law. Id. at *3; see also Pitts, at *6-7 (dismissing alleged violation of NRS 281A.400(2) due

16 to absence of “State or local law clarifying duties of elected incumbents regarding utilization of the

17 accoutrements of office”).2
18 To be clear, Governor Lombardo is not aware of any case in which the Commission found
19
that a sheriff’s use of his uniform and badge in a political campaign constitutes a violation of NRS
20
281A.400(2) if it is not prohibited by an applicable law or policy. See Lombardo MSJ at 6-7.
21
Because Governor Lombardo’s use of the Images in social media posts during his gubernatorial
22

23 campaign did not violate any applicable law or policy, see id., the Commission should determine that

24

25
2
26 The Executive Director cites Kuzanek but conspicuously neglects to mention that the quoted excerpt
of the decision related to NRS 281A.400(7), not NRS 281A.400(2). Id. at *6. In that regard, the
27 Commission did not find that the Washoe County Undersheriff in Kuzanek committed a violation of
NRS 281A.400(2) by using his uniform and badge in social media posts to support his campaign for
28 Washoe County Sheriff. Id.

Page 3 of 8
HB 00240
1 no violation of NRS 281A.400(2) occurred here.3

2 B. The Executive Director’s Analysis Of The Limited-Use Exception In NRS 281A.400(7)


Is Exceedingly Cursory And Wrong.
3

4 Again, the Executive Director represents that the Commission established a “hard line” in

5 Kirkland that a sheriff’s use of his uniform and badge for political purposes is a per se violation of
6 the limited-use exception in NRS 281A.400(7). Not quite. Setting aside that Kirkland involved a
7
sheriff’s use of the physical accoutrements of the office to endorse another candidate as opposed to
8
his own campaign for a separate, partisan office, Governor Lombardo demonstrated in his Motion
9
for Summary Judgment that the “appearance of impropriety” standard in the limited-use exception
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10

11 in NRS 281A.400(7) is vague, arbitrary and unconstitutional as applied to this specific issue. See
Phone: 702.382.5222 • Fax: 702.382.0540

12 Lombardo MSJ at 7-14. The Commission’s erratic decisional history on the issue speaks for itself
www.campbellandwilliams.com

13 and belies the Executive Director’s conclusory contention that Governor Lombardo’s use of the
14 Images in support of his gubernatorial campaign constitutes a per se violation of NRS 281A.400(7).
15
C. If The Commission Finds NRS 281A.400(7) Constitutional, Then It Should Deem
16 Governor Lombardo’s Alleged Violations Not Willful.

17 The Seriousness of the Violation


18 Governor Lombardo acknowledges the importance of Nevada’s Ethics in Government law
19
and the critical policies behind the prohibition against the use of government property for personal
20
gain. Nevertheless, Governor Lombardo maintains a good-faith belief that the “appearance of
21
impropriety” standard in the limited-use exception of NRS 281A.400(7) is exceedingly vague and
22

23 unconstitutionally applied as it relates the use of uniforms and badges by law enforcement officers,

24

25
3
26 The Executive Director’s citation to In re Public Officer, Comm’n Op. No. 19-124A (2020)—an
abstract opinion involving a public officer’s use of his title to endorse another candidate—is puzzling
27 given that the Commission has repeatedly addressed this exact issue and held that a sheriff’s use of
his uniform and badge does not violate NRS 281A.400(2) in the absence of any applicable law or
28 policy.

Page 4 of 8
HB 00241
1 a group of public officers that is disproportionately impacted by the Commission’s rulings in this

2 respect. This is especially true when this matter presents an issue of first impression as the
3
Commission has yet to address a scenario where a sheriff used his uniform and badge in a campaign
4
for a different partisan office such as Governor.
5
Respectfully, Governor Lombardo submits that there is a better approach to addressing a
6
sheriff’s use of his uniform and badge in a political campaign that balances the relevant ethical
7

8 considerations without punishing law enforcement officials. While the Commission is certainly

9 entitled to adopt more stringent restrictions when interpreting Nevada’s laws, the United States Office
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 of Special Counsel (“OSC”) has interpreted the Hatch Act, 5 U.S.C. §§ 1501-1508, and advised that
11
there is no blanket prohibition on a sheriff’s use of his uniform or badge while campaigning for re-
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

election or another partisan political office.4 In reaching this conclusion, the OSC reasoned that
13
Congress gave elected officials greater latitude to engage in political activity when it exempted those
14

15 officials from the candidacy prohibition to which other state and local employees are subject. Thus,

16 a sheriff’s use of his title and uniform “when campaigning for himself and other partisan candidates

17 is a natural and foreseeable incident of the elected official being permitted to run for partisan office.”
18 Id. The exact same rationale applies to Nevada’s Ethics in Government Law given that Sheriff is not
19
a “resign-to-run” position.
20
That, of course, is not to say a sheriff’s use of his office and position in campaign activities
21
should be completely unrestricted. Id. To the contrary, the OSC instructed that a sheriff may not (i)
22

23 ask his employees or subordinates to work on or contribute to the campaign, (ii) use his official

24 authority to request citizens to vote for them, (iii) canvass for votes in uniform, or (iv) use his official

25 authority to offer leniency to a citizen suspected of violating the law in exchange for that person’s
26

27

28 4
See Exhibit A (Feb. 29, 2012 OSC Memorandum).

Page 5 of 8
HB 00242
1 promise to vote for the sheriff.5 The OSC’s approach strikes a logical balance by prohibiting

2 activities that would undoubtedly create a legitimate appearance of impropriety or unfair advantage
3
while still allowing the limited use of a sheriff’s badge and uniform in a campaign. This Commission
4
should adopt the same approach.
5
History of Prior Violations, Letters of Caution or Warnings
6
The Executive Director concedes that this factor favors Governor Lombardo as he has no
7

8 prior ethics violations.

9 The Cost Related to the Violation


710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 The Executive Director seemingly concedes that this factor weighs in favor of Governor
11
Lombardo due to the parties’ agreement to resolve this matter with stipulated facts and cross-motions
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

for summary judgment.


13
Mitigating Factors
14

15 The Executive Director does not dispute that Governor Lombardo and his counsel have

16 cooperated with the Commission, Executive Director and their respective counsel to the fullest

17 extent, including by stipulating to an agreed-upon set of facts and resolving this legal issue on the
18 briefs and oral argument. Instead, the Executive Director contends that Governor Lombardo
19
“continued to produce campaign content featuring the use of his uniform, badge, and gun through
20
the end of the campaign.” See Mot. at 19:20-22. Notwithstanding that Governor Lombardo disputes
21
that his use of the Images is a violation of NRS 281A.400(2) or (7), the Executive Director’s
22

23 suggestion that Governor Lombardo “continued to produce content” ignores that this matter involves

24 the use of the same four stock Images that were merely re-posted on social media from time-to-time.

25 Suffice it to say, Governor Lombardo strongly disagrees with the implication that he thumbed his
26

27

28 5
See Exhibit B (Aug. 14, 2018 OSC Memorandum).

Page 6 of 8
HB 00243
1 nose at the Commission in connection with this issue and maintains his good-faith belief concerning

2 the appropriate interpretation of the Ethics in Government law.


3
Restitution to Affected Parties and Financial Gain
4
The Executive Director concedes that this matter does not implicate restitution or
5
reimbursement but contends Governor Lombardo obtained a financial gain from the use of his
6
uniform and badge in the form of his salary and benefits as Governor. In other words, the Executive
7

8 Director asserts that Governor Lombardo’s victory in the 2022 Gubernatorial Election is attributable

9 to his use of the Images in a series of run-of-the-mill social media posts. But there is no evidence
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 whatsoever that would suggest Governor Lombardo’s use of the Images had a cognizable impact on
11
the results of the election; nor could there be as Nevada’s voters knew Governor Lombardo served
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

as the Clark County Sheriff irrespective of any social media posts. There is no evidence to support
13
a causal connection between the Images and Governor Lombardo’s salary and benefits in his current
14

15 position.

16 D. The Executive Director’s Proposed Fine Is Unconstitutional And Violative Of NRS


281A.790(1).
17
Now that the Executive Director has confirmed his exorbitant demand for civil penalties
18

19 amounting to $1.665 million (as opposed to the $790,000 anticipated by Governor Lombardo), there

20 can be no doubt that the Executive Director’s request is legally defective in multiple respects. First,

21 a fine of $1.665 million for a series of social media posts is plainly disproportionate to the gravity of
22
the alleged offense and, thus, unconstitutional under the Excessive Fines Clause. See Lombardo
23
MSJ at 19-21. Second, the Executive Director does not provide any analysis or authority that would
24
permit the Commission to impose civil penalties beyond the third willful act under NRS
25
281A.790(1). Id.
26

27 As if that were not sufficient to demonstrate the Executive Director’s unbounded overreach

28 in this proceeding, his demand for a fine of $1.665 million is subject to yet another fatal flaw. Indeed,

Page 7 of 8
HB 00244
1 as evidenced by the Executive Director’s “Penalty Matrix,” he is double-counting the alleged

2 violations by seeking duplicative civil penalties for the same act or event under NRS 281A.400(2)
3
and (7). But NRS 281A.790(1) only permits the Commission to impose fines for second or third
4
willful violations if they arise out of “a separate act or event.” Accordingly, even if the Commission
5
had the ability to fine Governor Lombardo beyond the third willful violation, it cannot impose
6
duplicative fines for the same social media post of the Images on grounds that such posts constitute
7

8 violations of NRS 281A.400(2) and NRS 281A.400(7). Under the Executive Director’s own theory

9 of the case, each social media post is its own “separate act or event” and, thus, Governor Lombardo
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 can only be subject to a single fine related thereto under the plain language of NRS 281A.790(1).
11
The Commission should correct the Executive Director’s seemingly unfettered view of his authority
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

under Nevada law as it is plainly unconstitutional and violative of the applicable statutes.
13
III. CONCLUSION
14

15 Based on the foregoing, Mr. Lombardo respectfully requests that the Commission grant

16 summary judgment in his favor and dismiss the Complaint. In the alternative, Governor Lombardo

17 respectfully requests that the Commission deem the alleged violations not willful and decline to enter
18 the excessive and unlawful penalties sought by the Executive Director.
19
DATED this 19th day of April, 2023.
20
CAMPBELL & WILLIAMS
21
By /s/ Philip R. Erwin
22
J. COLBY WILLIAMS, ESQ. (5549)
23 PHILIP R. ERWIN, ESQ. (11563)
SAMUEL R. MIRKOVICH, ESQ. (11662)
24 710 South Seventh Street, Suite A
Las Vegas, Nevada 89101
25
Attorneys for Governor Joseph Lombardo
26

27

28

Page 8 of 8
HB 00245
EXHIBIT A
Feb. 29, 2012 OSC
Memorandum

HB 00246
HB 00247
HB 00248
HB 00249
EXHIBIT B
Aug. 14, 2018 OSC
Memorandum

HB 00250
U.S. OFFICE OF SPECIAL COUNSEL
1730 M Street, N.W., Suite 218
Washington, D.C. 20036-4505
202-804-7000

August 14, 2018

Xx. Xxxx Xxx Xxxxxxx


xxx Xxxxxxxxx
Xxxxxxxx, XX xxxxx

VIA ELECTRONIC MAIL: xxxxxxxxxxxxxxxxxxxx

Re: OSC File No. AD-18-xxxx

Dear Mx. Xxx Xxxxxxx:

This letter from the U.S. Office of Special Counsel (OSC) responds to your request for an
advisory opinion regarding the Hatch Act. 1 Specifically, you asked whether you, an incumbent
sheriff up for reelection in the Xxxxx xx Xxx Xxxx, may wear your uniform and drive your
agency-issued vehicle to an event at which you gather signatures for your reelection nominating
petition. As described below, the Hatch Act does not prohibit such activity.

The Hatch Act governs the political activity of certain state and local government
employees in order to protect the public workforce from partisan political influence and ensure
the nonpartisan administration of laws. See generally 5 U.S.C. §§ 1501-1508. The Hatch Act
applies to state and local government employees who work in the executive branch and whose
principal employment is in connection with an activity financed in whole or in part by loans or
grants made by the United States or a federal agency. 2 5 U.S.C. § 1501(4). Such employees
generally may not: (1) use their official authority or influence for the purpose of interfering with
or affecting the result of an election or a nomination for office; (2) coerce, attempt to coerce,
command, or advise another state or local government employee to engage in political activity;
or (3) be a candidate for elective office, if the employee’s salary is paid completely by loans or
grants made by the United States or a federal agency. 5 U.S.C. § 1502(a)(1)-(3). Individuals
holding elective office are exempt from the candidacy prohibition. 5 U.S.C. § 1502(c)(4).

We have interpreted the statutory restriction on an employee using official authority or


influence to affect an election to prohibit most covered employees from using an official title or
wearing an agency uniform while engaging in political activity. However, we generally do not
extend those prohibitions to employees holding elective office. Congress has explicitly granted
employees holding elective office greater leeway to engage in political activity by exempting

1
OSC is authorized by 5 U.S.C. § 1212(f) to issue opinions interpreting the Hatch Act.
2
We assume for purposes of this advisory opinion that sheriffs in the Xxxxx xx Xxx Xxxx are within the executive
branch and that you have duties in connection with an activity financed by the United States or a federal agency, and
therefore that you are subject to the Hatch Act.

HB 00251
U.S. Office of Special Counsel
Page 2

them from the candidacy prohibition. Because incumbents already hold partisan political office,
we have reasoned that incumbents do not violate the Hatch Act by wearing a uniform or using an
official title while campaigning for reelection. Thus, we have advised that a sheriff may attend
campaign events while wearing his uniform and identifying himself as the sheriff or use
photographs of himself in uniform for campaign purposes. Similarly, a sheriff does not violate
the Hatch Act by driving an agency-issued vehicle to a campaign event.

This is not to say that sheriffs are completely exempt from the prohibition on using
official authority to interfere with or affect an election or a nomination for office. Certain other
actions, such as a sheriff offering leniency to an individual suspected of violating the law in
exchange for that person’s promise to vote for the sheriff, would constitute a prohibited use of
official authority. Similarly, a sheriff may not go door-to-door canvassing for voter support
while in uniform. This is so because a private citizen, not knowing whether the sheriff was there
to discuss a law enforcement matter, might feel compelled to open the door when that citizen
would not feel similarly compelled to open the door for campaign volunteers or a candidate not
in uniform. To avoid creating any such feelings of compulsion, which would be a prohibited use
of official authority, a sheriff should not engage in door-to-door canvassing while in uniform.

Additionally, sheriffs remain subject to the Hatch Act prohibition on coercing or


attempting to coerce other employees into making political contributions. See 5 U.S.C.
§ 1502(a)(2). Asking a subordinate employee to make a political contribution or volunteer for a
political campaign is considered inherently coercive. See Special Counsel v. Acconcia (CB-
1216-06-0007-T-1, February 26, 2007) (Initial Decision at 9), modified, 107 M.S.P.R. 60 (2007),
citing Special Counsel v. Purnell, 37 M.S.P.R. 184, 195 (1988), aff’d sub nom. Fela v. U.S. Merit
Sys. Prot. Bd., 730 F. Supp. 779 (N.D. Ohio 1989). Where the supervisor-subordinate
relationship exists, no particular words are required to establish coercion because virtually any
language can be threatening. See Special Counsel v. Gallagher, 44 M.S.P.R. 57, 76 (1990).
Thus, sheriffs should not ask subordinate employees to contribute to a political campaign.

Please contact OSC attorney Eric Johnson at (202) 804-7044 if you have any additional
questions.

Sincerely,

Erica S. Hamrick
Deputy Chief, Hatch Act Unit

HB 00252
1 CAMPBELL & WILLIAMS
J. COLBY WILLIAMS, ESQ. (5549)
2 jcw@cwlawlv.com
PHILIP R. ERWIN, ESQ. (11563)
3
pre@cwlawlv.com
4 SAMUEL R. MIRKOVICH, ESQ. (11662)
srm@cwlawlv.com
5 710 South Seventh Street, Suite A
Las Vegas, Nevada 89101
6 Telephone: (702) 382-5222
Facsimile: (702) 382-0540
7

8 Attorneys for Defendant Joseph Lombardo

9 STATE OF NEVADA
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 BEFORE THE COMMISSION ON ETHICS


11 In re Joseph M. Lombardo, Sheriff of Clark Consolidated Ethics Complaint
Phone: 702.382.5222 • Fax: 702.382.0540

12 County, State of Nevada, Case Nos. 21-062C, 21-082C


www.campbellandwilliams.com

13 JOSEPH LOMBARDO’S MOTION FOR


SUMMARY JUDGMENT
14

15

16 POINTS AND AUTHORITIES


17 I. INTRODUCTION
18
The Executive Director’s heavy-handed approach to this proceeding is astounding.
19
Notwithstanding that this Complaint arises out of nothing more than a handful of photographs
20

21 depicting former Sheriff of Clark County and current Governor Joseph Lombardo (“Governor

22 Lombardo”) in his Las Vegas Metropolitan Police Department (“LVMPD”) uniform and badge that

23 were posted to his campaign’s website and social media accounts, the Executive Director has
24
indicated that he believes Governor Lombardo should be subject to nearly $800,000 in civil penalties.
25
What’s more, the Executive Director has threatened Governor Lombardo with impeachment—just
26
months after Nevada’s voters elected him in the 2022 Gubernatorial Election—based on the same
27
photographs even though the conduct occurred when Governor Lombardo held a different position
28

Page 1 of 22
HB 00253
1 that was subject to different removal proceedings. Simply put, the Executive Director’s approach to

2 this proceeding is the equivalent of using a sledgehammer to swat a fly.


3
There are more than a few problems with the Executive Director’s theory of the case. First,
4
the Commission has repeatedly found that a sheriff’s use of his uniform and badge in campaign
5
materials does not confer an “unwarranted” advantage under NRS 281A.400(2) because no state law,
6
code or policy prohibits it. Second, the “appearance of impropriety” standard in the “limited use”
7

8 exception to NRS 281A.400(7) is subjective, arbitrary and unconstitutionally vague as evidenced by

9 the Commission’s erratic decisional history related to the use of uniforms and badges in political
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 campaigns. Third, even if Governor Lombardo’s campaign photographs created an appearance of


11
impropriety under NRS 281A.400(7), the factors enumerated in NRS 281A.775(1) require a finding
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

that any violation was not willful. Fourth, the civil penalties sought by the Executive Director are
13
plainly barred by the statutory language of NRS 281A.790(1) and, in any event, would violate the
14

15 Excessive Fines Clauses in the United States and Nevada Constitutions. And, lastly, the Executive

16 Director’s threat to seek Governor Lombardo’s impeachment in his current position based on alleged

17 ethics violations as the Sheriff of Clark County is clearly not permitted by law. The Complaint
18 against Governor Lombardo should be dismissed.
19
II. STATEMENT OF UNDISPUTED FACTS1
20
A. Factual Background.
21
1. Governor Lombardo served as the elected Sheriff of LVMPD from 2014 through
22

23 2022.

24

25

26

27
1
Unless otherwise stated herein, Governor Lombardo’s Statement of Undisputed Facts is supported
28 by the parties’ Stipulated Facts and Documents submitted to the Commission on January 12, 2023.

Page 2 of 22
HB 00254
1 2. Sheriff is a public officer as defined in NRS 281A.160. Sheriff is the only uniformed

2 public office in the State of Nevada and is never “off duty.” That means a Sheriff must always be
3
ready to respond to a law enforcement emergency in his or her jurisdiction.
4
3. Clark County is a political subdivision as defined in NRS 281A.145.
5
4. LVMPD is a local agency as defined in NRS 281A.119, which receives funding from
6
the federal government of the United States of America.
7

8 5. LVMPD maintains a publicly available Policy Manual that contains its Political

9 Activities Policy.2 Specifically, Section 2/114.00 provides that LVMPD employees may appear in
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 uniform for their own campaign photographs since it “does not constitute an endorsement.”
11
6. Governor Lombardo announced his candidacy for the office of Governor of Nevada
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

on or about June 28, 2021, and campaigned through Election Day, November 8, 2022.
13
7. Because the Nevada Legislature declined to make the position of Sheriff a “resign to
14

15 run” position, Governor Lombardo continued to serve in his position as Clark County Sheriff during

16 his campaign for the office of Governor of Nevada. Thus, Governor Lombardo remained a public

17 officer as defined in NRS 281A.160 at all relevant times during his campaign.
18 8. Governor Lombardo and his campaign created a video announcing his candidacy for
19
the office of Governor of Nevada that was publicly disseminated on June 28, 2021.3 Governor
20
Lombardo filmed the video at the office of his campaign manager, not his LVMPD office. The video
21
does not depict any LVMPD employees, LVMPD insignia, or anything else that would give viewers
22

23 a reason to believe Lombardo filmed the video in his LVMPD office. Governor Lombardo did,

24 however, wear a LVMPD Sheriff’s badge on his lapel in the video.

25

26

27 2
Exhibit 35 (LVMPD Policy Manual).
28 3
Exhibit 1 (Campaign Video), available at https://youtu.be/9E-NjOsJKN8.

Page 3 of 22
HB 00255
1 9. During the course of Governor Lombardo’s partisan political campaign, he and his

2 campaign created certain photographs and videos—one campaign video, a still shot from that same
3
campaign video, and two photographs (collectively, the “Images”)—which are at issue in this
4
proceeding. The Images depict Lombardo in his Sheriff’s uniform and/or his badge or lapel pin. The
5
firearm depicted in the Images is Governor Lombardo’s personal property (as opposed to LVMPD
6
property), which he is required to carry as Sheriff.
7

8 10. Governor Lombardo’s campaign posted the Images of him wearing his LVMPD

9 Sheriff’s uniform and/or his badge or lapel pin on the Twitter account, @JoeLombardoNV, on 26
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 occasions during the course of Governor Lombardo’s campaign.4


11
11. Governor Lombardo’s campaign also posted the Images of him wearing his LVMPD
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

Sheriff’s uniform and/or his badge or lapel pin on the Facebook account, Joe Lombardo for Governor,
13
on 7 occasions during the course of Governor Lombardo’s campaign.5
14

15 12. The creation of the foregoing Images (i) did not interfere with Lombardo’s duties as

16 Sheriff, (ii) did not violate any LVMPD policy, and (iii) to the extent they posed any cost to LVMPD

17 or the public, such cost was nominal.


18 13. Notably, media organizations and news publications frequently depicted Governor
19
Lombardo wearing his Sheriff’s uniform and/or Sheriff’s badge when reporting on the announcement
20
of his candidacy or his campaign for the office of Governor of Nevada.6
21

22

23
4
Exhibits 2-27 (Twitter Posts).
24
5
25 Exhibits 28-34 (Facebook Posts).
6
26 Exhibit 36 (Assorted Media Articles). The Commission (or a court in future proceedings) may take
judicial notice of newspaper articles and other online publications to establish what was in the public
27 realm during Governor Lombardo’s campaign. See, e.g., Von Saher v. Norton Simon Museum of Art,
592 F.3d 954, 960 (9th Cir. 2009) (“Courts may take judicial notice of publications introduced to
28 indicate what was in the public realm at the time[.]”).

Page 4 of 22
HB 00256
1 B. Procedural History.

2 1. Former Executive Director David Hall filed the instant Ethics Complaint
3
(“Complaint”) against then-Sheriff Lombardo on September 1, 2021, alleging violations of NRS
4
281A.400(2) and NRS 281A.400(7) related to his campaign’s posting of the Images on Twitter and
5
Facebook.
6
2. The Commission filed its Order Initiating Ethics Complaint, Accepting Jurisdiction,
7

8 and Directing an Investigation on September 15, 2021, and Governor Lombardo submitted his

9 Response to the Complaint on January 14, 2022.


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10 3. In correspondence from counsel, the Executive Director has indicated that he intends
11
to pursue a theory that each post to the campaign’s website or social media accounts containing one
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

of the Images is a separate, willful violation that would subject Governor Lombardo to repeated
13
monetary penalties under NRS 281A.790(1). In other words, the Executive Director contends that
14

15 the Commission can impose fines on Governor Lombardo in the aggregate amount of $790,000 for

16 the 33 social media posts that are at issue in this proceeding.7 The Executive Director has also

17 indicated his belief that the Commission can somehow seek to commence impeachment proceedings
18 against Governor Lombardo under NRS 281A.790(4)(b) notwithstanding that the alleged violations
19
occurred while he held the office of Clark County Sheriff, which would be subject to different
20
removal proceedings under NRS 281A.790(4)(c).
21
.....
22

23 .....

24 .....

25

26
7
The Executive Director, in fact, previously threatened Governor Lombardo with civil penalties in
27 the total amount of $1,965,000 for an astounding 80 alleged willful violations although it is not clear
how the amount of alleged violations was determined. Exhibit 37 (11/17/2022 E-mail
28 Correspondence).

Page 5 of 22
HB 00257
1 III. ARGUMENT

2 A. The Images Did Not Confer An Unwarranted Privilege, Preference Or Advantage To


Governor Lombardo Under NRS 281A.400(2).
3

4 NRS 281A.400(2) provides that “[a] public officer or employee shall not use the public

5 officer’s or employee’s position in government to secure or grant unwarranted privileges,


6 preferences, exemptions or advantages for the public officer or employee, any business entity in
7
which the public officer or employee has a significant pecuniary interest or any person to whom the
8
public officer or employee has a commitment in a private capacity.” NRS 281A.400(2) further
9
defines the term “unwarranted” as “without justification or adequate reason.”
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10

11 The Commission has repeatedly held that an act confers an “unwarranted” advantage or
Phone: 702.382.5222 • Fax: 702.382.0540

12 preference if it violates state or local law. See, e.g., In re Kirkland, Comm’n Op. No. 98-41, at *3
www.campbellandwilliams.com

13 (1998) (“Kirkland”) (finding Sheriff’s use of uniform and badge in political endorsement did not
14 confer an “unwarranted” advantage or preference because it did not violate Nevada or Washoe
15
County law); In re Pitts, Comm’n Op. No. 14-71C, at *6-7 (2016) (“Pitts”) (dismissing alleged
16
violation of NRS 281A.400(2) due to absence of “State or local law clarifying duties of elected
17
incumbents regarding utilization of the accoutrements of office”); In re Antinoro, Comm’n Op. Nos.
18

19 18-031C and 18-052C, at *5 (2019) (“Antinoro”) (“A preference or advantage is unwarranted, in

20 part, if the public officer’s conduct was contrary to any applicable code or policy.”).

21 Here, it is undisputed that neither Nevada law nor Clark County Code prohibited Governor
22
Lombardo from utilizing his uniform and Sheriff’s badge in his gubernatorial campaign. See Pitts
23
at *6-7 (“The issue of whether an elected, incumbent sheriff may campaign in uniform [ ] has not
24
been addressed by Nevada’s courts or Legislature.”); CLARK COUNTY, NV., CODE ch. 2.42.
25
Similarly, LVMPD’s Political Activities Policy provides that department employees may appear in
26

27 uniform for their own campaign photographs since it “does not constitute an endorsement.”

28 Statement of Undisputed Facts (“UDF”) ¶ 5. Thus, Governor’s Lombardo’s use of his uniform and

Page 6 of 22
HB 00258
1 badge in the Images did not confer an unwarranted advantage or preference because it did not violate

2 any applicable law, code or policy.8 The Commission should dismiss the alleged violations of NRS
3
281A.400(2).
4
B. The Commission Should Dismiss The Alleged Violations Of NRS 281A.400(7) Or, At A
5 Minimum, Find That Any Violations Were Not Willful.
6 1. Legal Standard.
7
NRS 281A.400(7) prohibits a public officer from using governmental time, property,
8
equipment or other facility to benefit his significant personal or pecuniary interest, or any person to
9
whom he has a commitment in a private capacity. “Limited use” of government resources is
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10

11 permitted, however, if (i) the public officer or employee who is responsible for and has authority to
Phone: 702.382.5222 • Fax: 702.382.0540

12 authorize the use of such property, equipment, or other facility has established a policy allowing the
www.campbellandwilliams.com

13 use or the use is necessary as a result of emergency circumstances; (ii) the use does not interfere with
14 the public officer’s performance of public duties, (iii) the use has a nominal cost, and (iv) the use
15
does not create an appearance of impropriety. See NRS 281A.400(7)(a).
16
Thus, the Commission must analyze the alleged violations based on the unique facts and
17
circumstances at issue to determine whether Governor Lombardo’s use of his Sheriff’s uniform and
18

19 badge in the Images falls under the “limited use” exception of NRS 281A.400(7).9 See NRS

20 281A.710(1) (the Commission must “interpret[] the statutory ethical standard and appl[y] those

21

22

23 8
While Governor Lombardo seriously questions the rationale and effect of the October 7, 2019 Letter
from the Executive Director of the Commission to the Nevada Sheriffs’ and Chiefs’ Association
24 (“Sheriffs’ Letter”), see infra at Point III.B.2, it is undisputed that the Sheriffs’ Letter did not advise
25 that the use of the uniform and badge conferred an unwarranted advantage or preference under NRS
281A.400(2).
26
9
The “appearance of impropriety” element is determinative in this matter as the parties do not dispute
27 that Governor Lombardo’s use of his uniform and badge did not (i) violate LVMPD policy or any
other applicable law or code; (ii) interfere with his performance of public duties; or (iii) incur more
28 than a nominal cost. See Statement of UDF ¶ 12.

Page 7 of 22
HB 00259
1 standards to a given set of facts and circumstances regarding the propriety of the conduct of a public

2 officer”). This particularized analysis is especially important where, as here, Governor Lombardo’s
3
alleged violations of NRS 281A.400(7) involve a matter of first impression for the Commission.
4
Indeed, although the Commission has previously addressed the appearance of impropriety (or lack
5
thereof) of an incumbent sheriff using the accoutrements of the office while endorsing another
6
candidate or campaigning for re-election to the office of Sheriff, the Commission has never addressed
7

8 whether a sheriff may make limited use of his uniform, badge and/or other accoutrements of the

9 office when running for a separate partisan office such as Governor.


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10 Notwithstanding that the Commission’s prior opinions and stipulated agreements do not
11
address the exact issue presented here, Governor Lombardo will briefly detail them to demonstrate
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

the widely-varying results over the last 25 years. The Commission first addressed a sheriff’s use of
13
his uniform and badge in Kirkland. There, the Washoe County Sheriff wore his uniform and badge
14

15 in a televised advertisement in which he endorsed a judicial candidate, which the Commission found

16 could lead voters to believe Washoe County or the Washoe County Sheriff’s Office endorsed the

17 judicial candidate in question. Id. at *4. The Commission further reasoned that this type of
18 endorsement might imply that the judicial candidate in question would better enforce the criminal
19
law or that the public would be less protected if the other candidate were elected. Id. As a result,
20
the Commission determined that the Washoe County Sheriff’s use of the physical accoutrements of
21
his office to bolster his endorsement of the judicial candidate created an appearance of impropriety
22

23 under NRS 281A.400(7). Id.

24 This issue next arose in In re Kuzanek, Comm’n Op. No. 14-61C (2014) (“Kuzanek”) where

25 the Commission addressed the Washoe County undersheriff’s use of his uniform/badge at events and
26
in photographs on the Internet and social media related to his campaign for Washoe County Sheriff.
27
Id. at *3. After entering into a stipulated agreement, the Commission found that the undersheriff’s
28

Page 8 of 22
HB 00260
1 use of his uniform and badge resulted in a visual endorsement, affirmation, and sanction of his

2 campaign by the Washoe County Sheriff’s office that created an appearance of impropriety under
3
NRS 281A.400(7). Id. at *6-7. More specifically, the Commission found that allowing one candidate
4
for Sheriff to cloak himself in the office by using his uniform and badge would confer an “unfair
5
advantage” over his opponent. Id. Nevertheless, the Commission determined that Kuzanek’s
6
violation was not “willful” and declined to impose a civil penalty. Id. at *7.
7

8 Then, the Commission in Pitts considered alleged violations of NRS 281A.400(7) by an

9 incumbent sheriff seeking re-election who appeared in uniform and badge on his campaign website
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 and social media. Id. at *4. Recognizing that the issue was one of first impression, the Commission
11
dismissed the alleged violations of NRS 281A.400(7) because no state or local law governed or
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

clarified the duties of elected incumbent sheriffs with respect to the use of the physical accoutrements
13
of office during a re-election campaign. Id. at *7.
14

15 Notwithstanding that neither state nor local law had changed in the 3 years since the Pitts

16 decision, the Commission in Antinoro reversed course and held that “[a]n elected sheriff’s use of his

17 official uniform, badge and ‘other physical accoutrements’ of the public office in the course of
18 supporting his own campaign for re-election [ ] creates an appearance of impropriety and violates
19
NRS 281A.400(7).” Id. at *6. Nevertheless, the Commission then contradicted itself by finding that
20
Antinoro had not violated NRS 281A.400(7) by wearing his uniform and badge in campaign
21
photographs and debates. Id. at *7. The parties did, however, agree that the Executive Director
22

23 would send the Sheriffs’ Letter and provide “information and guidance about the Commission’s

24 position that the use of uniforms, badges and other physical accoutrements of office by elected

25 sheriffs during their campaigns for re-election creates an appearance of impropriety and violates NRS
26
281A.400(7).” Id. at *8.
27
Contrary to the Commission’s limited directive in Antinoro that the Executive Director
28

Page 9 of 22
HB 00261
1 should address an elected sheriff’s use of physical accoutrements in a campaign for re-election, the

2 Executive Director instead issued a blanket determination that the Commission “has now definitively
3
concluded that no state or local government law enforcement official, including an elected incumbent
4
official, may wear his/her uniform, badge or other physical accouterment of office, and may not use
5
official letterhead or government email, in support or opposition of a political campaign, including
6
his/her own campaign or as an endorsement. Such use constitutes a violation of NRS 281A.400(7).”
7

8 See Sheriffs’ Letter at *1-2. Put another way, by finding a sheriff’s use of a uniform or badge in

9 connection with any political campaign always creates an appearance of impropriety under any set
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10 of facts, the Executive Director effectively decreed an administrative prohibition that writes out the
11
statutory “limited use” exception previously codified by the Nevada legislature.
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

With that background, we now turn to the reasons why the Commission should dismiss the
13
alleged violations of NRS 281A.400(7) against Governor Lombardo.
14

15 2. The “Appearance Of Impropriety” Is Vague, Arbitrary And Unconstitutional.

16 “The void-for-vagueness doctrine is rooted in the Due Process Clauses of the Fifth and

17 Fourteenth Amendments.” Carrigan v. Comm’n on Ethics of State, 129 Nev. 894, 899, 313 P.3d
18 880, 884 (2013). “A law may be struck down as impermissibly vague for either of two independent
19
reasons: (1) if it fails to provide a person of ordinary intelligence fair notice of what is prohibited; or
20
(2) if it so standardless that it authorizes or encourages seriously discriminatory enforcement.” Id.
21
(quoting Holder v. Humanitarian Law Project, 561 U.S. 1, 18 (2010)). “The degree of vagueness
22

23 that the Constitution tolerates—as well as the relative importance of fair notice and fair

24 enforcement—depends in part on the nature of the enactment.” Id. (quoting Vill. Of Hoffman Estates

25 v. Flipside, Hoffman Estates, Inc., 455 U.S. 489, 498 (1982)). “Civil laws are held to a less strict
26
vagueness standard than criminal laws because the consequences of imprecision are qualitatively
27
less severe.” Id. Nevertheless, “[s]ince the Ethics in Government Law carries serious sanctions for
28

Page 10 of 22
HB 00262
1 disobedience, its terms must be sufficiently explicit to inform those who are subject to it what

2 conduct will render them liable to its penalties.” Dunphy v. Sheehan, 92 Nev. 259, 262, 549 P.2d
3
332, 334 (1976) (holding that financial disclosure provisions in Ethics in Government Law are
4
unconstitutionally vague).
5
Here, Governor Lombardo submits that the “appearance of impropriety” standard of the
6
“limited use” exception in NRS 281A.400(7) is wholly subjective and unconstitutionally vague such
7

8 that it authorizes or encourages seriously discriminatory enforcement.10 Indeed, unlike the term

9 “unwarranted” in NRS 281A.400(2), the term “appearance of impropriety” is not defined in NRS
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 281A.400(7) or any other provision of the Ethics in Government Law. This lack of clarity and
11
direction is particularly glaring given that the Nevada Supreme Court has repeatedly described the
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12
www.campbellandwilliams.com

“appearance of impropriety” standard as “ambiguous.” See Liapis v. Second Judicial Dist. Court,
13
128 Nev. 414, 418-19, 282 P.3d 733, 736 (2012) (discussing the abandonment of the “appearance of
14

15 impropriety” standard in the Rules of Professional Conduct governing lawyers); State v. Eighth

16 Judicial Dist. Court, 130 Nev. 158, 164, 321 P.3d 882, 886 (2014) (“Using a standard that is as

17 ambiguous as the appearance-of-impropriety standard could result in many unnecessary


18 disqualifications, limit mobility from private practice, and restrict the assignment of counsel when
19
no breach of confidences has occurred.”).
20
Other courts have also criticized the “appearance of impropriety” standard as hopelessly
21
arbitrary, subjective and vague. See, e.g., Marcum v. Scorsone, 457 S.W.3d 710, 717-18 (Ky. 2015)
22

23 (describing “appearance of impropriety” standard as “vague,” “possibly deceiving,” and “question-

24 begging”); Essex Equity Holdings USA, LLC v. Lehman Bros., Inc., 909N.Y.S.2d 285, 294 (N.Y.

25 Sup. Ct. 2010) (“[T]here is a general recognition that ‘appearance of impropriety,’ without more, is
26

27
10
Governor Lombardo is not mounting a facial challenge to NRS 281A.400(7) under the first prong
28 of the vagueness doctrine as described by the Nevada Supreme Court in Carrigan.

Page 11 of 22
HB 00263
1 too vague a standard to justify disciplinary measures or disqualification.”); Spargo v. New York State

2 Comm’n on Judicial Conduct, 244 F.Supp.2d 72, 91 (N.D.N.Y. 2003) (voiding sections of Code of
3
Judicial Conduct for vagueness and describing “appearance of impropriety” standard as “arbitrary
4
and subjective”), rev’d on other grounds in 351 F.3d 65 (2d Cir. 2003); Spargo v. New York State
5
Comm’n on Judicial Conduct, 2003 WL 2002762, at *4 (N.D.N.Y. April 29, 2003) (collecting
6
judicial critiques of the “appearance of impropriety” standard, including that it is “beset by legal and
7

8 moral complexity” and, in the words of former United States Supreme Court Justice Arthur

9 Goldberg, “unbelievably ambiguous”).


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10 Nowhere is the lack of clarity and selective application of the “appearance of impropriety”
11
standard more apparent than this Commission’s decisional history concerning the “limited use”
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

exception as applied to a sheriff’s use of his uniform and badge in political campaigns. For example,
13
in Kuzanek, the Commission found that the undersheriff’s use of his uniform and badge in support
14

15 of his campaign for sheriff created an appearance of impropriety and violated NRS 281A.400(7).

16 The Commission, however, declined to find a willful violation and did not impose civil sanctions

17 against Kuzanek. Notwithstanding that Kuzanek was decided just two years earlier, the Commission
18 in Pitts determined that a sheriff’s use of his uniform and badge in his own re-election campaign did
19
not constitute a violation of NRS 281A.400(7) because Nevada’s courts and legislature had not
20
addressed the issue.
21
The Commission’s interpretation of “appearance of impropriety” standard changed yet again
22

23 just four years later in Antinoro. There, the Commission stated that an incumbent sheriff’s use of his

24 uniform and badge in support of his own re-election campaign created an appearance of impropriety

25 and violated NRS 281A.400(7). But just two paragraphs later in the same order, the Commission
26
found that Antinoro’s use of his uniform and badge in campaign debates and photographs only
27
“implicated” NRS 281A.400(7) and did not rise to the level of an actual violation. The Commission,
28

Page 12 of 22
HB 00264
1 thus, opined in one breath that Antinoro’s conduct would violate NRS 281A.400(7) and, in the very

2 next breath, declined to find that his conduct did, in fact, violate the statute. In short, the
3
Commission’s interpretation and application of the “appearance of impropriety” standard to the use
4
of a sheriff’s uniform and badge for campaign purposes has changed with each consecutive decision
5
from Kirkland to Antinoro.
6
And, to be clear, the Commission’s inconsistent application of the vague “appearance of
7

8 impropriety” standard in NRS 281A.400(7) was not remedied by the non-binding Sheriffs’ Letter

9 because the Executive Director plainly expanded on the Commission’s directive in Antinoro.11
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10 Indeed, the Commission in Antinoro stipulated that the Executive Director would send a letter to the
11
Nevada Sheriffs’ and Chiefs’ Association advising “that the use of uniforms, badges and other
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

physical accoutrements of office by elected sheriffs during their campaign for re-election creates an
13
appearance of impropriety and violates NRS 281A.400(7).” Id. (emphasis added). The Sheriffs’
14

15 Letter, however, enlarged the Commission’s directive in Antinoro by barring sheriffs from wearing

16 their uniforms and badges “to support or oppose any political campaign,” including a sheriff’s

17 campaign for a different partisan office such as Governor.


18 Simply put, the Commission’s interpretation of the “appearance of impropriety” standard has
19
morphed from holding in Pitts that a sheriff’s use of his uniform and badge in a re-election campaign
20
did not violate NRS 281A.400(7) to instructing in the Sheriffs’ Letter that the statute effectuates a
21
wholesale prohibition in any political campaign. The Commission’s erratic application of this
22

23 subjective standard is only exacerbated by the fact that Nevada law (or, in reality, the lack thereof)

24 governing the use of sheriffs’ uniforms and badges in partisan political campaigns did not change in

25

26

27 11
Governor Lombardo disputes that the Sheriffs’ Letter has any binding legal effect on him or other
law enforcement officers in the State. See Dunphy, 92 Nev. at 264, 549 P.2d at 336 (observing that
28 an advisory opinion from the Commission “carries no binding force”).

Page 13 of 22
HB 00265
1 the 5 years between the Pitts and Antinoro decisions.

2 Suffice it to say, the Commission’s inability to consistently interpret the “appearance of


3
impropriety” standard confirms that NRS 281A.400(7) is void for vagueness as applied to the limited
4
use of sheriffs’ uniforms and badges in political campaigns. See Carrigan, 129 Nev. at 904, 313
5
P.3d at 887 (finding conflict-of-interest recusal provision in Ethics in Government law was not
6
unconstitutionally vague on an as-applied basis where the Commission “evenhandedly” sanctioned
7

8 similarly situated persons); In re Discipline of Schaefer, 117 Nev. 496, 512, 25 P.3d 191, 202 (2001)

9 (“We conclude that the non-binding nature of Formal Opinion 8, together with the existence of
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 conflicting authority from other jurisdictions, renders SCR 182 vague as applied to Schaefer[.]”);
11
Jones v. Schneiderman, 974 F.Supp.2d 322, 340-41 (S.D.N.Y. 2013) (finding State’s “erratic history
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

of enforcement” of mixed martial arts ban supported as-applied vagueness challenge to statute
13
because “[c]ourts routinely consider such evidence in adjudicating vagueness claims”) (listing
14

15 supporting cases).12

16 3. If The Commission Finds NRS 281A.400(7) Constitutional, Then It Should Deem


Governor Lombardo’s Alleged Violations Not Willful.
17
In determining whether Governor Lombardo’s alleged violations of NRS 281A.400(7) were
18

19 willful such that they warrant the imposition of civil penalties, the Commission must consider the

20

21
12
22 In In re Public Officer, Advisory Op. No. 19-124A (2019), the Commission cited Comm’n of
Ethics v. Carrigan, 564 U.S. 117 (2011) and Carrigan v. Comm’n on Ethics of State, 129 Nev. 894,
23 899, 313 P.3d 880, 884 (2013) for the proposition that “courts have determined that the phrase
‘appearance of impropriety’ is not vague and is constitutional.” This is a gross mischaracterization
24 of the Carrigan decisions. Neither the United States Supreme Court nor the Nevada Supreme Court
25 considered a vagueness challenge or addressed the constitutionality of the “appearance of
impropriety” standard. Id. To the contrary, the Commission’s citation of the Carrigan decisions to
26 buttress the constitutionality of the “appearance of impropriety” standard is the exact type of cursory
and inaccurate legal analysis that the court vociferously criticized in Spargo, 2003 WL 2002762, at
27 *3-4 (rejecting New York state court’s constitutional analysis of “appearance of impropriety”
standard where it relied on legal authority where “[n]o constitutional question is raised in any of the
28 cases cited”).

Page 14 of 22
HB 00266
1 following non-inclusive factors:

2 1) The seriousness of the violation or alleged violation, including, without limitation, the
nature, circumstances, extent and gravity of the violation or alleged violation;
3

4 2) The number and history of previous warnings, letters of caution or instruction, deferral
agreements or violations or alleged violations of the provisions of this chapter relating to
5 the public officer or employee;
6 3) The cost to conduct the investigation and any meetings, hearings or other proceedings
7 relating to the violation or alleged violation;

8 4) Any mitigating factors, including, without limitation, any self-reporting prompt


correction of the violation or alleged violation, any attempts to rectify the violation or
9 alleged violation before any ethics complaint is filed and any cooperation by the public
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

officer or employee in resolving the ethics complaint;


10

11 5) Any restitution or reimbursement paid to parties affected by the violation or alleged


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violation;
12
www.campbellandwilliams.com

6) The extent of any financial gain resulting from the violation or alleged violation; and
13

14 7) Any other matter justice may require.

15 NRS 281A.775(1).
16 Importantly, the Commission is required to “treat comparable situations in a comparable
17
manner and shall ensure that the disposition of the matter bears a reasonable relationship to the
18
determination of the severity of the violation or alleged violation.” NRS 281A.775(3). This is
19
critical given that the Executive Director is seeking to impose almost $2 million in fines even though
20

21 the Commission has never deemed a sheriff’s use of his uniform and badge in a political campaign

22 to be a willful violation of NRS 281A.400(7) or imposed civil penalties under NRS 281A.785. In

23 that regard, the Commission has frequently declined to find a willful violation in similar cases based
24
on the following factors: (i) the sheriff has no prior violations of the Ethics in Government law; (ii)
25
no financial gain; (iii) cooperation with the Commission’s investigation and analysis; (iv) similar
26
campaign techniques employed by other law enforcement officers; and (v) conflicts in the law and
27
prior decisions by the Commission. See, e.g., Pitts; Kuzanek; Antinoro. With that in mind, Governor
28

Page 15 of 22
HB 00267
1 Lombardo will analyze the relevant factors under NRS 281A.775(1) below.

2 The Seriousness of the Violation


3
Respectfully, Governor Lombardo submits that the alleged violations of NRS 281A.400(7)
4
are relatively inconsequential, particularly when the Executive Director is seeking approximately
5
$790,000 in fines as well as the commencement of impeachment proceedings. The sole conduct at
6
issue in this proceeding is the posting of the Images to Governor Lombardo’s campaign website and
7

8 social media pages, which are plainly affiliated with his gubernatorial campaign and not LVMPD.

9 There is no allegation that Governor Lombardo—unlike other sheriffs whose violations were deemed
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 non-willful—appeared at campaign events or debates wearing his uniform or badge or sought to


11
imply that he had received LVMPD’s endorsement. There is likewise no harm from the Images as
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

the media frequently published articles related to Governor Lombardo’s campaign with photographs
13
of him in his uniform and badge.
14

15 In short, the Images only confirm what the voting public already knew, which is that

16 Governor Lombardo served as the Sheriff of Clark County. To that end, other non-uniformed public

17 officials (including his opponent in the race for Governor) have routinely utilized their public titles
18 and accoutrements of office (or former offices) without reproach. For example, Governor Sisolak
19
regularly made appearances in support of his campaign for re-election while donning his Governor’s
20
pin.13 Similarly, Las Vegas Councilwoman Michele Fiore has posted campaign materials depicting
21
her on the legislature floor and in her City Council seat.14 Clark County District Attorney Steve
22

23 Wolfson has also posted photographs to social media pages for his campaign that were taken in

24

25

26
13
See Exhibit 38 (Photographs)
27
14
Id.
28

Page 16 of 22
HB 00268
1 courtrooms from the Eighth Judicial District Court.15 The list of Nevada politicians who have

2 engaged in similar conduct during political campaigns goes on.


3
To be clear, Governor Lombardo does not contend that these candidates violated the Ethics
4
in Government law; rather, he submits that these examples merely represent the types of “limited
5
use” contemplated by the Legislature when it enacted NRS 281A.400(7). The only difference
6
between Governor Lombardo and these candidates is that his elected position required a uniform and
7

8 badge whereas all other elected positions do not. This factor weighs against a finding of willfulness.

9 History of Prior Violations, Letters of Caution or Warnings


710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 In more than 25 years as a public servant, Governor Lombardo had never been accused of
11
violating the Ethics in Government law before the instant complaint was filed. To the extent the
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

Executive Director contends that the Sheriffs’ Letter constituted a prior warning to Governor
13
Lombardo, the Commission’s decisional history and analysis of the “appearance of impropriety”
14

15 standard as applied to this issue is hardly a model of clarity. This is especially true because Governor

16 Lombardo’s conduct at issue here does not run afoul of the parameters of the stipulated agreement

17 in Antinoro, which was the premise for the Sheriffs’ letter. The Commission should not find that this
18 factor weighs against Governor Lombardo considering it has yet to interpret the “limited use”
19
exception in the same manner on consecutive occasions when addressing a sheriff’s use of his
20
uniform and badge.
21
The Cost Related to the Violation
22

23 The cost incurred as a result of the alleged violations by Governor Lombardo is negligible.

24 As the Commission is aware, Governor Lombardo proposed that this matter be resolved through

25 briefing and oral argument rather than forcing the Commission to participate in a time-consuming
26

27

28 15
Id.

Page 17 of 22
HB 00269
1 investigative proceeding with costly discovery. In short, this contested complaint has been resolved

2 in the most expedient manner possible which weighs against a willful violation.
3
Mitigating Factors
4
Governor Lombardo was not given the opportunity to mitigate the alleged violations prior to
5
the filing of the complaint as the Executive Director made no such request before commencing this
6
action. Since the filing of the complaint, Governor Lombardo and his counsel have cooperated with
7

8 the Commission, Executive Director and their respective counsel to the fullest extent, including by

9 stipulating to an agreed-upon set of facts and resolving this legal issue on the briefs and oral
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 argument. This factor likewise favors Governor Lombardo.


11
Restitution to Affected Parties and Financial Gain
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

Consistent with the absence of serious harm arising out of the use of the Images in Governor
13
Lombardo’s campaign, there are no affected parties to whom restitution or reimbursement is owed.
14

15 Similarly, Governor Lombardo did not obtain any financial gain arising out of the use of the Images.

16 These factors clearly negate the existence of a willful violation.

17 Other Factors
18 Pursuant to NRS 281A.775(3), Governor Lombardo submits that the Commission should also
19
consider certain factors applied in prior proceedings involving sheriffs and the use of uniforms and
20
badges in political campaigns. Specifically, there is a long history of sheriffs in this State wearing
21
their uniforms and badges in political campaigns with disparate results when the issue is brought
22

23 before the Commission. Additionally, this proceeding presents a matter of first impression as

24 Governor Lombardo did not run for re-election as Sheriff of Clark County or wear his uniform and

25 badge in support of another candidate. Rather, the Images were used in support of Governor
26
Lombardo’s campaign for a different statewide office which is a factual scenario that has yet to be
27
addressed by the Commission. And, lastly, Governor Lombardo strongly maintains his good-faith
28

Page 18 of 22
HB 00270
1 position that the “appearance of impropriety” standard in the limited use exception of NRS

2 281A.400(7) is unconstitutionally vague as applied to the facts of this case.


3
Based on the foregoing factors along with this body’s uneven decisional history on this issue,
4
the Commission should find that Governor Lombardo’s alleged violations of NRS 281A.400(7) are
5
not willful if it determines the statute is enforceable as applied to these circumstances.
6
C. The Civil Penalties Threatened By The Executive Director Are Grossly Excessive And
7
Unconstitutional.
8
The Eighth Amendment of the United States Constitution provides “[e]xcessive bail shall not
9
be required, nor excessive fines imposed, nor cruel and unusual punishment inflicted.” Id. (emphasis
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10

11 added). Article 1, Section 6 of the Nevada Constitution contains the same prohibition of excessive
Phone: 702.382.5222 • Fax: 702.382.0540

12 fines. The Nevada Supreme Court has applied the Excessive Fines Clauses in the United States and
www.campbellandwilliams.com

13 Nevada Constitutions to invalidate excessive civil penalties and/or forfeitures levied by state
14 regulatory bodies and agencies. See City of Las Vegas v. Nevada Indus., 105 Nev. 174, 178-79, 772
15
P.2d 1275, 1277-78 (1989); Levingston v. Washoe Co., 112 Nev. 479, 488, 916 P.2d 163, 169 (1996),
16
modified on rehearing, 114 Nev. 306, 956 P.2d 84 (1998).16
17
The term “fine” means “a payment to a sovereign as punishment for some offense.” United
18

19 States v. Bajakajian, 524 U.S. 321, 327-28 (1998) (citing Browning-Ferris Indus. of Vt., Inc. v. Kelco

20 Disposal, Inc., 492 U.S. 257, 265 (1989)). The Excessive Fines Clause “limits the government’s

21 power to extract payments, whether in cash or in kind, as punishment for some offense.” Austin v.
22
United States, 509 U.S. 602, 609-10 (1993). “The touchstone of the constitutional inquiry under the
23

24

25 16
The Excessive Fines Clause in the United States Constitution is not limited to criminal forfeitures
26 and applies to civil proceedings where monetary penalties are imposed. See, e.g., Hudson v. United
States, 522 U.S. 93, 103 (1997) (“The Eighth Amendment protects against excessive civil fines…”);
27 United States v. $100,438.00 in U.S. Currency, 354 F.3d 1110 (9th Cir. 2004) (same); United States
v. Mackby, 261 F.3d 821 (9th Cir. 2001) (applying Excessive Fines Clause to civil sanctions imposed
28 under the False Claims Act).

Page 19 of 22
HB 00271
1 Excessive Fines Clause is the principle of proportionality: [t]he amount of the forfeiture must bear

2 some relationship to the gravity of the offense that it is designed to punish.” Bajakajian, 524 U.S. at
3
334. Although this is not the case here, the Excessive Fines Clause applies even when there is “a
4
permitted statutory basis for the penalty [as] it will not always be constitutional as applied.” Id. at
5
338-39.
6
Beginning with the latter point, the plain language of NRS 281A.790(1) does not permit the
7

8 Commission to impose serial or aggregated fines for each alleged violation of NRS 281A.400(7) by

9 Governor Lombardo. Platte River Ins. Co. v. Jackson, 137 Nev. Adv. Op. 82, 500 P.3d 1257, 1259
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 (2021) (“In interpreting a statute, we begin with its plain language.”). Assuming arguendo that each
11
post of the Images constitutes a “separate act or event” under NRS 281A.790(1)(b)-(c)—which is
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

highly questionable at best—the fact remains that the statute only allows the Commission to impose
13
civil penalties not to exceed $5,000 for the “first willful violation,” $10,000 for the “second willful
14

15 violation,” and $25,000 for the “third willful violation.” Put another way, if the Commission finds

16 that Governor Lombardo committed three willful violations of NRS 281A.400(7) then it has the

17 discretion to impose fines in the aggregate amount of $40,000. That is it.


18 Indeed, contrary to the Executive Director’s flawed interpretation, NRS 281A.790(1) does
19
not contain any language that would permit the Commission to impose civil penalties beyond the
20
“third willful violation.” For example, the legislature could have easily drafted NRS 281A.790(1)
21
to allow civil penalties for “each” willful violation of the statutory scheme. Similarly, the legislature
22

23 could have crafted NRS 281A.790(1)(c) to provide that the Commission may impose a fine of

24 $25,000 for the “third and each subsequent willful violation.” But the legislature did not employ

25 language in NRS 281A.790(1) that would permit the Commission to impose civil penalties for each
26
subsequent willful violation beyond the third.
27
That omission is presumed to be intentional under Nevada law. Moore v. State, 117 Nev.
28

Page 20 of 22
HB 00272
1 659, 661, 27 P.3d 447, 449 (2001) (“In construing a statute, our primary goal is to ascertain the

2 legislature’s intent in enacting it, and we presume that the statute’s language reflects the legislature’s
3
intent.”). This is especially true where NRS 281A.790(4)(c)(2)—a different section in the same
4
statutory scheme—expressly contemplated that a public officer may commit “three or more willful
5
violations” when addressing removal proceedings for public officers. See Williams v. State Dep’t of
6
Corr., 133 Nev. 594, 598-99, 402 P.3d 1260, 1264 (2017) (courts “must presume that the variation
7

8 in language indicates a variation in meaning” when interpreting statutes to ascertain legislative

9 intent) (listing cases).


710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 Even if NRS 281A.790(1) granted the Commission the ability to impose civil penalties on
11
Governor Lombardo in excess of $40,000—and it does not—the fines sought by the Executive
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

Director clearly violate the Excessive Fines Clauses in the United States and Nevada Constitutions.
13
To be sure, the Executive Director is seeking to impose civil penalties on Governor Lombardo in the
14

15 approximate amount of $790,000 because the Images were posted to his campaign website and social

16 media accounts on 33 occasions—a purported violation that is not a crime, did not cause any financial

17 harm to the public, or create any identifiable advantage for Governor Lombardo in the gubernatorial
18 race. Suffice it to say, the Executive Director’s threat to seek several hundreds of thousands of
19
dollars based on a handful of photographs on Governor Lombardo’s campaign website and social
20
media accounts is grossly disproportionate to the gravity of the alleged offense and blatantly
21
unconstitutional.
22

23 D. The Executive Director’s Threat Of Impeachment Is Patently Absurd.

24 In addition to pursuing an eye-watering amount of civil penalties for the purported violations,

25 the Executive Director unequivocally threatened Governor Lombardo with impeachment


26
proceedings before the legislature pursuant to NRS 281A.790(4)(b). That subsection of the statute,
27
however, only applies when the Commission has found “[o]ne of more violations of this chapter
28

Page 21 of 22
HB 00273
1 have been committed by a state officer removable from office only through impeachment.” Id.

2 (emphasis added). Here, Governor Lombardo committed the alleged violations while he was a public
3
officer—i.e. the Sheriff of Clark County—and subject to judicial removal proceedings under NRS
4
281A.790(4)(c). Id. (if the Commission finds “one or more violations have been committed by a
5
public officer other than a public officer described in paragraphs (a) and (b)” then the appropriate
6
remedy is commencing a proceeding for judicial removal).
7

8 In short, the Executive Director cannot take alleged violations committed by Governor

9 Lombardo in his capacity as Sheriff of Clark County—a position subject to judicial removal under
710 SOUTH SEVENTH STREET, SUITE A, LAS VEGAS, NEVADA 89101

10 subsection (c)—and use them to seek his impeachment under subsection (b). These provisions
11
expressly provide separate mechanisms for the removal of a public officer from the office in which
Phone: 702.382.5222 • Fax: 702.382.0540

12
www.campbellandwilliams.com

he or she “committed” the alleged violations. The Executive Director cannot blend the statute to
13
obtain his desired result. Regardless, the issue of removal from office is moot because Governor
14

15 Lombardo no longer serves as the Sheriff of Clark County.

16 IV. CONCLUSION

17 Based on the foregoing, Mr. Lombardo respectfully requests that the Commission grant
18 summary judgment in his favor and dismiss the Complaint. In the alternative, Governor Lombardo
19
respectfully requests that the Commission deem the alleged violations not willful and decline to enter
20
the excessive and unlawful penalties sought by the Executive Director.
21
DATED this 22nd day of March, 2023.
22

23 CAMPBELL & WILLIAMS

24 By /s/ Philip R. Erwin


J. COLBY WILLIAMS, ESQ. (5549)
25 PHILIP R. ERWIN, ESQ. (11563)
SAMUEL R. MIRKOVICH, ESQ. (11662)
26
710 South Seventh Street, Suite A
27 Las Vegas, Nevada 89101

28 Attorneys for Governor Joseph Lombardo

Page 22 of 22
HB 00274
EXHIBIT 36
Assorted Articles

HB 00275
HB 00276
HB 00277
HB 00278
HB 00279
HB 00280
HB 00281
HB 00282
HB 00283
HB 00284
HB 00285
HB 00286
HB 00287
EXHIBIT 37
E-Mail Correspondence

HB 00288
Tuesday, March 21, 2023 at 10:04:09 Pacific Daylight Time

Subject: Ethics Case Nos. 21-062, 21-082, 22-107C (Lombardo)- FOR SETTLEMENT PURPOSES ONLY
Date: Thursday, November 17, 2022 at 8:58:37 AM Pacific Standard Time
From: Elizabeth BasseR
To: Sam Mirkovich
CC: Ross Armstrong
AEachments: image001.jpg

Hi Sam-

Considering the upcoming deadlines and scheduled hearings in Case Nos. 21-062C and 21-082C, before
either party needs to put significant work into Case No, 22-107C, and before your client is sworn into his new
posiEon and our statutes require that addiEonal acEons be taken, the ExecuEve Director and I wanted to
make a global seLlement offer to seLle all three of your client’s currently pending ethics maLers. The
ExecuEve Director offers to seLle all three of these maLers for the following terms:

Sheriff Lombardo would sEpulate to three willful violaEons of the Ethics Law: 2 willful violaEons for
violaEons as idenEfied in Case Nos. 21-062C and 21-082C and 1 willful violaEon for violaEons as
idenEfied in Case No. 22-107C
A total fine of $50,000
Censure from the Commission
Ethics training for all staff within 30 days of your client’s inauguraEon as Governor
A designated ethics officer in his office for his first term as Governor (this would be a member of his
team with this designaEon, not an enEre separate posiEon)

There are a number of reasons that we believe this is an extremely fair offer to resolve all three of these
cases. We reasonably believe that we can prove and obtain at least 80 willful violaEons against Sheriff
Lombardo in these three maLers. Pursuant to NRS 281A.790(1), the total potenEal civil penalEes that could
be imposed for 80 willful violaEons would be $1,965,000. A fine of $50,000 is therefore a very reasonable
offer.

AddiEonally, NRS 281A.7904(c) currently applies to Sheriff Lombardo as a public officer prior to his taking
office as Governor. Once he is sworn in as Governor, he becomes a state officer to whom (b) of that statute
applies. Under (c), the Commission “[s]hall file a complaint in the appropriate court for removal of the public
officer pursuant to NRS 283.440 when the public officer is found . . . to have commiLed three or more willful
violaEons of this chapter.” However, if we were able to enter into a sEpulaEon at our December meeEng
while he is sEll Sheriff, since Sheriff Lombardo would no longer be subject to (c) by early January, we believe
the issue of filing such a complaint would be moot and would not pursue that issue.

Please let me know if you have any quesEons or would like to discuss the offer or anything else in this email
further. I know that I am asking for a quick turn-around at a very busy Eme, but to be able to have a
proposed sEpulated agreement before the Commission for their review and approval before your client’s
inauguraEon, we would need to have a drag prepared by roughly the end of this month.

Thank you,
Liz

Elizabeth J. Bassett, Esq.


Associate Counsel

Page 1 of 2
HB 00289
Nevada Commission on Ethics

704 West Nye Lane, Suite 204


Carson City, NV 89703
(775) 687-5469, ext. 229
Fax: (775) 687-1279
ethics.nv.gov

CONFIDENTIALITY : The contents of this message and any attachments hereto may be subject to
the confidentiality provisions contained in NRS Chapter 281A and should not be disclosed to other
parties, distributed, or copied in any way.

Page 2 of 2
HB 00290
EXHIBIT 38
Photographs

HB 00291
HB 00292
HB 00293
HB 00294
HB 00295
HB 00296
HB 00297
HB 00298
HB 00299
HB 00300
HB 00301
HB 00302
1 Elizabeth J. Bassett, Esq. (NV Bar No. 9013)
Associate Counsel
2
Nevada Commission on Ethics
3 704 West Nye Lane, Suite 204
Carson City, Nevada 89703
4 (775) 687-5469
Email: ebassett@ethics.nv.gov
5

6 Attorney for Ross E. Armstrong, Esq., Executive Director


Nevada Commission on Ethics
7
STATE OF NEVADA
8

9 BEFORE THE COMMISSION ON ETHICS


10

11
In re Joseph M. Lombardo,
Sheriff of Clark County, Consolidated Ethics Complaint
12 State of Nevada, Case Nos. 21-062C, 21-082C
13 Subject /
14

15 EXECUTIVE DIRECTOR’S OPPOSITION TO


SUBJECT’S MOTION FOR SUMMARY JUDGMENT
16

17 Ross E. Armstrong, Esq., Executive Director of the Nevada Commission on

18 Ethics (“Commission”), through the Commission’s Associate Counsel, Elizabeth J.

19 Bassett, Esq., submits this Opposition to Subject Jospeh M. Lombardo’s (“Subject or

20 “Lombardo””) Motion for Summary Judgment (“Motion”).

21 ARGUMENT

22 I. INTRODUCTION

23 A. Subject Misrepresents the Contents of the Executive Director’s Protected,


Private Settlement Negotiations
24
In his “Procedural History” section, Subject refers to and attaches
25
correspondence from Executive Director’s counsel to Subject’s counsel, alleging the
26
correspondence contains “threats” regarding the Ethics Law violations alleged in these
27
matters. What Subject fails to disclose, however, is that the referenced
28

Page 1 of 13

HB 00303
1 correspondence was a private, protected settlement communication, as is clearly
2 indicated in the subject line of the attached email.
3 As is customary in settlement negotiations, the Executive Director’s counsel
4 provided Subject’s counsel with information regarding what violations and penalties
5 the Executive Director reasonably believed he could obtain against Subject and then
6 made a settlement offer to resolve these matters, along with a third matter. No threats
7 were made against Subject in the correspondence.
8 The Motion also misrepresents the contents of the correspondence, arguing
9 that the Executive Director’s counsel stated a belief “that the Commission can
10 somehow seek to commence impeachment proceedings against Governor
11 Lombardo”. This is the exact opposite of what was stated. In fact, the information
12 provided in the correspondence was that once he was sworn in as Governor, NRS
13 281A.790(4)(b) would apply to Lombardo and he could then only be impeached by
14 the Assembly, not the Commission.
15 What the correspondence brought to Subject’s attention is the requirement
16 within the Ethics Law that if the Commission finds a single willful violation against
17 Lombardo after he were sworn in as Governor, that it must provide that information to
18 the Speaker of the Assembly and the Majority Leader of the Senate. The Commission
19 would not have any discretion on this issue. What the Legislature does with the
20 information once received is then wholly within the Legislature’s constitutional powers,
21 which may include a variety of sanctions, up to and including impeachment. 1
22 Subject’s attempt to misrepresent the contents of a private, protected
23 settlement negotiation, which never should have been shared in the context of a
24 dispositive motion, must be disregarded.
25 ///
26

27 1 For example, former Comptroller Kathy Augustine was impeached, but not removed, by the
Legislature when she was found to have committed a willful violation of the Ethics Laws during her
28 reelection campaign.

Page 2 of 13

HB 00304
1 B. Legal Standard on Summary Judgment
2
To be entitled to summary judgment, the moving party must demonstrate both
3
the absence of genuinely contested material facts as well as a prima facie entitlement
4
to judgment as a matter of law based upon undisputed evidence that would be
5
admissible at trial. See Cuzze v. Univ. & Cmty. Coll. Sys. of Nev., 123 Nev. 598, 602-
6
03, 172 P.3d 131, 134 (2007) (moving party must make initial showing of both an
7
absence of genuinely disputed material facts as well as entitlement to judgment as a
8
matter of law before burden shifts to opposing party). "Summary judgment cannot be
9
granted unless and until all of these requirements are satisfied." See Nutton v. Sunset
10
Station, Inc., 357 P.3d 966, 131 Nev. Adv. Op. 34 (Nev. App., 2015).
11
II. LEGAL ANALYSIS
12
A. The Executive Director Has Shown He Is Entitled to Summary Judgment
13 on Both Claims Alleged Against Lombardo

14 In his Motion for Summary Judgment in this matter, the Executive Director has
15 shown that he is entitled to summary judgment as to all claims alleged against
16 Subject. As the Executive Director is entitled to summary judgment as to both NRS
17 281A.400(2) and (7), Subject’s Motion necessarily fails.

18 B. Subject’s Argument Regarding NRS 281A.400(2) is Based on a


Misstatement of the Ethics Law
19
Subject argues that for a violation of NRS 281A.400(2) there must be a
20
separate violation of state or local law. This is a misstatement of the Ethics Law.
21
NRS 281A.400(2) provides:
22
A public officer or employee shall not use the public officer’s or
23
employee’s position in government to secure or grant unwarranted
24 privileges, preferences, exemptions or advantages for the public officer or
employee. As used in this subsection, “unwarranted” means without
25 justification or adequate reason.
26
Nothing in the statute requires a separate violation of state or local law.
27

28

Page 3 of 13

HB 00305
1 In In re Public Officer, Comm’n Op No. 19-124A (2020), citing to the very same
2 cases Subject alleges support his position, the Commission “continued to caution” that
3 the use of any accouterments of office in a campaign or endorsement is unwarranted
4 and violates NRS 281A.400(2). The advisory opinion also states that local
5 government policies cannot violate or be materially different from State laws;
6 therefore, Clark County’s Codes and LVMPD’s Political Activities Policies do not
7 overrule the Ethics Law.
8 In In re Kirkland, Comm’n Op. No. 98-041 (1999), the Commission
reviewed whether an elected public officer’s use of an official title, uniform
9
and badge to provide a private political endorsement was unwarranted.
10 The Commission found that an elected public officer’s use of only a name
and title were not precluded by the Ethics Law. However, any use of an
11 official position including any accouterments of public office to bolster the
political endorsement was inappropriate because it creates the impression
12
of government sanction. A hard line was established to guide elected
13 public officers to assure compliance with the Ethics Law and opinion
precedent. “The power and prestige of the [public] office” may not be used
14 to bolster private political endorsements.” In re Antinoro, Comm’n Op. No.
15
18-031C/18-052C (2019), at p. 6, citing In re Kuzanek, Comm’n Op. No.
14-61C (2014).
16
The Commission continues to caution against any attempt, even an
17 incidental one, to bolster a political endorsement by the use of a public
18
office and associated accouterments or any governmental property,
equipment or resources. Such uses provide the impression that the
19 public officer is acting in an official capacity implicating NRS
281A.400(2). Likewise, the use of official authority to excuse a public
20 officer’s own compliance or to create or manipulate established policies in
21
order to secure private campaign advantages will be considered by the
Commission to determine whether there is compliance with NRS
22 281A.400, the Code of Ethical Standards. See In re Antinoro, Comm’n Op.
No. 16-54C (2017). It is a fundamental principle of law that established
23
local governmental policies may not be violative of or materially
24 inconsistent with State Law. See Clark County Social Serv. Dep't v.
Newkirk, 106 Nev. 177, 789 P.2d 227 (1990).
25
In re Public Officer, Comm’n Op. No.19-124A (2020), pgs. 5-6 (emphasis added).
26
The stipulated facts establish that Subject used the power and prestige of his
27
office through the use of uniform and badge to bolster his private interest. Subject
28

Page 4 of 13

HB 00306
1 therefore fails to meet the summary judgment standard as to the NRS 281A.400(2)
2 violations and his Motion must be denied.
3 C. Subject Does Not Meet the Standard for Summary Judgment as to the
Allegation Regarding NRS 281A.400(7)
4

5 a. Even if Subject Prevailed on His Argument Regarding the


Constitutionality of the Exception to NRS 281A.400(7), It Would Not
6 Relieve His Violations of The Ethics Law
7
The entirety of Subject’s argument in opposition to the Executive Director’s
8
allegation that he violated NRS 281A.400(7) is that the fourth prong of the exception
9
to that statute is unconstitutionally vague. Even if Subject were to prevail on this
10
argument, however, it would not result in the entirety of NRS 281A.400(7) being
11
deemed unconstitutional—only the exception contained in subsection 7(a) to that
12
statute would be unconstitutional.
13
NRS 0.020 provides:
14
1. If any provision of the Nevada Revised Statutes, or the
15 application thereof to any person, thing or circumstance is held
invalid, such invalidity shall not affect the provisions or application
16 of NRS which can be given effect without the invalid provision or
application, and to this end the provisions of NRS are declared to
17
be severable.
18
2. The inclusion of an express declaration of severability in the
19 enactment of any provision of NRS or the inclusion of any such
20
provision in NRS, does not enhance the severability of the provision
so treated or detract from the severability of any other provision of
21 NRS.
22 Therefore, even if Subject could show that the exception to NRS 281A.400(7) is
23
unconstitutional (which the Executive Director disputes 2) the only effect would be that
24

25
2
Subject argues that NRS 281A.400(7)(a)(4) is unconstitutionally vague because it encourages
26 “seriously discriminatory enforcement”. The Nevada Supreme Court considered, and rejected, a similar
argument in Carrigan v. Comm'n on Ethics of Nev., 129 Nev. 894, 904, 313 P.3d 880, 887 (2013)
27 finding “Analyzed on an as-applied basis, see United States v. Jones, 689 F.3d 696, 702 (7th Cir.
2012) ("Vagueness challenges are normally evaluated in light of the particular facts of the case, not in
28 general."), Carrigan's claim that NRS 281A.420(2)(c) and NRS 281A.420(8)(e) are so lacking in

Page 5 of 13

HB 00307
1 the invalid sections of the exception would be severed from the remainder of NRS
2 281A.400(7), which would still apply to Subject.
3 As shown in the Executive Director’s Motion for Summary Judgment, a violation
4 of NRS 281A.400(7) occurs when a public officer (1) uses governmental time,
5 property, equipment or other facility, (2) to benefit his significant personal or pecuniary
6 interest. NRS 281A.400(7).
7 Subject had a significant personal and financial interest in being elected
8 Governor of Nevada. See In re Public Officer, Comm’n Op. No.19-124A (2020), at p.
9 4; In re Antinoro, Comm’n Op. Nos. 18-031C/18-052C (2019); In re Matson, Comm’n
10 Op. No. 11-67C (2014). He used government property—his Sheriff uniform and
11 badge—in support of his efforts to be elected Governor. Subject therefore used
12 governmental property and equipment to benefit his significant personal or pecuniary
13 interest in being elected—a violation of NRS 281A.400(7).
14 Subject’s Motion therefore fails to meet the summary judgment standard.
15 b. The Commission’s Legal Precedent Regarding NRS 281A.400(7)
16
In addressing his violation of NRS 281A.400(7), Subject’s Motion cites to and
17
discusses some of the Commission’s previous cases involving campaigns and the use
18
of uniforms, badges and the accouterments of office, but fails to include all of the
19
relevant information necessary to understand the Commission’s findings in each case.
20
The following table summarizes all the Commission’s cases on this issue, notes any
21

22

23
standards as to authorize or encourage "'seriously discriminatory enforcement,'" Humanitarian Law
24 Project, 561 U.S. at 18, 130 S. Ct. at 2718 (quoting United States v. Williams, 553 U.S. 285, 304, 128
S. Ct. 1830, 170 L. Ed. 2d 650 (2008)), also fails. Nothing in the record suggests that the bipartisan
25 [Ethics] Commission harbored an improper motive or failed to sanction other similarly situated persons.
On the contrary, the Commission evenhandedly sanctioned another council member for his vote
26 against the Lazy 8 project because of an undisclosed business relationship with the Nugget, a
competing casino that opposed the Lazy 8. See In re Salerno, No. 08-05C (Nev. Comm'n on Ethics,
27 Dec. 2, 2008). Id.” Regarding NRS 281A.400(7) violations for the use of uniforms, badges and
accouterments of office in campaigns, the Commission has consistently treated all similarly situated
28 subjects even handedly. Subject’s argument would therefore fail.

Page 6 of 13

HB 00308
1 special facts that impacted the outcome and shows the development of the
2 Commission’s precedent:
3 Case Complaint Violation Willful Special Facts
/Advisory
4 Opinion
98-41A Advisory None N/A The Commission advised Sheriff
5
(Kirkland) Kirkland not use his uniform, badge,
6 employees or other physical
accouterments of his office in support
7 of political endorsements to avoid the
appearance of impropriety under the
8 previous version of NRS 281A.400(7).
9
14-61C Complaint- NRS Non Washoe County Undersheriff filed his
10
(Kuzanek) Stip. Agmt. 281A.400(7) Willful candidacy for Sheriff and obtained
advice from the DA that no legal
11 authority prohibited the use of his
badge or uniform in campaign
12 materials. Once notified of ethics
investigation he removed all photos
13 with his badge and uniform.
14-71C Complaint- None N/A Pitts campaign website for reelection
14
(Pitts) Stip. Agmt. as Sheriff displayed pictures of him in
15
his Sheriff’s uniform and badge. In
posting the pictures, Pitts relied on
16 opinion of the US Office of Special
Counsel.
17 18-031C, Complaint- None N/A Antinoro posted campaign pictures and
18-052C Stip. Agmt. appeared at debates in his uniform and
18 (Antinoro) badge. Antinoro relied in good faith
upon the Pitts Stipulated Agreement as
19
it was represented to him and other
20 sheriffs at a meeting of the Nevada
Sheriffs’ and Chiefs’ Association and
21 the opinion of the US Office of Special
Counsel created legal uncertainty for
22 Antinoro and other Sheriffs. The
Stipulated Agreement in this matter
23 also called for the Commission to
provide a letter to the Nevada Sheriffs’
24
and Chiefs’ Association providing
25 information and guidance about the
Commission’s position that the use of
26 uniforms, badges and other physical
accouterments of office by elected
27 sheriffs violates the Ethics Law.
28

Page 7 of 13

HB 00309
1 22-055C Complaint- NRS Non Coverley appeared at a campaign
(Coverley) Stip. Agmt. 281A.400(7) Willful event for a Senate candidate in his
2 Sheriff’s uniform. He took full
responsibility for his actions in his
3
Response to the Complaint and
4 obtained information from the
Commission’s staff to ensure his future
5 compliance with the law.
22-126 Complaint- NRS Willful Cochran appeared in a video
6 (Cochran) Stip. Agmt. 281A.400(7) supporting a Senate candidate.
Cochran did not wear his official City of
7 Reno uniform or identify himself as the
City of Reno Fire Chief. He also did
8
not expressly endorse the candidate
9 for whom he made a campaign video.
23-051C Complaint- NRS Willful Commission orally announced four
10 (Rodriguez) Adj. Hear. 281A.400(2) willful violations (two of each statute)
(final NRS against Rodriguez for posting two
11 opinion 281A.400(7) photographs in his uniform, badge and
pending) gun on his campaign website for
12
election as a Washoe County School
13
District Trustee.

14 D. The Undisputed Facts Show Lombardo’s Violations Were Willful


15 Subject argues that his violations of the Ethics Law should be found non willful
16 because, unlike previous sheriffs whose violations were found non willful, he did not
17 appear at campaign events or debates wearing his uniform or badge nor did he seek
18 to imply that he had received LVMPD’s endorsement. Subject’s analysis of the
19 Commission’s previous precedent is incorrect. The following matters resulted in non
20 willful violations for the noted reasons:
21 Case Reason(s) for Non Willful Violation
22 14-61C (Kuzanek) Subject obtained advice from the DA that no legal authority
prohibited the use of his badge or uniform in campaign
23
materials; therefore, his violation was not willful pursuant to
24 NRS 281A.790(5)
22-055C Subject was not aware of the requirements of the Ethics Law
25 (Coverley) prior to the violation; Subject immediately took responsibility
for his violation and took actions to prevent violations in the
26
future.
27

28 ///

Page 8 of 13

HB 00310
1 The following matters resulted in willful violations for the noted reasons:
2 Case Reason(s) for Willful Violation
3 22-126 (Cochran) Subject was aware of the Ethics Laws before he appeared in
the election video and specifically wore the uniform with the
4
intent to bolster a campaign.
5 23-051C Subject was aware of the Ethics Law before he posted the
(Rodriguez) photographs at issue on his website and did not remove them
6 after receiving notice of the Ethics Complaint.
7
Subject argues that the Commission is required to treat comparable situations
8
in a comparable manner, and the Executive Director agrees. See NRS 281A.775(3).
9
The evidence shows that Subject was aware of the Ethics Laws at issue prior to his
10
campaign and prior to posting the photographs at issue on his campaign website and
11
social media sites. In a July 19, 2021 article in The Nevada Independent, Lombardo’s
12
campaign strategist, Ryan Erwin, admitted that the strategy of pushing Lombardo’s
13
government-funded image in his LVMPD owned-uniform and with his LVMPD-owned
14
badge was purposeful in order to bring his position as Sheriff to the forefront of voters’
15
attention, arguing,
16
Lombardo is a police officer and sheriff, and Nevada voters are entitled to
17 know and see what he does for a living . . . Judges regularly appear in
robes, teachers in classrooms, and prosecutors in courtrooms as part of
18 their campaign materials - all are public employees in positions of trust.
19
Singling out law enforcement from other positions of public trust makes no
sense.
20
See Executive Director’s Exhibit 36, Newspaper Article, Tabitha Mueller, The Nevada
21
Independent, July 19, 2021.
22
Additionally, Assembly Bill, AB 218, was introduced in March 2021 during the
23
2021 Legislative Session entitled “AN ACT relating to public office; authorizing a
24
sheriff or constable to campaign for reelection to office wearing the physical
25
accouterments of the office; and providing other matters properly relating thereto.”
26
The digest for AB 218 describes the proposed act as follows:
27
Existing law requires, with limited exception, that: (1) sheriffs must be
28 elected by the qualified electors of their respective counties; and (2)

Page 9 of 13

HB 00311
1 constables must be elected by the qualified electors of their respective
townships. (NRS 248.010, 258.010) Sections 1 and 2 of this bill authorize
2
a sheriff and constable, respectively, to campaign for reelection wearing
3 the physical accouterments of the office, including, without limitation, a
uniform and badge.
4
Thus, had it passed, AB 218 would have expressly provided Subject with the right to
5
campaign in his uniform and badge, including posting the photographs at issue on his
6
campaign website and social media sites.
7
A review of the March 17, 2021 Minutes of the Meeting of the Assembly
8
Committee on Government Affairs on AB 218 shows that both Eric Spratley, the
9
Executive Director of the Nevada Sheriffs’ and Chiefs’ Association and Christopher
10
Ries, an employee of the LVMPD, were present at the hearing and testified in support
11
of AB 218. See Minutes of the Meeting of the Assembly Committee on Government
12
Affairs on AB 218, March 17, 2021, ED MSJ Exhibit No. 39. AB 218 ultimately died in
13
committee, evidencing the Legislature’s intent that the Ethics Law’s prohibition on
14
Sheriffs’ campaigning in their uniforms, badges and other accouterments of their office
15
remain in place.
16
What AB 218 and the Minutes from its hearing also show is that Subject was
17
well aware of the Ethics Law’s rules regarding Sheriffs’ campaigning in their uniforms
18
and badges and that his office participated in an effort to change that law prior to
19
announcing his candidacy for Governor. One of Subject’s own employees testified in
20
support of AB 218, as did the Executive Director of an Association of which LVMPD is
21
a member. Subject therefore posted the photographs and videos at issue to his
22
campaign website and social media sites knowing they violated the Ethics Law.
23
Additionally, Subject made no attempt to rectify his violations of the Ethics Law
24
after he received notice of the Complaints in these matters. Instead, he continued to
25
maintain all the images at issue on his campaign website and social media sites. Not
26
only that, but he produced additional campaign content featuring the use of his
27
uniform and badge all the way through the end of the campaign.
28

Page 10 of 13

HB 00312
1 E. The Penalty Requested Is Supported by Statute and Subject’s Post-
Election Fundraising
2

3 Subject argues that the Commission is limited to imposing a maximum penalty

4 of $40,000 and a maximum of three violations of the Ethics Law. This argument is

5 without basis.

6 A plain reading of NRS 281A.790(1) shows that the statute sets an increasing

7 maximum penalty for each of the first three violations found by the Commission. It

8 does not limit the Commission to three violations, nor does it limit the Commission to

9 the penalties set for those first three violations for the violations beyond the third. To

10 limit the Commission to penalties for only three violations would make no sense in the

11 structure of the rest of the statutory scheme. As noted by Subject in his own Motion,

12 other statutes within NRS 281A refer to “three or more” violations of the Ethics Law.

13 See, e.g., NRS 281A.790(4)(c)(2). If the Commission were limited to finding and

14 imposing penalties for only three violations, the references to “three or more

15 violations” would not make sense within the broader scheme of the Ethics Law.

16 Such a limitation would also prevent the Ethics Commission from effectively

17 enforcing its laws. For example, in this matter Subject made a knowing decision to

18 violate the Ethics Law by wearing his uniform and badge in photographs, taking a

19 calculated risk that it would assist him in being elected as Governor—a strategy that

20 was ultimately successful. Following his election as Governor, but before he was

21 sworn in, Subject received an additional nearly $2 million in campaign donations. See

22 Subject’s 2022 Contributions and Expenses Report No. 4, ED MSJ Exhibit No. 40.

23 If the Commission were limited to a $40,000 penalty for Subject’s knowing and

24 blatant disregard of the Ethics Laws, there would be no reason for any candidate to

25 comply with the law when they know they can pay a small penalty compared with the

26 potential to raise millions of dollars in campaign donations on top of being elected.

27 The purpose of the penalties contained in NRS 281A.790(1) is to deter violations of

28 the Ethics Law and to do so the amount of the penalty must be in line with the

Page 11 of 13

HB 00313
1 particular violation. In this case, the penalty requested by the Executive Director is
2 reasonable and warranted given the scope and severity of Subject’s violations.
3 Subject also questions the propriety of the Executive Director’s charging of
4 each instance of Subject using or posting the uniform and badge photographs and
5 videos as a separate violation. The Commission has treated repeated similar ethical
6 misconduct as separate violations in previous Opinions following hearings on
7 dispositive Motions. See Order on Dispositive Motions, Case No 19-088C (Ramos),
8 ED MSJ Exhibit No. 41.
9 The Commission should therefore grant the Executive Director’s requested
10 penalty in this matter.
11 III. CONCLUSION
12 Subject’s motion should be denied and Summary Judgment should be granted
13 in favor of the Executive Director as requested in his Motion.
14 DATED this 19th day of April, 2023.
15 NEVADA COMMISSION ON ETHICS
16

17 /s/ Elizabeth J. Bassett


Elizabeth J. Bassett, Esq.
18 Associate Counsel
19

20

21

22

23

24

25

26

27

28

Page 12 of 13

HB 00314
1 CERTIFICATE OF SERVICE
2 I certify that I am an employee of the Nevada Commission on Ethics and
3 that on this day in Carson City, Nevada, I served via email, a true and correct copy
4 of the foregoing document in Ethics Complaint Nos. 21-062C and 21-082C to the
5 following:
6 Joseph M. Lombardo
c/o Donald J. Campbell, Esq.
7
Samuel R. Mirkovich, Esq.
8 Campbell & Williams
710 South Seventh St. Ste. A
9 Las Vegas, NV 89101
Email: srm@cwlawlv.com
10
Email: mmh@cwlawlv.com
11 Attorneys for Subject Joseph M. Lombardo

12

13
Dated: April 19, 2023 /s/ Elizabeth J. Bassett__________
14 Employee,
Nevada Commission on Ethics
15

16

17

18

19

20

21

22

23

24

25

26

27

28

Page 13 of 13

HB 00315
1 Elizabeth J. Bassett, Esq. (NV Bar No. 9013)
Associate Counsel
2
Nevada Commission on Ethics
3 704 West Nye Lane, Suite 204
Carson City, Nevada 89703
4 (775) 687-5469
Email: ebassett@ethics.nv.gov
5

6 Attorney for Ross E. Armstrong, Esq.


Executive Director
7
STATE OF NEVADA
8

9 BEFORE THE COMMISSION ON ETHICS


10

11
In re Joseph M. Lombardo,
12 Sheriff of Clark County, Consolidated Ethics Complaint
State of Nevada, Case Nos. 21-062C, 21-082C
13

14
Subject /

15
EXHIBITS IN SUPPORT OF EXECUTIVE DIRECTOR’S OPPOSITION TO
16 SUBJECT’S MOTION FOR SUMMARY JUDGMENT
17
Ross E. Armstrong, Esq., Executive Director of the Nevada Commission on
18
Ethics (“Commission”), through the Commission’s Associate Counsel, Elizabeth J.
19 Bassett, Esq., hereby submits his Exhibits in Support of his Opposition to Subject
20 Jospeh Lombardo’s Motion for Summary Judgment in this matter:
21

22 Exhibit No. Exhibit

23

Minutes of the Meeting of the Assembly Committee on Government


24 39
Affairs on AB 218, March 17, 2021
25

26
Joseph Lombardo’s 2022 Contributions and Expenses Report No. 4
40
27

28

Page 1 of 3

HB 00316
1

2
Order on Dispositive Motions, Case No 19-088C (Ramos)
3 41
4

5 DATED this 19th day of April, 2023.

6 NEVADA COMMISSION ON ETHICS

8 /s/ Elizabeth J. Bassett


Elizabeth J. Bassett, Esq.
9 Associate Counsel
10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Page 2 of 3

HB 00317
1 CERTIFICATE OF SERVICE
2 I certify that I am an employee of the Nevada Commission on Ethics and
3 that on this day in Carson City, Nevada, I served via email, a true and correct copy
4 of the foregoing document in Ethics Complaint Nos. 21-062C and 21-082C to the
5 following:
6 Joseph M. Lombardo
c/o Donald J. Campbell, Esq.
7
Samuel R. Mirkovich, Esq.
8 Campbell & Williams
710 South Seventh St. Ste. A
9 Las Vegas, NV 89101
Email: srm@cwlawlv.com
10
Email: mmh@cwlawlv.com
11 Attorneys for Subject Joseph M. Lombardo

12

13
Dated: April 19, 2023 /s/ Elizabeth J. Bassett
14 Employee, Nevada Commission on Ethics
15

16

17

18

19

20

21

22

23

24

25

26

27

28

Page 3 of 3

HB 00318
EXECUTIVE DIRECTOR’S EXHIBITS
EXHIBIT 39

HB 00319
MINUTES OF THE MEETING
OF THE
ASSEMBLY COMMITTEE ON GOVERNMENT AFFAIRS

Eighty-First Session
March 17, 2021

The Committee on Government Affairs was called to order by Chair Edgar Flores at 9 a.m.
on Wednesday, March 17, 2021, Online. Copies of the minutes, including the Agenda
(Exhibit A), the Attendance Roster (Exhibit B), and other substantive exhibits, are available
and on file in the Research Library of the Legislative Counsel Bureau and on the Nevada
Legislature's website at www.leg.state.nv.us/App/NELIS/REL/81st2021.

COMMITTEE MEMBERS PRESENT:

Assemblyman Edgar Flores, Chair


Assemblywoman Selena Torres, Vice Chair
Assemblywoman Natha C. Anderson
Assemblywoman Annie Black
Assemblywoman Tracy Brown-May
Assemblywoman Venicia Considine
Assemblywoman Jill Dickman
Assemblywoman Bea Duran
Assemblyman John Ellison
Assemblywoman Susie Martinez
Assemblyman Andy Matthews
Assemblyman Richard McArthur
Assemblywoman Clara Thomas

COMMITTEE MEMBERS ABSENT:

None

GUEST LEGISLATORS PRESENT:

Assemblywoman Robin L. Titus, Assembly District No. 38

STAFF MEMBERS PRESENT:

Jered McDonald, Committee Policy Analyst


Judith Bishop, Committee Manager
Geigy Stringer, Committee Secretary
Cheryl Williams, Committee Assistant

Minutes ID: 556

*CM556* HB 00320
Assembly Committee on Government Affairs
March 17, 2021
Page 2

OTHERS PRESENT:

Eric Spratley, Executive Director, Nevada Sheriffs' and Chiefs' Association


Christopher Ries, representing Las Vegas Metropolitan Police Department
Annemarie Grant, Private Citizen, Quincy, Massachusetts

Chair Flores:
[The meeting was called to order. Committee protocol was explained.] Happy Saint
Patrick's Day. Thank you to our amazing committee manager, Judith Bishop, for getting the
festivities started early and always having the right energy. Our very own Assemblywoman
Titus will be joining us to present Assembly Bill 218. At this time, I would like to open up
the hearing on Assembly Bill 218.

Assembly Bill 218: Revises provisions governing certain elected county offices.
(BDR 20-195)

Assemblywoman Robin L. Titus, Assembly District No. 38:


Assembly Bill 218 is an act relating to public office, authorizing a sheriff or a constable to
campaign for reelection to office while wearing the physical accoutrements of their office.
I represent District 38, which is all of Churchill County and most of Lyon County.

Assembly Bill 218 clarifies that a sheriff or constable campaigning for reelection to office
may indeed wear the uniform of their office. As a wife of a retired sheriff, I know that the
job is 24 hours a day, 7 days a week, 365 days a year. The uniform they wear is theirs.
When elected, they choose what the uniform looks like; they choose the colors that they and
their officers will wear. Assembly Bill 218 clarifies that indeed they may wear that uniform
anytime, including when they are campaigning for reelection. They are never not on duty.

I am now going to ask Eric Spratley, the executive director of Nevada Sheriffs' and Chiefs'
Association, to give some further comments. I will be available to answer questions, if there
are any, at the end.

Eric Spratley, Executive Director, Nevada Sheriffs' and Chiefs' Association:


The Nevada Sheriffs’ and Chiefs’ Association is the professional association composed of
your 17 elected sheriffs, chiefs of police, and law enforcement leaders throughout the state of
Nevada. The association is grateful to Assemblywoman Titus for bringing forth this
legislation, and I am truly honored to be in front of this Committee to discuss the need for
Assembly Bill 218 and the main points for why we ask you to consider this legislation.

Mr. Chair, if I may take a few minutes of your time to go over those points?

Chair Flores:
Please.

HB 00321
Assembly Committee on Government Affairs
March 17, 2021
Page 3

Eric Spratley:
The office of sheriff in the state of Nevada is a political, nonpartisan office in which
a candidate for sheriff is elected by the majority of voters in each of the 17 Nevada counties
with elections occurring every four years. It is the same for the office of the county
constable. The sheriff’s qualifications, duties, responsibilities, and other provisions or
limitations are spelled out in Chapter 248 of Nevada Revised Statutes (NRS); constables are
in NRS Chapter 258. This bill seeks to amend these two chapters by adding language
permitting a sheriff and/or a constable to wear the “accoutrements of the office”—which are
a badge and gun—while campaigning. Here is why this is important. I will speak to sheriffs
specifically:

1. Each Nevada sheriff is the chief law enforcement officer in the entire county—
24 hours a day, for every day of the year that they are in office, as you heard
Assemblywoman Titus say.
2. In that law enforcement capacity, the sheriff has—as the main outward identifiers for
their position—a uniform, a badge, and a gun.
3. Even if a sheriff is not in full agency uniform, they will almost always have their
badge and gun with them, and the badge and gun are considered what are known as
accoutrements of the uniform—whether or not the sheriff personally paid for and
owns these items.
4. They wear the uniform and their accoutrements due to their statutory responsibility
under NRS 248.090 to “keep and preserve the peace in their respective counties.”
This is key. They have the unquestionable personal responsibility to respond to crisis
and apprehend criminals.
a. Under NRS 248.040, sheriffs have the ability to appoint deputies. This is
what you know as command structure—executive staff, supervisors, and
deputies. These folks help assist them in carrying out these statutory duties,
but the responsibility rests with the elected sheriff.
b. There are police departments in cities, but the elected sheriff retains their law
enforcement authority at all times.
c. Similar to an “is there a doctor in the house?” call during a medical
emergency, if there is a need for a law enforcement response at any particular
moment in the sheriff's presence, the elected sheriff has the personal duty to
respond and handle the issue; they need to have at least the minimum uniform
accoutrements on their person to do so.
5. For over 160 years, each Nevada sheriff has worn, and continues to wear, the official
uniform and its accoutrements—badge and gun, minimally—while in public and
carrying out the wide variety of statutory duties, such as emergencies, traffic control,
search and rescue, coroner calls, crime scenes, jail operations, calls for service,
officer backup, and things such as that. They also have public service opportunities,
such as community meetings, safety meetings, media interviews, recruitment
opportunities, speaking events, fish fries, bake sales, town halls, all those fun things
they get to do—and that they like to do as well—that are regularly presented to them.

HB 00322
Assembly Committee on Government Affairs
March 17, 2021
Page 4

What keeps sheriffs and constables accountable so they are not behaving improperly with
this perceived power and prestige of the office? The answer is NRS Chapter 281A and the
federal Hatch Act of 1939. The Hatch Act applies to state and local government employees
who work in the Executive Branch and whose principal employment is in connection with
any activity financed in whole or in part by loans or grants made by the United States or a
federal agency. Sheriff’s offices fall under this authority—we get grants from the federal
government and we are bound by certain things regarding the federal government. The
Hatch Act was specifically addressed by the U.S. Office of Special Counsel in 2012 and
2018, regarding whether or not it was a violation of the Hatch Act for an incumbent sheriff to
wear the uniform while campaigning for office. The answer, in plain terms, was no. In its
interpretation of the Hatch Act, the Office of Special Counsel says, No, it is not a violation.
Some of the language they used in the memo on that determination says:

Because incumbents already hold partisan political office, we have reasoned


that incumbents do not violate the Hatch Act by wearing a uniform or using an
official title while campaigning for reelection. Thus, we have advised that a
sheriff may attend campaign events while wearing his uniform and identifying
himself as the sheriff or use photographs of himself in uniform for
campaigning purposes. Similarly, a sheriff does not violate the Hatch Act by
driving an agency-issued vehicle to a campaign event.

That is from the Office of Special Counsel, August 14, 2018.

Our Nevada sheriffs are well aware of the Hatch Act and the code of ethical standards in
NRS Chapter 281A, and they confidently operate within those requirements. However,
neither the Hatch Act nor NRS Chapter 281A applies to nonincumbents who may feel free to
dress in a law enforcement uniform for the purposes of campaigning for the office of the
sheriff. That law, that Hatch Act, does not apply to nonincumbent people running for the
office. You would think that if someone is throwing on a uniform and campaigning for the
office of the sheriff, that NRS 199.430, impersonating an officer, would apply. But unless
that candidate tried to do something official in the uniform and injured or defrauded another
person, that statute does not apply. Now the scales would be tipped in favor of that person,
whereas the current incumbent Nevada sheriff, who rightfully wears the uniform, is being
questioned for wearing his.

Over the past decade or so, there have been complaints filed against incumbent sheriffs
claiming that it is improper for the sheriff to wear the official uniform or its accoutrements.
As you are well aware, campaigns are difficult enough to navigate, and a wide variety of
things are thrown around to try to derail an opponent’s momentum. I am not familiar with it,
but you are and our sheriffs are. Campaigns are difficult. Congratulations to you for being
successful in yours.

To make matters worse, there is no official start date for a sheriff's campaign cycle, so in the
case of complaints against an incumbent sheriff, any behavior of a sheriff in uniform, or their
simply wearing the badge and gun at any time they are in office, may be used as a basis for a

HB 00323
Assembly Committee on Government Affairs
March 17, 2021
Page 5

complaint for a violation of NRS 281A.400 regarding ethics. It should be noted here that
while there have been a few campaigning in uniform complaints filed against Nevada sheriffs
over the past decade, none that we are aware of have been found as violation of law by the
Commission on Ethics. The Ethics Commission has acknowledged that the use of uniforms
and badges in campaign materials in Nevada has been employed by candidates for other law
enforcement offices in Nevada. They also state that without a state or local law governing or
clarifying duties of elected incumbents regarding utilization of the accoutrements of office,
the Ethics Commission had to stipulate to the dismissal of these allegations over this past
decade.

These complaints, though none have been sustained, really do wear on the sheriff accused,
and the other sheriffs as well, during the time the case is being handled by the Ethics
Commission. It has them all walking on eggshells rather than freely and confidently
focusing on the job at hand and the public service duties they were elected by the people
to do.

I will wrap it up with a couple of considerations. Is it reasonable to have a sheriff in uniform


deny a citizen conversation simply because it might lead to or be interpreted as campaigning?
Should a sheriff not hold a press conference for a critical incident in October of an election
year simply because it is close to Election Day, or must that sheriff hold the press conference
without wearing a uniform, a badge, or a gun because someone might consider it a campaign
advantage? Certainly not.

You have the opportunity with this bill to support that elected sheriff—your elected sheriff—
and elected constable, if you have one in your county, so they may continue to perform their
statutory duties and daily functions without worrying whether or not their actions in uniform
will be used as a basis for yet another complaint. Assembly Bill 218 will make it clear that
our elected officials may wear the uniform they have the right to wear—to perform the duties
they have been elected to perform—and to do so within the guidelines of the Nevada code of
ethical standards and the federal Hatch Act.

For those reasons, the Nevada Sheriffs' and Chiefs' Association asks for your support and
affirmative vote for Assembly Bill 218.

Mr. Chair, that concludes my testimony.

Chair Flores:
Thank you for that detailed explanation. I appreciate your going to other sections of the NRS
that may have triggered some questions by folks and preemptively addressing them. At this
time, we will start with questions.

Assemblywoman Dickman:
I think you touched on my question, but say a deputy was going to run against the incumbent
sheriff, or the Sparks police chief decided he wanted to run for the Washoe County Sheriff's

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Assembly Committee on Government Affairs
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position. In those two examples, would they both be able to wear their uniforms while
campaigning, or is it just the incumbent sheriff who is included?

Eric Spratley:
It is questionable. I believe NRS Chapter 281A, the way I read it, covers the fact that elected
officials and their employees cannot—and I am just trying to pull it up as I am speaking to
you, so I am multitasking—I believe it covers them as well. I, Eric Spratley, not a law
enforcement officer, can buy some uniform accoutrements, put on patches and a badge that
says Las Vegas Metropolitan Police Department, and run for that office. The Hatch Act,
NRS Chapter 281A, ethics—none of that applies to me. If I do not try to do something
official with that uniform and harm another person in doing it, I am not impersonating an
officer. There is nothing that really prohibits a person from doing that. When it comes to
employees, directly to your question, I believe they are covered under NRS Chapter 281A
and would be prohibited from doing that.

Assemblywoman Dickman:
It basically gives the incumbent sheriff an advantage over someone else who might have a
uniform but cannot wear it. Why not just include every law enforcement officer in this bill
and allow them all to wear their uniform if they are campaigning for sheriff?

Eric Spratley:
I guess that would be a decision for this Committee to make.

Assemblywoman Anderson:
Assemblywoman Titus, I emailed you two questions yesterday, and Assemblywoman
Dickman just brought up one of them, so I greatly appreciated it. This is my other question:
Say there is someone who runs for office and wins in 2015, and then runs again and loses.
He decides to run for sheriff for a third time against the incumbent sheriff. Are both
individuals able to wear their uniforms because they have both served as sheriffs? Or is it
only the current sheriff who is able to wear the uniform while campaigning?

Eric Spratley:
In your scenario, the nonincumbent sheriff—the one who was sheriff, did not win, and is
coming back—can actually wear that uniform again. The incumbent sheriff would not be
able to, under current law—or current lack of law. He could, but then people file complaints
and the Ethics Commission deals with the complaints. The Commission states in some of
their determinations that it is not prohibited without a state statute or local law. They do not
provide very clear direction; they have to go off of what seems to be impartial. That is why
we are asking for a state law. To that point, it can still be a local government's choice and
even a policy decision by that sheriff's office. If there is a policy against it, or a local
government says, Hey, we do not want our sheriff wearing the uniform while campaigning,
that is up to the local government. We are asking for the state level to say, Yeah, it is
appropriate. That would get rid of the ability for ethics complaints to be filed and avoid
people having to deal with that and keeping the sheriffs on eggshells as to whether or not
they can wear their uniform in an election campaign.

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Assembly Committee on Government Affairs
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Assemblywoman Anderson:
If I understand correctly, the current format is the complaint would be done at the local level.
For clarification purposes, could you walk through how that complaint is made? Is it done at
the state level or the local level?

Eric Spratley:
I believe complaints of this nature would go directly to the Ethics Commission at the state
level.

Assemblywoman Anderson:
Then the Ethics Commission would utilize the state law. But based on your answer, it
sounds like there is also a way to get the local level involved in making that decision as well.
I guess that is where my confusion is coming from.

Eric Spratley:
Your local county commission can pass a county ordinance handling the matter of whether a
sheriff or elected official can wear a certain uniform during the campaign or not. Yes, they
can. Right now, the Ethics Commission does not see any of those at the local level or, for
example, that there are no prohibitions in a sheriff's policy manual or a county policy. The
Ethics Commission reverts back to the language in NRS Chapter 281A and tries to make a
decision based off of that. We are asking for it to be clear: Yes, a sheriff can wear the
accoutrements. He is elected for four years and he gets to be the sheriff the entire time. He
does not have to pull back or dress down when he has a press conference and a microphone
comes up and somebody thinks he is campaigning in uniform when he is just being the
sheriff and doing his or her job at a traffic crash scene.

Assemblywoman Duran:
My question is this: Basically, you cannot wear campaign gear while you are near voting
sites. Is it going to be a violation if a sheriff wears his uniform to vote?

Eric Spratley:
I do not know. I do not have an answer. I think our sheriffs would be very cautious in that
regard.

Assemblywoman Titus:
I think this bill does not affect that. I think for a sheriff in uniform—or anybody in uniform
going to vote on their way to work—there is no prohibition. We could ask our legal counsel,
if they are not too busy helping finish some of the bill draft requests. I think there could be a
problem if the sheriff wore a reelection campaign button or that sort of thing. But if
somebody wears their uniform—whether it be for the military, National Guard, or something
else—to vote on their way to work, I would say that is not a campaign violation. They are
not wearing the T-shirt they wore in their reelection campaign—I think there would be a
difference. If our legal counsel is available, we could certainly have them get some
clarification on that.

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Assembly Committee on Government Affairs
March 17, 2021
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Assemblywoman Duran:
If they are available, we would like to get that clarification for the record.

Chair Flores:
We will have our policy analyst reach out with an inquiry. I am sure that by the conclusion
of today's hearing, we will have a response from the legal counsel. As we all know, we are
responsible for having them work really late and not being available since we have so many
bill draft requests. They are out drafting, but I am sure we will get a response later during the
hearing.

Assemblywoman Thomas:
I have one question for clarification. I am a retired veteran, and I think it would be great if I
could show up at campaigns in my military uniform. Even though I am a veteran, I am still
allowed to wear my uniform. Would that be appropriate?

Assemblywoman Titus:
Thank you for your service. Nothing in this bill interferes with whether you can wear your
uniform or not while you are campaigning. It is your uniform. We have veterans show up in
their uniforms to campaign; there would be nothing that restricts that based on this bill or the
current law we have. That is not really this bill's purpose and would not affect your ability to
wear your uniform at any time.

Assemblywoman Thomas:
Would that be an advantage that I would have over my opponent?

Assemblywoman Titus:
I certainly cannot address who your opponent might be and whether or not he is a veteran.
Again, this bill is not about giving advantages. This bill is about clarification on ethics
complaints about the sheriff. I think this is a one-page bill that we need to put in statute to
say sheriffs and constables can wear their uniform. Going back to Assemblywoman
Dickman's question of whether or not the captain of the Sparks police force could wear his
uniform while campaigning, this bill does not prohibit nor does it address whether he can do
that. That is a company policy. This is just going to clear up in statute that, indeed, the
sheriff is able to wear his uniform because of the uniqueness of that uniform. However, if
the Sparks city police have no problem with their captain wearing his uniform, and he is on
duty 24/7, that could be a policy. None of this bill affects whether they can be wearing their
uniform in all these unique situations. Nothing prohibits it either.

Assemblywoman Considine:
After I read this bill, I had so many questions running through my head. Assemblywoman
Titus, I know I sent you a bunch of those questions. For example, I asked if the sheriff could
wear his uniform when he is fishing, if he wears it 24/7. To boil it down: I understand what
this bill is for, but from the other side, how does anyone know whether the sheriff is being
the sheriff or is in campaign mode if he looks the same in both situations?

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Assembly Committee on Government Affairs
March 17, 2021
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Assemblywoman Titus:
Being married to a sheriff, I know he had his badge and gun when we went fishing. He never
left those behind, whether he was in the supermarket, or fishing, or wherever he was. He was
the sheriff, and we could have gotten—and have gotten—calls during any situation. There is
none in which you could describe whether or not he would have his badge or gun—because
he did. Did he have some other stuff in the car? Yes. As Eric Spratley expressed, that is the
purpose because they could be at a car accident in October or the day of the election. They
could be there anytime; they would be in uniform. Your question is well taken because how
do you know if they are campaigning or not? When does X happen? Someone is in
campaign mode and then is the sheriff—and a transition does not happen because they are
always in sheriff mode and it may be a reelection year. That is where the gray zone is and
that is why there is a need for this bill. Anybody can say the sheriffs are just out
campaigning, when in reality the sheriffs are working. We are trying to clarify that it does
not matter when something happens; they are entitled to be wearing it.

Assemblywoman Considine:
Again, having thought about this all night, reading the letter that is attached, and listening to
Mr. Spratley today, I am wondering if the problems coming up that Mr. Spratley had
mentioned could be taken care of by tweaking or working on campaign laws to tighten them
up as opposed to what this bill does.

Assemblywoman Titus:
Mr. Spratley can address this also, but I will say there was a lot of discussion prior to this bill
being presented about what the best fix was in terms of clarity. As we all know, sitting in
this hearing on both sides of the Zoom meeting, campaigns can be tough. None of us want to
have an ethics violation filed against us, and there can be issues out there. We looked at the
different options—what would provide the most clarity with a simple wording change and
the simplest processes to make it clear. This is where we landed. Now I will have
Mr. Spratley add anything he might want to add.

Eric Spratley:
That is right. It is really about going for the clearest option in this regard. Sheriffs and
constables are unique—especially sheriffs—in that they have to wear that uniform, as well as
the accoutrements of the uniform, which is what it really comes down to. It used to be
thought that if the sheriff buys his uniform, badge, and gun, then those are his personal
property and he can wear them whenever he wants. But it has been determined that this is
not the case; it is the official uniform of the sheriff's office. It is unique in that regard, so
when you get into the campaign side of things, it starts affecting everybody. Maybe an
elected official is in his official position, wearing a tweed jacket with leather patches on the
elbows all the time. Then all of a sudden he is campaigning in that same tweed jacket and he
can get an ethics complaint filed against him. It is kind of a stretch, but that is the idea. For
example, my little pin here is an accoutrement of my position in this organization.

The sheriffs have a duty; they have been elected to do that job 365 days a year. Certainly,
they do not sleep in the uniform or sit in a uniform while fishing, but they have the badge and

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Assembly Committee on Government Affairs
March 17, 2021
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the gun, and they are ready to respond to a law enforcement crisis at any time. It really made
sense to put it specifically into NRS Chapter 248 for sheriffs and NRS Chapter 258 for
constables.

Assemblywoman Considine:
Personally, I am trying to look at some sort of fair balance on this, so I do appreciate the
answers.

Assemblywoman Brown-May:
Thank you, Assemblywoman Titus, for bringing this bill forward and giving us an
opportunity to consider this decision. I have one clarifying question. I certainly appreciate
that a sheriff would need to carry a badge and gun at all times so he can be easily identified
in the duties of his office. I am curious, though. When there is campaigning going on, is
there any distinction between appearing in person in uniform—in the action of his or her
duty—and appearing in TV ads or other media ads that would be specific to campaigning
events? Has any thought been given to that?

Eric Spratley:
There is no distinction here, especially when you look at the Hatch Act of 1939, when this
was addressed in 2012 and 2018 regarding sheriffs. In simple terms, they said, No, it is not
improper, so go ahead and do it. They even included the vehicle, and I am thankful that they
did because, as I said, of our rural sheriffs. In Nye County, Sheriff Sharon Wehrly will be
out driving and come across a traffic crash or hear of an officer needing assistance. She
drives a marked patrol vehicle and will show up on scene, so the person on scene knows who
she is—I guess they would probably consider her a deputy of the department; they would not
know she is the sheriff. It is not inappropriate, and it is for all aspects of the campaign—left
to the discretion of the sheriff.

Assemblywoman Torres:
I am looking at the legislation, and I know it talks about the uniform and badge. In the
conversation today during the hearing, we also talked about the gun the sheriff or constable
would have. I do not see that specified here in the legislation. I think the disagreement here
with the Committee is specifically with the uniform, not with the other two items. I can
understand that an officer would have the badge on their person at all times. But even for our
state offices, a state employee could not wear their badge to attend a campaign event.
I suppose I have concerns about the specific part of the uniform, and I think part of the
conversation has included the arms. That is not included in this legislation, and I am
wondering if there was the intent to add it.

Assemblywoman Titus:
Are you speaking to their carrying a firearm at all times?

Assemblywoman Torres:
I think the idea that they should be able to carry their badge and gun was a big part of
Mr. Spratley's conversation. It is not specified, though obviously the legislation does say

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Assembly Committee on Government Affairs
March 17, 2021
Page 11

"without limitation." I just feel "without limitation" might be a little general. They cannot
use a government car off duty as desired, right? Could we get more clarification on that?

Assemblywoman Titus:
Again, they are not off duty. They are issued a car and they always have that car. They are
always on duty. Just to clarify, this is not somebody who is hired through a department and
is assigned a car while on duty, like all government officials—like any of our employees here
and our officers who do such a good job. Those employees are hired, they do their shift, and
when they are off duty, they are off duty.

The distinction here is a sheriff is an elected official who is never off duty. As everyone here
in this meeting knows, we are never not assemblymen. We are elected. There is a distinction
between an elected official and an employee who has set hours and certain things they do at
certain times. That is the distinction we are making—this person has this position at all
times. Again, my husband takes his boots off and puts the gun beside the bed—he does not
wear it to bed, but it is never far away, I will tell you. That is the reality here. There was this
gray zone of going home to change and going to an event or something. I was asked to carry
this bill because of the concern about the ethics. Are they entitled to do this? We are trying
to make this distinction. It does not roll over to others who are employees; that would be a
limited policy.

Again, the gun stays with them no matter what. Even if a sheriff is out campaigning in a suit,
he will have his gun on. That is just part of the process.

Eric Spratley:
Just to add to that, even if the person is wearing a suit like mine, he is still wearing the
accoutrements of the office. If he becomes visible at any time, it could be an issue—for
example, if he unbuttons his jacket and the badge appears. The accoutrements of the office
are important. Again, it comes down to an elected sheriff who has a specific uniform he
wears the majority of the time. They want to be able to wear it without question and
complaint, to do their normal duties if it turns into something that could be perceived as
campaigning—for example, if they are answering media questions and somebody says, No,
they are campaigning. It just gets rid of that gray area.

The Hatch Act says it does not apply to a sheriff in uniform going door to door campaigning.
The Hatch Act says that because a person feels compelled to open the door to talk to a law
enforcement officer, door-to-door campaigning would maybe put the person back on their
heels a bit. This bill does not apply to that; it is not free rein to do anything you want in
uniform. Our sheriffs in Nevada are very cognizant of that. They are cognizant of NRS
Chapter 281A ethics violations and the Hatch Act. They just wanted clarity. That is all we
are asking for here today—that NRS Chapter 248 and NRS Chapter 258 be clear on what
sheriffs and constables are allowed to do.

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Assembly Committee on Government Affairs
March 17, 2021
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Assemblywoman Torres:
I would advise caution about saying what this bill does and does not apply to. I believe it
would actually apply to that. If that was the discussion, I think there needs to be more
clarification on what type of campaigning this could apply to—is it just photos on literature
or is this more general? Is it door-to-door campaigning? Because when I look at the phrase
"campaign for reelection," I think those examples are central parts of it. I do not need a
response; I just urge the sponsor to consider putting more clarifying language into the bill.

Assemblywoman Martinez:
If they are campaigning with their uniforms on, would that mean taxpayers are paying for
them to campaign?

Assemblywoman Titus:
To clarify, they are salaried whether they are campaigning or not. What they do is what they
do; this does not change any of that behavior. I am sensing some pushback from folks who
think it is giving sheriffs and constables undue abilities. I think we can get some clarification
for your question, Assemblywoman Martinez, and Vice Chair Torres' point about whether
they can go door to door campaigning. That would be inappropriate, and it is not the intent
of the bill. The questions folks have raised are well-intentioned, and I do appreciate them. If
you have those questions, what does the system have? So I appreciate your bringing that up
and asking whether taxpayers are paying for sheriffs and constables to go door to door.

Whether they are wearing their uniform or not while they campaign, they are campaigning at
times when they are the elected official because they are salaried and work 24 hours a day.
This bill does not affect whether they will go door to door and campaign when they are
salaried employees, just to be clear on that.

Back to the Vice Chair's question: I think those are great questions, great points, and we can
certainly get some more clarity.

Assemblywoman Considine:
A similar question to mine was asked, but mine is a little narrower. It has been mentioned
that part of the sheriff's accoutrements is the car. My specific question was a bit different,
but Assemblywoman Titus may be able to follow up with it: I know that is not necessarily
part of the salary if they are using the car to go to and from campaign events, but is that
something the taxpayers are paying for whether it is for the campaign or not?

Assemblywoman Titus:
A vehicle is assigned to you, for X amount, wherever you are going with that vehicle. I can
assure you my husband would not even drop his child off at school in the sheriff's vehicle
because that is just not something he did. To clarify: This bill does not address that; it does
not say you can or cannot take the car somewhere. A sheriff has to be responsible and know
what is right and wrong. For anybody out there who has an issued vehicle, we would hope
they would only ever use it for the intended purpose. I would hope the sheriffs also follow
that rule. Just to be clear, that is not what this bill is trying to do.

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Assembly Committee on Government Affairs
March 17, 2021
Page 13

Eric Spratley:
The accoutrements of the office, as defined by Nevada, include the badge and the gun; they
do not include a vehicle. In the statement I read, I talked about the vehicle not being a
violation of the Hatch Act—the Hatch Act is the one that talked about door-to-door
campaigning as well. That is where it comes from.

Assemblywoman Considine:
To me, this goes back to the distinctions and how gray they are. I think we could probably
go on for hours coming up with situations where it is unknown whether the person in
question would be the sheriff as sheriff or sheriff as campaigner. I just feel like the
distinctions, as we go on, are getting harder and harder to define.

Assemblyman Matthews:
Under this bill, what would happen if an incumbent sheriff was campaigning for another
office? The way it is written in the bill is "for reelection," which at least implies it is for the
office currently held. If an elected sheriff campaigned for county commissioner or some
other office, would that sheriff be allowed to wear the uniform under those circumstances?

Assemblywoman Titus:
At this point in time, they can because it is their uniform. They can show up in their uniform
now and campaign for that next office. It is not addressed in this bill. The complaint was
they were campaigning for their own office in uniform and they should not; that was the
ethics concern. I think a sheriff would have to make the choice whether or not he would
show up in his uniform and campaign for the office, and whether it was a good decision on
his part. I would go back to the scenario you described. If they filed and ran for county
commissioner but are now going to an accident scene and reporting on that, somebody might
file a complaint on them—now they are in uniform and running for office. Again, we have
opened a lot of gray zones and are just trying to get clarity about whether they can wear their
uniform for any office they are running for. I will turn it over to Mr. Spratley to see what his
comments are.

Eric Spratley:
I do not have an answer to that question. I do not know.

Chair Flores:
Maybe we can get some clarification in a little bit on that particular question.

Assemblyman Ellison:
As a rural person, a lot of these sheriffs might get called in to speak and talk about
campaigns—they are still on duty. They would still go in wearing their full uniform; if there
is any event, they are there as a sworn officer but still might be campaigning. I support this
bill; I think it is a good bill, mostly for some of the people in Ely, Eureka, and Elko—all
these other small counties. I strongly support this bill.

HB 00332
Assembly Committee on Government Affairs
March 17, 2021
Page 14

I just want to let you know I am trying to follow two meetings. I was not ignoring
everything; I am just trying to do both at one time. I want to get on the record that this is a
good bill. I could not believe we had to go to this point to put a bill in for something that is
common sense.

Assemblywoman Dickman:
One of my colleagues—I cannot remember who it was—brought up a topic I think is kind of
important here. The fact that under this bill, they would be able to use their uniform in TV
ads and campaign material, it seems to me it would give them an unfair advantage. What if
we clarified that a little bit, since the point of this bill seems to be to make it easier for
sheriffs not to have ethics complaints filed when they are performing their duties. Would
you consider being more specific on what this allows? I want to support this bill. Years ago,
I had a sheriff who took a picture with me. He was on duty. We used it on a campaign piece
and found out afterward that we had to destroy the 5,000 pictures we had printed because no
one was sure if it would be an issue.

Assemblywoman Titus:
We will certainly try to be thoughtful about where we need to fix this and about your
concerns regarding when they can and cannot wear the uniform. It is all gray zones, and I
appreciate everyone's questions and comments. They were all thoughtful. I appreciate
everybody on the Committee because each of you had a unique question and observations.
We have hearings to vet these bills before they go forward, if we can get you on board with
the need for this, and to clarify what this addresses and what it does not. All the questions
and thoughts were great and obviously needed to be asked. I can guarantee that we will try
to work on that. I hear your question, Assemblywoman Dickman, and I do not have an
answer. I think we can certainly follow through with that and see if we can clarify some of
this for you.

Assemblywoman Dickman:
That would be great because I really want to support this bill, but I do see some issues
with it.

Chair Flores:
I do not believe we have additional questions. At this time, I would like to invite those
wishing to testify in support of Assembly Bill 218.

Christopher Ries, representing Las Vegas Metropolitan Police Department:


I would like to echo Director Spratley's testimony to allow elected sheriffs to campaign in
uniform, and we are in support of A.B. 218. Sheriffs have been duly elected and in turn have
earned that title as well as the ability to wear the uniform which identifies them as such. This
bill decreases confusion for both the elected sheriff and the citizens of Nevada.

HB 00333
Assembly Committee on Government Affairs
March 17, 2021
Page 15

Chair Flores:
Is there anyone else wishing to testify in support of Assembly Bill 218? [There was no one.]
At this time, I would like to invite those wishing to speak in opposition to Assembly Bill 218
to call in.

Annemarie Grant, Private Citizen, Quincy, Massachusetts:


I am opposed to this bill. It is important to me who becomes the elected sheriff, given that
my brother was killed at a jail run by a sheriff in Nevada. There needs to be that separation
between the politician and the position, which is the highest-ranking law enforcement office
in the county. Many hypotheticals have been presented; I am curious about the actual yearly
number of ethics complaints regarding this issue. This bill does not strengthen transparency
and accountability. How many times has a former law enforcement officer running for office
worn their uniform? I know that Allan Fox was running for sheriff in 2018 in Washoe
County. He did not wear his uniform; he was a former member of the Reno Police
Department. Also, Adam Hopkins ran for sheriff in 2018; he was a former Washoe County
sergeant, or maybe even higher ranking. He did not campaign in uniform.

As a previously uninformed voter—and I admit it, I was—that is something that would sway
me. Being an uninformed voter—I am not anymore, but I was—seeing somebody in their
uniform would be something that would sway me to vote for them, and I do not think it is
right. Please do not support this bill. Please support bills that strengthen transparency and
accountability from law enforcement.

Chair Flores:
Is there anyone else wishing to speak in opposition to Assembly Bill 218? [There was no
one.] At this time, we will invite those wishing to speak in the neutral position to A.B. 218
to call in. [There was no one.] Assemblywoman Titus, I invite you to come forward with
any closing remarks you may have.

Assemblywoman Titus:
I really appreciate all the wonderful questions that were brought up by members of your
Committee today. Trust that I will take each and every question to heart, try to get some
clarifying language, and answer your concerns. To those of you who have reached out to me
via email, I still have about 15,000 emails in my inbox—I am trying to get through them as
best I can, so I apologize for not responding prior to this meeting. Happy Saint Patrick's Day
to you all.

[Exhibit C was submitted but not discussed and is included as an exhibit for the hearing.]

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Assembly Committee on Government Affairs
March 17, 2021
Page 16

Chair Flores:
I am sure the members will continue to reach out with questions and work with you on this
bill. At this time, we will close out the hearing on Assembly Bill 218. Thank you again,
Mr. Spratley, for joining us this morning, and for all the work you all do to help our Nevada
citizens. At this time, I would like to invite those wishing to speak in public comment to
call in.

Annemarie Grant, Private Citizen, Quincy, Massachusetts:


My brother, Thomas Purdy, was 38 years old when he was hog-tied by Reno Police and
asphyxiated to death by four deputies at the Washoe County Jail. Those officers' names were
Christopher Good, David Tallman, Jorge Aparicio, and Officer Maxwell, Brendan Glynn,
Timothy Senger, and Paul Hubbell.

It is the little things I miss the most about my brother: a hug, a phone call, the way he was so
protective of my son in order to make sure nobody was bothering him and made sure that my
son was doing right. There is not a single day—I am sorry—I miss hearing him say, I love
you, Anne, at the end of our conversations. My brother was a father of two children who
were ten and eight years old when he was killed by Reno police on October 8, 2015. I have
to bear witness to the profound and detrimental effects it has had on their lives. Myself, I
have not slept over three hours a night since October 4, 2015. Can you try to imagine being a
child and having to process your parent being asphyxiated to death by those who we have
taught them are there to protect them?

Kenny Stafford was also a father of three when he was killed by Sparks police. Niko Smith
was a father when he was asphyxiated to death by the Washoe County Sheriff's Office.
Johnny Bonta was a father when he was shot and killed by Sparks police. Kyle Zimbelman
was a father of three when he was killed by multiple law enforcement agencies in Nevada.
Nick Farah was a father when he was asphyxiated to death at the Clark County Detention
Center.

There is not a single day, hour, or minute that my brother, and the torture and terror he
experienced, is not on my mind. This is why I continue until my last breath to be his voice
and advocate for change. I do not want your families to know this pain, and it is a real
reality. I, too, once lived on an imaginary pedestal, where my loved one would never be
murdered by police without consequence either. Please promote bills that support
transparency and accountability from law enforcement.

Chair Flores:
Thank you again for joining us, and as always, we are sorry to hear about the tragic loss of
your brother. Is there anyone else wishing to speak in public comment? [There was no one.]

HB 00335
Assembly Committee on Government Affairs
March 17, 2021
Page 17

Members, as you know, tomorrow we will be having a hearing on Assembly Bill 253 that
will be presented by our very own Assemblywoman Considine. Please give yourself an
opportunity to review that bill and reach out preemptively if there is anything you would like
to get clarified. This meeting is adjourned [at 10 a.m.].

RESPECTFULLY SUBMITTED:

Geigy Stringer
Recording Secretary

RESPECTFULLY SUBMITTED:

Lindsey Howell
Transcribing Secretary

APPROVED BY:

Assemblyman Edgar Flores, Chair

DATE:

HB 00336
Assembly Committee on Government Affairs
March 17, 2021
Page 18

EXHIBITS

Exhibit A is the Agenda.

Exhibit B is the Attendance Roster.

Exhibit C is a letter dated March 12, 2021, submitted by Sharon Wehrly, Sheriff, Nye
County, in support of Assembly Bill 218.

HB 00337
EXECUTIVE DIRECTOR’S EXHIBITS
EXHIBIT 40

HB 00338
CONTRIBUTIONS AND EXPENSES REPORT State of Nevada 
Joseph Lombardo Governor Clark County
Name Office (if applicable) District (if applicable)
50 S Jones #201, Las Vegas, NV, 89107 702-259-5559
Mailing Address Telephone No.
reports@incompliance.net
E-Mail Address
Select Appropriate Box(es) CANDIDATE      LEGAL DEFENSE FUND What is this?       AMENDED

 
Report #1 - Due April 15, 2022
Period: Jan 01, 2022 - Mar 31, 2022
Report #2 - Due July 15, 2022
FILED
Period: Apr 01, 2022 - Jun 30, 2022 Jan 17 2023
Report #3 - Due October 15, 2022

 
Period: Jul 01, 2022 - Sep 30, 2022 FRANCISCO V.
Report #4 - Due January 15, 2023 AGUILAR
Period: Oct 01, 2022 - Dec 31, 2022 SECRETARY OF STATE
Annual Filing - Due January 15, 2023
Period: Jan 01, 2022 - Dec 31, 2022 FOR OFFICE USE ONLY

      * Report #4 suffices for the 2023 Annual CE Filing only if Report #’s 1, 2, 3, are previously filed this period.
Cumulative From
Beginning of Report
CONTRIBUTIONS SUMMARY This Period Period #1 Through
End of This
Reporting Period
1. Total Monetary Contributions Received in Excess of $100 $ 3,667,205.90   $ 7,414,883.20

 
2. Total Monetary Contributions in the Form of Loans Guaranteed by a 3rd-Party in Excess of $100 $ 0.00   $0.00
3. Total Monetary Contributions in the Form of Loans that were Forgiven in Excess of $100 $ 0.00   $0.00
4. Total Amount of Written Commitments for Contributions in Excess of $100 $ 0.00   $0.00

 
5. Total Value of In Kind Contributions in Excess of $100 $ 29,888.08   $155,881.81

 
6. Total Value of Written Commitments for In Kind Contributions in Excess of $100 $ 0.00   $0.00

 
7. Total Amount of all Contributions of $100 or less $ 29,447.42   $118,761.59

 
8. Total Amount of All Contributions (Add Lines 1 through 7) $ 3,726,541.40   $7,689,526.60

 
EXPENSES SUMMARY
9. Total Monetary Expenses Paid in Excess of $100 $ 3,600,528.81   $8,315,671.47
 
10. Total Value In Kind Expenses in Excess of $100 $ 29,888.08   $155,881.81
 
11. Total Amount of all Expenses of $100 or less $ 1,457.33   $9,681.58
 
12. Total Amount of All Expenses (Add Lines 9 through 11) $ 3,631,874.22   $8,481,234.86
 
ENDING FUND BALANCE
13. Fund balance at the end of the reporting period  $1859805.16
 
 
AFFIRMATION
 I Declare Under an Oath to God that the Forgoing is True and Correct*
         * A declaration under an oath to God is subject to the same penalties as declaration under penalty of perjury
AND
 I have agreed to the following terms and conditions:

HB 00339
I declare, under penalty of perjury or under an oath to God, that the information I submitted herein to the Secretary of State for the State of
Nevada is true and correct, and is not submitted for any improper purpose, and that I am authorized to submit the information, and to the
best of my knowledge complies with NRS Chapter 294A. I have reviewed the NRS 225.083 Notice. I understand it is unlawful to submit any
illegal, unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or improper information, as defined by state and federal law, to the
Secretary of State, and agree to indemnify the Secretary of State, and any other parties entitled thereto, for any damages incurred for any
unlawful, unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or improper information, as defined by the federal and state law,
submitted to the Secretary of State by my use of this electronic filing system. I further understand that I may be subject to criminal (NRS
239.330) and/or civil (NRS 225.084) penalties for submitting any unlawful unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or
improper information, as defined by federal and state law. I understand and agree that all information submitted is the property of the
Secretary of State, and may be monitored for all lawful purposes. I further understand that during such monitoring, all information, including
personal information placed on this system, may be examined, copied, and used for any authorized purpose. By submitting this report I
intend to identify myself as the authorized person signing this document and with the present intent to authenticate my signature as such.

Cameron Phillips 01/17/2023


Signature Date
 
MONETARY
Report Period   # 4
 
 CONTRIBUTIONS

Joseph Lombardo Governor Clark County


Name (print) Office (if applicable) District (if applicable)

MONETARY CONTRIBUTIONS IN EXCESS OF $100 OR,


WHEN ADDED TOGETHER FROM ONE CONTRIBUTOR, THAT EXCEED $100
(Transfer Total Amount of All Monetary Contributions to Lines 1, 2, or 3, As Applicable, of Contributions Summary)

NAME AND ADDRESS


NAME AND ADDRESS OF PERSON, GROUP
NAME AND ADDRESS OF PERSON, DATE OF AMOUNT OF
CHECK OF 3rd PARTY IF LOAN OR ORGANIZATION
GROUP OR ORGANIZATION WHO CONTRIBUTION
HERE IF GUARANTEED BY 3rd WHO FORGAVE THE
MADE CONTRIBUTION CONTRIBUTION LOAN PARTY LOAN, IF DIFFERENT
THAN CONTRIBUTOR
John Cole 10/06/2022 $4.00
1050 Country Ln
10/06/2022 $100.00  
 
 
Gardnerville, NV 89460
Marvin May
10620 Southern Highlands Pkwy #110-
173 10/06/2022 $5,000.00
 
 
 
Las Vegas, NV 89141
John Boogaard
14003 Leahy Ave 10/06/2022 $250.00
 
 
 
Bellflower, CA 90706
Herb Santos
14205 Prairie Flower Ct Suite C 10/06/2022 $5,000.00
 
 
 
Reno, NV 89501
Sheila Mehrens 10/06/2022 $20.00
 
 
 
1829 Swallow Hill Ave
Henderson, NV 89012 10/23/2022 $2.50
10/23/2022 $10.00

HB 00340
10/31/2022 $10.00
10/31/2022 $10.00
10/31/2022 $20.00
11/02/2022 $25.00
11/06/2022 $25.00
10/06/2022 $150.00
Margaret Vander Laan 10/06/2022 $6.00
1915 Wild Onion Ct
10/23/2022 $6.00

 
 
 
Gardnerville, NV 89410
10/23/2022 $150.00
Burt Clements 10/06/2022 $2,500.00
2050 Dunes Cir
10/10/2022 $500.00

 
 
 
Reno, NV 89509
William Heaton 10/06/2022 $100.00
245 S Bay Harbor Dr
10/06/2022 $25.00

 
 
 
Key Largo, FL 33037
David Fandel 10/06/2022 $100.00
2800 Settlers Bay Ln
10/31/2022 $100.00

 
 
 
Las Vegas, NV 89134
Andrew Polluck
2840 Augusta Dr 10/06/2022 $200.00

 
 
 
Las Vegas, NV 89109
Kevin Tice 10/06/2022 $4.00
2931 Edgemont Dr
10/06/2022 $100.00

 
 
 
Henderson, NV 89074
Thomas McDonald
3 Sable Ridge Ct 10/06/2022 $500.00

 
 
 
Las Vegas, NV 89135
Mark Terry
3256 Ella Lee Ln 10/06/2022 $150.00

 
 
 
Houston, TX 77019
Shandell Auten 10/06/2022 $4.00
3406 Cinnamon Creek Ave
10/06/2022 $100.00

 
 
 
North Las Vegas, NV 89031
Ann Silver 10/06/2022 $100.00

 
 
 
3407 Skyline Blvd
Reno, NV 89509 10/15/2022 $100.00
10/15/2022 $50.00
10/24/2022 $100.00
10/31/2022 $100.00
11/01/2022 $100.00
11/09/2022 $100.00
11/19/2022 $50.00
11/19/2022 $100.00
11/19/2022 $100.00
12/03/2022 $100.00
12/03/2022 $100.00
12/06/2022 $100.00
12/17/2022 $50.00
12/17/2022 $100.00
12/25/2022 $100.00
12/31/2022 $100.00

HB 00341
12/31/2022 $100.00
Mark Hicks 10/06/2022 $100.00
38 Remington Ln
10/23/2022 $100.00

 
 
 
Aliso Viejo, CA 92656
Michael Miranda 10/06/2022 $4.00
421 N Lamb Blvd Unit C
10/06/2022 $100.00

 
 
 
Las Vegas, NV 89110
Elise Carey 10/06/2022 $50.00
4401 Charneta Ct
12/31/2022 $100.00

 
 
 
Las Vegas, NV 89130
10/06/2022 $50.00
10/15/2022 $50.00
10/21/2022 $100.00
Derrek Yelton 10/30/2022 $100.00
4569 Atlantico St
10/31/2022 $100.00

 
 
 
Las Vegas, NV 89135
11/02/2022 $100.00
11/08/2022 $100.00
11/08/2022 $100.00
10/06/2022 $25.00
Elena Boriga Harns 10/06/2022 $100.00
5230 Ithaca Ave
11/06/2022 $100.00

 
 
 
Las Vegas, NV 89122
11/08/2022 $100.00
Paul Mossman
531 Keolu Dr 10/06/2022 $200.00

 
 
 
Kailua, HI 96734
Paolo Tiramani 10/06/2022 $5,000.00
5345 E North Belt Rd
10/06/2022 $5,000.00

 
 
 
Las Vegas, NV 89115
10/06/2022 $62.50

John Jaidinger 10/06/2022 $250.00


601 N Menge Rd 10/15/2022 $25.00

 
 
 
Marengo, IL 60152 10/15/2022 $100.00
10/31/2022 $250.00
10/06/2022 $35.00
Mike Manning 10/15/2022 $25.00
6423 Hook Creek Ct
10/31/2022 $35.00

 
 
 
Las Vegas, NV 89130
11/08/2022 $25.00
Thomas Torrey 10/06/2022 $10.00
6725 W Oquendo Rd
10/06/2022 $250.00
 
 
 
Las Vegas, NV 89118
Daniel Cummings 10/06/2022 $2,000.00
710 Saddlespur Rd
11/01/2022 $500.00
 
 
 
Reno, NV 89511
10/06/2022 $25.00
Lawrence Miller 10/25/2022 $25.00
7081 Magic Moment Ln
10/31/2022 $50.00
 
 
 
Las Vegas, NV 89119
11/06/2022 $50.00
Tyra Bellholland 10/06/2022 $250.00
 
 
 
7226 Estonian Dr
Las Vegas, NV 89113

HB 00342
Bob Canfield 10/06/2022 $100.00
7260 W Azure Dr #140-18
10/15/2022 $100.00

 
 
 
Las Vegas, NV 89130
James Huesing 10/06/2022 $500.00
7452 Jager Ct
10/23/2022 $500.00

 
 
 
Cincinnati, OH 45230
David Contis
774 Mays Blvd 10/06/2022 $500.00

 
 
 
Incline Village, NV 89451
10/06/2022 $50.00
10/06/2022 $2.00
10/15/2022 $50.00

Gregory Jolley 10/15/2022 $2.00


9550 Crassula Pagoda Ave 10/29/2022 $2.00

 
 
 
Las Vegas, NV 89139 10/29/2022 $50.00
10/30/2022 $50.00
10/30/2022 $2.00
11/08/2022 $35.00
Liesl K. Freedman
9804 Piper Glen Pl 10/06/2022 $500.00

 
 
 
Las Vegas, NV 89134
10/06/2022 $50.00
10/06/2022 $2.00
Paul Page 10/23/2022 $2.00
PO Box 18604
10/23/2022 $50.00

 
 
 
Reno, NV 89511
10/31/2022 $50.00
10/31/2022 $12.50
10/06/2022 $100.00
Guy Bowers 10/06/2022 $100.00
PO Box 8090
11/08/2022 $50.00

 
 
 
Ruidoso, NM 88355
11/08/2022 $50.00
Spirit of Virginia 10/07/2022 $5,000.00
PO Box 3950
10/07/2022 $5,000.00

 
 
 
Merrifield, VA 22116
Battle Born Women PAC
PO Box 17041 10/07/2022 $5,000.00

 
 
 
Reno, NV 89511
Coeur Rochester Inc 10/07/2022 $5,000.00
PO Box 1057
12/15/2022 $5,000.00
 
 
 
Lovelock, NV 89419
George Ogilvie
9105 Sandy Bluff Court 10/07/2022 $1,000.00
 
 
 
Las Vegas, NV 89134
Epic Events Group, LLC
8905 West Post Road Ste 200 10/07/2022 $2,500.00
 
 
 
Las Vegas, NV 89148
BM Old Seward LLC 10/07/2022 $5,000.00
7326 West Cheyenne Avenue #120
10/07/2022 $5,000.00
 
 
 
Las Vegas, NV 89129
Blizz Vegas Holdings LLC 10/07/2022 $2,500.00
 
 
 
6975 South Decatur Boulevard #110
Las Vegas, NV 89118

HB 00343
Summit Spirits & Wine 10/07/2022 $5,000.00
6975 South Decatur Boulevard #100
10/07/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
Charles Lilley
520 Southwest Yamhill Street 10/07/2022 $1,000.00

 
 
 
Portland, OR 97204
Claggett & Sykes Law Firm
4101 Meadows Lane #100 10/07/2022 $5,000.00

 
 
 
Las Vegas, NV 89152
Washoe Republican Women
3495 Lakeside Drive #84 10/07/2022 $1,000.00

 
 
 
Reno, NV 89509
Christopher Stimson
35 Hawk Ridge Drive 10/07/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
N&P LV Holdings LLC dba Socks &
Bottoms
10/07/2022 $2,500.00
3545 Las Vegas Boulevard South

 
 
 
Las Vegas, NV 89109
Professional Massage, Inc
3560 Polaris Avenue #18 10/07/2022 $3,000.00

 
 
 
Las Vegas, NV 89103
Charles Watkins
150 Las Vegas Boulevard North #1705 10/07/2022 $2,500.00

 
 
 
Las Vegas, NV 89101
Associated General Contractors Build
PAC 10/07/2022 $5,000.00
150 N. Durango Dr.
10/07/2022 $5,000.00

 
 
 
Ste. 100
Las Vegas, NV 89145
Innovative Food Brands
12207 Los Nietos Road #A 10/07/2022 $2,500.00

 
 
 
Santa Fe Springs, CA 90670
10/10/2022 $4.00
10/10/2022 $100.00

James Kelly 10/15/2022 $100.00


120 Jaunita Dr #24 10/23/2022 $100.00

 
 
 
IIncline Village, NV 89451 10/23/2022 $4.00
10/26/2022 $4.00
10/26/2022 $100.00
Steve Roberts
10300 Huxley Cross Ln 10/10/2022 $250.00  
 
 
Las Vegas, NV 89144
Patrick Mckenna 10/10/2022 $100.00
10391 Tewa Ct
10/10/2022 $4.00
 
 
 
Reno, NV 89511
10/10/2022 $50.00
Allen Simon 10/15/2022 $50.00
1383 N Criss St
11/08/2022 $50.00
 
 
 
Chandler, AZ 85226
11/19/2022 $50.00
10/10/2022 $50.00
Nhien Le
2362 Bellows Place 10/23/2022 $50.00
 
 
 
Woodland, CA 95776 10/31/2022 $25.00

HB 00344
10/10/2022 $25.00
Dennis Houge 10/23/2022 $12.50
2049 Wind Ranch Rd #C
10/31/2022 $20.22

 
 
 
Reno, NV 89521
11/06/2022 $50.00
Timothy Walker
213 Campbell Drive 10/10/2022 $5,000.00

 
 
 
Las Vegas, NV 89107
Bombard Mechanical
3933 West Ali Baba Lane 10/10/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
David Gubler 10/10/2022 $100.00
521 Moutain City Hwy #9
10/10/2022 $4.00

 
 
 
Elko, NV 89801
C.C.B. Enterprises Inc. dba Crisci
Builders
10/10/2022 $5,000.00
5020 East Cartier Avenue

 
 
 
Las Vegas, NV 89115
10/10/2022 $25.00
Marshall Tripp 10/15/2022 $25.00
4616 W Sahara Ave #560
10/23/2022 $20.22

 
 
 
Las Vegas, NV 89102
10/25/2022 $35.00
Jamie Rhodes
765 San Antonio Ranch Road 10/10/2022 $500.00

 
 
 
Washoe Valley, NV 89704
Penn Air Control Inc.
5941 Lakeshore Dr 10/10/2022 $5,000.00

 
 
 
Cypress, CA 90630
Tyler Bennet
9833 Ridge Rock Ct 10/10/2022 $2,500.00

 
 
 
Las Vegas, NV 89134
L Witt
C/O The Witt Family Trust
10/10/2022 $5,000.00
5756 North Rainbow Boulevard

 
 
 
Las Vegas, NV 89130

Vernon Tyerman 10/10/2022 $250.00


PO Box 3791 10/15/2022 $10.00

 
 
 
Incline Village, NV 89450 10/15/2022 $250.00
Astellas Pharma US, Inc.
Astellas Astellas Way 10/11/2022 $5,000.00

 
 
 
Northbrook, IL 60062
T Nickolas Co 10/11/2022 $5,000.00
3710 West Sunset Road
10/11/2022 $5,000.00
 
 
 
Las Vegas, NV 89118
James Pope
3324 Granville Drive 10/11/2022 $2,500.00
 
 
 
Raleigh, NC 27609
Christopher Vito
1316 Eagle Meadow Court 10/11/2022 $1,000.00
 
 
 
Las Vegas, NV 89123
Joyce Seeco
10269 Copper Cloud Drive 10/11/2022 $250.00
 
 
 
Reno, NV 89511
David Hockaday 10/11/2022 $250.00
 
 
 
12 Juanita Lane
Smith Valley, NV 89444

HB 00345
i3 Public Affairs 10/13/2022 $5,000.00
1575 Delucchi Lane
10/13/2022 $500.00

 
 
 
Reno, NV 89502
Npm & Csa 10/13/2022 $4,500.00
1575 Delucchi Lane #201
10/13/2022 $5,000.00

 
 
 
Reno, NV 89502
Amt Investments 10/14/2022 $5,000.00
1627 U.S. Highway 395 North
10/14/2022 $5,000.00

 
 
 
Minden, NV 89423
Steven Loye
1410 Webster Way 10/14/2022 $1,000.00

 
 
 
Reno, NV 89509
The Ferraro Group 10/14/2022 $5,000.00
165 West Liberty Street #210
10/14/2022 $2,500.00

 
 
 
Reno, NV 89501
Guy Nohra
16880 Salut Court 10/14/2022 $3,000.00

 
 
 
Reno, NV 89511
Republican Governors Association
1747 Pennsylvania Avenue Northwest 10/14/2022 $5,000.00
Suite 250 10/14/2022 $5,000.00

 
 
 
Washington, DC 20006
Cafe Leone LLC dba Cafe Leone 10/14/2022 $5,000.00
1215 South Fort Apache Road #120
10/14/2022 $5,000.00

 
 
 
Las Vegas, NV 89117
Sahara Center LLC 10/14/2022 $5,000.00
1215 South Fort Apache Road #120
10/14/2022 $5,000.00

 
 
 
Las Vegas, NV 89117
Gregor Jackson 10/14/2022 $5,000.00
10080 Alta Drive #101
10/14/2022 $5,000.00

 
 
 
Las Vegas, NV 89145
Richard Haddrill
10 Ridge Blossom Road 10/14/2022 $3,000.00

 
 
 
Las Vegas, NV 89135
Lance Bradford
3145 Saint Rose Parkway #200 10/14/2022 $3,750.00

 
 
 
Henderson, NV 89052
Leilani Bradford
3145 Saint Rose Parkway #200 10/14/2022 $3,750.00

 
 
 
Henderson, NV 89052
Village At St Rose LLC
3145 Saint Rose Parkway #200 10/14/2022 $2,500.00
 
 
 
Henderson, NV 89052
Andy Russo Jr., Inc.
3030 Valley View Blvd. 10/14/2022 $2,500.00
 
 
 
Las Vegas, NV 89102
George Lee
311 Greenwich Street #4H 10/14/2022 $200.00
 
 
 
New York, NY 10013
Chris Davidson
306 Rosegate Avenue 10/14/2022 $5,000.00
 
 
 
Henderson, NV 89052
JDC I LLC 10/14/2022 $5,000.00
2505 Anthem Village Drive #E-594
10/14/2022 $5,000.00
 
 
 
Henderson, NV 89052

HB 00346
Crovetti Bone and Joint Institute of
Southern Nevada Ltd 10/14/2022 $5,000.00
2779 West Horizon Ridge Parkway
10/14/2022 $5,000.00

 
 
 
#200
Henderson, NV 89052
Rapid Tote Systems LLC
2450 Saint Rose Parkway #200 10/14/2022 $5,000.00

 
 
 
Henderson, NV 89074
Lisa Manning
381 Rancho Rosario Court 10/14/2022 $500.00

 
 
 
Las Vegas, NV 89138
Golssa Moridi 10/14/2022 $5,000.00
405 Royalton Drive
10/14/2022 $4,000.00

 
 
 
Las Vegas, NV 89144
DRZ, Inc.
3970 Ponderosa Way 10/14/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
Power Parent Inc
400 South 4th Street
10/14/2022 $200.00
3rd floor

 
 
 
Las Vegas, NV 89101
Jill Straub
426 Mountain Lake Court 10/14/2022 $350.00

 
 
 
Incline Village, NV 89451
Edward Stockton 10/14/2022 $5,000.00
44 Emerald Dunes Circle
10/14/2022 $5,000.00

 
 
 
Henderson, NV 89052
E-z Management Group LLC
5160 South Rogers Street 10/14/2022 $2,000.00

 
 
 
Las Vegas, NV 89118
General Design & Construction Co Inc
5160 South Rogers Street 10/14/2022 $2,000.00

 
 
 
Las Vegas, NV 89118
Bumble Breeze Plumbing
5130 South Valley View Boulevard, 10/14/2022 $5,000.00
#112

 
 
 
Las Vegas, NV 89118
Buenos Aires Air Conditioning &
Heating Inc 10/14/2022 $5,000.00
5200 Vegas Drive

 
 
 
Las Vegas, NV 89108
Albert Pistritto
5345 North Campbell Road 10/14/2022 $500.00

 
 
 
Las Vegas, NV 89149
Roxanne Caviola
5 Paradise Valley Court 10/14/2022 $500.00
 
 
 
Henderson, NV 89052
Paul W. Robarts
6450 Spring Mountain Road Ste. 12 10/14/2022 $5,000.00
 
 
 
Las Vegas, NV 89146

Paul Skittone 10/14/2022 $1,000.00


7 Cambria St 10/26/2022 $100.00
 
 
 
Staten Island, NY 10305
10/31/2022 $25.00
NextEra Energy Resources LLC
700 Universe Boulevard 10/14/2022 $10,000.00
 
 
 
Juno Beach, FL 33408
Las Vegas Motor Speedway 10/14/2022 $1,000.00
 
 
 
7000 Las Vegas Boulevard North

HB 00347
Las Vegas, NV 89115
Kenneth D. Goodrich
9324 Canyon Classic Drive 10/14/2022 $10,000.00

 
 
 
Las Vegas, NV 89144
Wendy A. Garner
9324 Canyon Classic Drive 10/14/2022 $10,000.00

 
 
 
Las Vegas, NV 89144
Richard Warneka
PO Box 30973 10/14/2022 $1,000.00

 
 
 
Laughlin, NV 89028
Pegram LLC 10/14/2022 $5,000.00
PO Box 9
10/14/2022 $5,000.00

 
 
 
Minden, NV 89423
Elizabeth McGinnis
PO Box 777637 10/14/2022 $2,900.00

 
 
 
Henderson, NV 89077
Fred Muhs
PO Box 778148 10/14/2022 $2,900.00

 
 
 
Henderson, NV 89077
Cathay Development Corp
PO Box 80898 10/14/2022 $1,500.00

 
 
 
Las Vegas, NV 89180
Christina M. Strickland LLC
PO Box 94924 10/14/2022 $5,000.00

 
 
 
Las Vegas, NV 89193
Delia Ross 10/15/2022 $4.00
PO Box 81496
10/15/2022 $100.00

 
 
 
Las Vegas, NV 89180
10/15/2022 $12.50

ernest aguirre 10/15/2022 $50.00


PO Box 33359 10/29/2022 $35.00

 
 
 
Laughlin, NV 89028 11/08/2022 $6.25
11/08/2022 $25.00
Andrea Carlton 10/15/2022 $5,000.00
PO Box 58258
10/15/2022 $5,000.00

 
 
 
Nashville, TN 37205
Ryan Erwin
9500 W Flamingo #203 10/15/2022 $2,500.00

 
 
 
Las Vegas, NV 89147
Mike Slanker
9045 Waterfield Ct 10/15/2022 $1,000.00
 
 
 
Las Vegas, NV 89134
Wiilliam Cockerell
Box 1637 10/15/2022 $250.00
 
 
 
Zephyr Cove, NV 89448
10/15/2022 $10.00
10/15/2022 $250.00
Malcolm Wittig 10/24/2022 $100.00
HC 60 Box 50
11/02/2022 $50.00
 
 
 
Wells, NV 89835
11/08/2022 $50.00
11/08/2022 $100.00
Tom Ahlborn 10/15/2022 $250.00
 
 
 
9808 Old Camp Ln
Windsor, CA 95492

HB 00348
Steve Capp
9811 W Charleston Blvd #2296 10/15/2022 $500.00

 
 
 
Las Vegas, NV 89117
Brett Tibbitts
PO Box 10600 10/15/2022 $250.00

 
 
 
Zephyr Cove, NV 89448
Lacy Williams 10/15/2022 $50.00
NP63 Lake Cherokee
10/15/2022 $1,000.00

 
 
 
Longview, TX 75603

Judith Otto 10/15/2022 $2.00


6755 Quaking Aspen Rd 10/15/2022 $50.00

 
 
 
Reno, NV 89510
10/31/2022 $50.00

Paul Petrucelly 10/15/2022 $50.00


7445 E Eaglecrest 11/06/2022 $50.00

 
 
 
Mesa, AZ 85207 11/08/2022 $100.00
10/15/2022 $2.00
Thomas Macdiarmid 10/15/2022 $50.00
7506 Ulysses Dr
11/01/2022 $2.00

 
 
 
Sparks, NV 89436
11/01/2022 $50.00
10/15/2022 $100.00
10/15/2022 $4.00
Patti Carter 10/23/2022 $102.43
7671 Gracemoor Ct
10/31/2022 $100.00

 
 
 
Las Vegas, NV 89149
11/19/2022 $102.43
12/17/2022 $102.43
10/15/2022 $50.00
Paula Hammack
8300 Mooses Ct 11/19/2022 $50.00

 
 
 
Las Vegas, NV 89131
12/17/2022 $50.00
Lisa Cannito
8560 S Miller Ln 10/15/2022 $1,000.00

 
 
 
Las Vegas, NV 89113
Walt Walters 10/15/2022 $250.00
6688 Valley View Rdg Ct
11/19/2022 $250.00

 
 
 
Las Vegas, NV 89110
Orestes Guerra 10/15/2022 $100.00
6063 Stone Rise St
10/15/2022 $4.00
 
 
 
Las Vegas, NV 89135
Stephen E. Thorne 10/15/2022 $5,000.00
621 Majestic Rim
10/15/2022 $5,000.00
 
 
 
Henderson, NV 89012
10/15/2022 $2.00
Teresa Mogg 10/15/2022 $50.00
5912 Karnes Ranch Ave
10/29/2022 $2.00
 
 
 
Las Vegas, NV 89131
10/29/2022 $50.00
William Crozer
601 13th St NW, 11th Floor S 10/15/2022 $1,000.00
 
 
 
Washington, DC 20005
John Alex
540 Christina Dr 10/15/2022 $250.00
 
 
 
Saint Augustine, FL 32086

HB 00349
Richard Florino 10/15/2022 $100.00
58 Blackstone Dr
10/15/2022 $25.00

 
 
 
Raymond, NH 3077
Craig Podesta
585 Lakeshore Blvd 10/15/2022 $250.00

 
 
 
Incline Village, NV 89451
Charlie Shalvoy
59 Damonte Ranch Pkwy #B-598 10/15/2022 $250.00

 
 
 
Reno, NV 89521
Mary Weneta 10/15/2022 $10.00
4205 Longknife Rd
10/15/2022 $250.00

 
 
 
Reno, NV 89519
Paula Reber
3809 Old Orchard Ct 10/15/2022 $150.00

 
 
 
Las Vegas, NV 89108
Joseph Dutra 10/15/2022 $250.00
405 Edison Way
10/15/2022 $10.00

 
 
 
Reno, NV 89502
10/15/2022 $1.00
10/15/2022 $25.00
10/24/2022 $5.00
Martha Peralta
2421 Oak Ridge Dr 10/24/2022 $20.00

 
 
 
Carson City, NV 89703 10/24/2022 $25.00
10/31/2022 $25.00
11/08/2022 $10.00
Michael Cirillo
2321 East 4th St 10/15/2022 $5,000.00

 
 
 
Santa Ana, CA 92705
10/15/2022 $100.00
10/15/2022 $25.00
Larry Morris 10/23/2022 $4.00
220 Desert Rose Ct
10/23/2022 $100.00

 
 
 
Boulder City, NV 89005
10/24/2022 $100.00
10/31/2022 $100.00

George E McCall 10/15/2022 $100.00


218 Via D Este#1308 11/19/2022 $100.00

 
 
 
Delray Beach, FL 33445 12/17/2022 $100.00

Kyle Stephens 10/15/2022 $500.00


2231 S Monte Cristo Way 10/23/2022 $1,000.00
 
 
 
Las Vegas, NV 89117 10/23/2022 $500.00
James Gregory 10/15/2022 $500.00
2110 Pratt Dr
10/15/2022 $20.00
 
 
 
Elko, NV 89801
Daniel Hughes
2005 Fern Hill Ct 10/15/2022 $250.00
 
 
 
Henderson, NV 89052
John O'Donnell
2065 Eaglepath Cir 10/15/2022 $150.00
 
 
 
Henderson, NV 89074
Brad Mora 10/15/2022 $100.00
 
 
 
2090 Rice Rd
Fallon, NV 89406 10/25/2022 $50.00

HB 00350
10/15/2022 $20.00
10/15/2022 $20.00
10/23/2022 $20.22

C. Edward Cotton 10/31/2022 $20.22


1919 Racine Dr 11/08/2022 $20.00

 
 
 
Las Vegas, NV 89156 11/19/2022 $20.00
12/03/2022 $20.22
12/17/2022 $20.00
12/17/2022 $20.00

Cameron Hopkins 10/15/2022 $100.00


194 Mount St Helens 11/19/2022 $100.00

 
 
 
Henderson, NV 89012 12/17/2022 $100.00
Ali Shahrestani
20 Meadowhawk Ln 10/15/2022 $2,000.00

 
 
 
Las Vegas, NV 89135
Juliane Tran
2011 Pray St 10/15/2022 $1,000.00

 
 
 
Fullerton, CA 92833
Vicki Paulbick
2980 S Jones Blvd 10/15/2022 $250.00

 
 
 
Las Vegas, NV 89146
10/15/2022 $50.00
Jim Battista 10/31/2022 $100.00
284C E Lake Mead Pkwy
11/19/2022 $50.00

 
 
 
Henderson, NV 89015
12/17/2022 $50.00

Thomas Claridge 10/15/2022 $100.00


2878 Quartz Cyn Dr 10/25/2022 $50.00

 
 
 
Henderson, NV 89052 10/26/2022 $100.00
Heather Mercer
2857 Paradise Rd #3001 10/15/2022 $5,000.00

 
 
 
Las Vegas, NV 89109
Yolanda Sargent 10/15/2022 $5,000.00
28 Panorama Crest Ave
10/15/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Robert Laurie 10/15/2022 $500.00
2808 Kimberlite Rd
10/24/2022 $200.00
 
 
 
Sparks, NV 89436
10/15/2022 $12.50
Paul Sherman 10/15/2022 $50.00
3250 Orange Sun St
10/31/2022 $50.00
 
 
 
Las Vegas, NV 89135
11/05/2022 $100.00
Terry Coffing 10/15/2022 $4.00
10001 Park Run Dr
10/15/2022 $100.00
 
 
 
Las Vegas, NV 89145
Della Bynum 10/15/2022 $500.00
10128 Indian Ridge Dr
10/15/2022 $20.00
 
 
 
Reno, NV 89511
Randi Thompson
12575 Overbrook Dr 10/15/2022 $250.00
 
 
 
Reno, NV 89511

HB 00351
Michael Grodzicki 10/15/2022 $50.00
115 Crestview Ct 10/24/2022 $50.00

 
 
 
San Carlos, CA 94070 11/01/2022 $35.00
Lou Tarter
11524 Bohemian Forest 10/15/2022 $1,000.00

 
 
 
Las Vegas, NV 89138
10/15/2022 $20.00

Carla Slagle 10/23/2022 $20.00


11197 Antonine Wall Ct 10/29/2022 $25.00

 
 
 
Las Vegas, NV 89141 11/08/2022 $50.00
11/08/2022 $35.00
Robert Cummins 10/15/2022 $100.00
1685 Apple Blossom Dr
10/15/2022 $4.00

 
 
 
Cumming, GA 30041
Nord Andresen
1700 Shattuck Ave #107 10/15/2022 $250.00

 
 
 
Berkeley, CA 94709
Michael Shetler 10/15/2022 $250.00
1845 Rustling Oaks Ln
10/15/2022 $10.00

 
 
 
Prescott, AZ 86303
Wells Cargo Inc
10191 West Park Run Drive 10/18/2022 $5,000.00

 
 
 
Las Vegas, NV 89145
NV First 10/18/2022 $5,000.00
316 California Avenue #519
10/18/2022 $4,000.00

 
 
 
Reno, NV 89509
Sean McConnell
2855 Dalsetter Drive 10/18/2022 $2,000.00

 
 
 
Henderson, NV 89044
Marion Camp
2702 Wind Feather Trail 10/18/2022 $250.00

 
 
 
Reno, NV 89511
Matthew Ricciardella
2212 Paiute Meadows Drive 10/18/2022 $3,500.00

 
 
 
Las Vegas, NV 89134
Brian Chapman
3701 Freightliner Drive 10/18/2022 $1,500.00

 
 
 
North Las Vegas, NV 89081
Henderson Chamber Of Commerce
IMPAC 10/18/2022 $2,500.00
590 South Boulder Highway  
 
 
Henderson, NV 89015
Champions Tavern LLC dba Aces East
7272 South El Capitan Way 10/18/2022 $1,500.00
 
 
 
Las Vegas, NV 89148
Encore Commercial Inc
7272 South El Capitan Way 10/18/2022 $1,000.00
 
 
 
Las Vegas, NV 89148
Encore Real Estate Services Inc dba
Home Smart Encore 10/18/2022 $500.00
7272 South El Capitan Way
 
 
 
Las Vegas, NV 89148
Wedgies Sports Bar LLC
7272 South El Capitan Way 10/18/2022 $1,500.00
 
 
 
Las Vegas, NV 89148

HB 00352
Raising The Kilt LLC
7272 South El Capitan Way #2 10/18/2022 $1,500.00

 
 
 
Las Vegas, NV 89148
Rajarataka LLC
7272 South El Capitan Way #2 10/18/2022 $1,000.00

 
 
 
Las Vegas, NV 89148
National Association of Insurance &
Financial Advisors PAC 10/18/2022 $500.00
9187 West Flamingo Road

 
 
 
Las Vegas, NV 89147
Urban Jungle Contractors Ltd
PO Box 60609 10/18/2022 $250.00

 
 
 
Boulder City, NV 89006
Pj2Investments LLC 10/19/2022 $1,500.00
PO Box 777926
12/27/2022 $1,500.00

 
 
 
Henderson, NV 89077
Truline Corporation 10/19/2022 $5,000.00
9390 Redwood Street
10/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89139
RJS Inc 10/19/2022 $5,000.00
9777 South Las Vegas Boulevard
10/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89183
James Daniel Carpenter 10/19/2022 $5,000.00
2505 Anthem Village Drive #E594
10/19/2022 $5,000.00

 
 
 
Henderson, NV 89052
Eye & Cosmetic Surgery LLC 10/19/2022 $5,000.00
2505 Anthem Village Drive #E-594
10/19/2022 $5,000.00

 
 
 
Henderson, NV 89052
Edgewater Gaming LLC 10/19/2022 $5,000.00
2020 South Casino Drive
10/19/2022 $5,000.00

 
 
 
Laughlin, NV 89029
Aquarius Casino Resort 10/19/2022 $5,000.00
1900 South Casino Drive
10/19/2022 $5,000.00

 
 
 
Laughlin, NV 89029
American Comeback Committee
10/20/2022 $5,000.00
1747 Pennsylvania Avenue Northwest
Suite 1747 10/20/2022 $5,000.00

 
 
 
Washington, DC 20006
Andrea Hendrick
14 Sable Ridge Court 10/21/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Kirk Hendrick
14 Sable Ridge Court 10/21/2022 $5,000.00
 
 
 
Las Vegas, NV 89135
Pain & Orthopedic Of Southern
Nevada
10/21/2022 $2,000.00
1485 East Flamingo Road
 
 
 
Las Vegas, NV 89119
Appiah Tours Inc
10161 West Park Run Drive #150 10/21/2022 $1,000.00
 
 
 
Las Vegas, NV 89145
Red Arrow Marketing LLC 10/21/2022 $5,000.00
10777 West Twain Avenue #215
10/21/2022 $5,000.00
 
 
 
Las Vegas, NV 89135
Jerry Wenger
1090 Road 10 10/21/2022 $2,900.00
 
 
 
Powell, WY 82435

HB 00353
Damon Young
11212 Campsie Fells Court 10/21/2022 $200.00

 
 
 
Las Vegas, NV 89141
WJS Consulting LLC
11035 Lavender Hill Drive #160-524 10/21/2022 $250.00

 
 
 
Las Vegas, NV 89135
Jing Las Vegas 10/21/2022 $1,500.00
10975 Oval Park Drive #100
11/02/2022 $2,500.00

 
 
 
Las Vegas, NV 89135
Patrick McNulty
10981 Keymar Drive 10/21/2022 $250.00

 
 
 
Las Vegas, NV 89135
Capital Healthcare Solutions
11700 West Charleston Boulevard 10/21/2022 $1,000.00
#170-220

 
 
 
Las Vegas, NV 89135
Lori Chavez
11280 Granite Ridge Drive #1045 10/21/2022 $500.00

 
 
 
Las Vegas, NV 89135
Meow LLC
195 East Reno Avenue #A 10/21/2022 $2,500.00

 
 
 
Las Vegas, NV 89119
Donald Weir 10/21/2022 $5,000.00
2250 Del Monte Lane
10/21/2022 $5,000.00

 
 
 
Reno, NV 89511
James B Manning
2680 Crimson Canyon Drive 10/21/2022 $1,000.00

 
 
 
Las Vegas, NV 89128
Cook's Truck & Tractor LLC 10/21/2022 $5,000.00
2590 Nature Park Drive #200
10/21/2022 $5,000.00

 
 
 
North Las Vegas, NV 89084
Patriot Contractors LLC 10/21/2022 $5,000.00
2590 Nature Park Drive #200
10/21/2022 $5,000.00

 
 
 
North Las Vegas, NV 89084
Strategic Medical Management LLC
3050 Raywood Ash Drive 10/21/2022 $2,000.00

 
 
 
Las Vegas, NV 89138
Frontline Medical Group LLC dba
Sassan Kevah MD
10/21/2022 $500.00
3150 North Tenaya Way #400

 
 
 
Las Vegas, NV 89128
Omni Limousine Inc
335 Bond Street 10/21/2022 $2,500.00
 
 
 
Brooklyn, NY 11231
Ryan Alexander Chtd
3017 West Charleston Boulevard #58 10/21/2022 $500.00
 
 
 
Las Vegas, NV 89102
LBC Law Group
723 South 7th Street 10/21/2022 $150.00
 
 
 
Las Vegas, NV 89101
Balle Management 10/21/2022 $5,000.00
8213 Long Buffalo Avenue
10/21/2022 $5,000.00
 
 
 
Las Vegas, NV 89131
Donna A Ruthe 10/21/2022 $5,000.00
7904 Rockwind Court
10/21/2022 $5,000.00
 
 
 
Las Vegas, NV 89117

HB 00354
Randolph Townsend
8 Quail Run Road 10/21/2022 $5,000.00

 
 
 
Henderson, NV 89014
Robyne Brooks Townsend
8 Quail Run Road 10/21/2022 $5,000.00

 
 
 
Henderson, NV 89014
Sierra Medical Services LLC
8068 West Sahara Avenue # C 10/21/2022 $2,500.00

 
 
 
Las Vegas, NV 89117
Jefferies Company Inc
8068 West Sahara Avenue #C 10/21/2022 $2,500.00

 
 
 
Las Vegas, NV 89117
Retail Concepts Corporations
5415 Cameron Street #119 10/21/2022 $2,000.00

 
 
 
Las Vegas, NV 89118
Jo Ann Acres 10/21/2022 $5,000.00
64 Tapadero Lane
10/21/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
John Acres 10/21/2022 $5,000.00
64 Tapadero Lane
10/21/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Acres 4 0 10/21/2022 $5,000.00
6415 South Tenaya Way #110
10/21/2022 $5,000.00

 
 
 
Las Vegas, NV 89113
Acres Manufacturing Company 10/21/2022 $5,000.00
6415 South Tenaya Way #110
10/21/2022 $5,000.00

 
 
 
Las Vegas, NV 89113
Acres Technology 10/21/2022 $5,000.00
6415 South Tenaya Way #110
10/21/2022 $5,000.00

 
 
 
Las Vegas, NV 89113
Brian M Collins
3670 West Oquendo Road 10/21/2022 $2,000.00

 
 
 
Las Vegas, NV 89118
William Weinberger
3754 Mesa Linda Drive 10/21/2022 $1,000.00

 
 
 
Las Vegas, NV 89120
AK Global Investment LLC
4495 West Hacienda Avenue #1 10/21/2022 $2,000.00

 
 
 
Las Vegas, NV 89118
10/21/2022 $5,000.00
XL Concrete Masonry LLC 10/21/2022 $5,000.00
4460 Riviera Ridge Avenue
10/21/2022 $5,000.00  
 
 
Las Vegas, NV 89115
10/21/2022 $5,000.00
NV Chiropractic Rehab Center
3900 West Charleston Boulevard #140 10/21/2022 $1,500.00
 
 
 
Las Vegas, NV 89102
Desert Cab LLC
4675 Wynn Rd. 10/21/2022 $5,000.00
 
 
 
Las Vegas, NV 89103
Derrick Warfel
PO Box 3448 10/21/2022 $900.00
 
 
 
Tequesta, FL 33469
Lazaro R Chavez
PO Box 370187 10/21/2022 $500.00
 
 
 
Las Vegas, NV 89137

HB 00355
Vincent Laurenzo 10/23/2022 $100.00
PO Box 2157
10/29/2022 $100.00

 
 
 
Ballston Spa, NY 12020
NV Auto Dealers Election Action
Committee 10/23/2022 $5,000.00
PO Box 7320

 
 
 
Reno, NV 89501
10/23/2022 $50.00

Buddy Manwill 10/23/2022 $2.00


PO Box 90884 10/24/2022 $20.22

 
 
 
Henderson, NV 89009 10/31/2022 $50.00
12/03/2022 $20.22

Mike Korlin 10/23/2022 $100.00


PO Box 5229 10/23/2022 $50.00

 
 
 
Sevierville, TN 37864
10/23/2022 $100.00
Mynda Smith 10/23/2022 $200.00
9825 Glenrock
10/23/2022 $5,000.00

 
 
 
Las Vegas, NV 89134
Stanley Van Vleck
PO Box 1878 10/23/2022 $2,500.00

 
 
 
Crystal Bay, NV 89402
Pawan Agrawal 10/23/2022 $100.00
9392 Jeremy Blaine Ct
10/31/2022 $100.00

 
 
 
Las Vegas, NV 89139
10/23/2022 $100.00

Paul Latour 10/23/2022 $25.00


9434 Grand Isle 10/23/2022 $4.00

 
 
 
Houston, TX 77044
10/23/2022 $25.00
10/29/2022 $25.00
Desert Institute of Spine Care
9339 West Sunset Road 10/23/2022 $2,000.00
Suite 100

 
 
 
Las Vegas, NV 89148
Marshall Hunt
8258 San Fernando Way 10/23/2022 $5,000.00

 
 
 
Dallas, TX 75218
Frederick Zimmerman
5 Hedwig Cir 10/23/2022 $250.00

 
 
 
Houston, TX 77024
Fabulous Freddy's Car Wash 10/23/2022 $5,000.00
4350 S Durango
10/23/2022 $200.00
 
 
 
Las Vegas, NV 89147
Shannon Petersen
4380 Maltese Crest Cir 10/23/2022 $1,000.00
 
 
 
Las Vegas, NV 89129
James Upton 10/23/2022 $100.00
4190 Houston Dr
10/23/2022 $4.00
 
 
 
Reno, NV 89502
William Jacob 10/23/2022 $100.00
4471 Dean Martin Dr #1406
10/23/2022 $4.00
 
 
 
Las Vegas, NV 89103
Danny Sanders
440 E Paradise Hills Dr 10/23/2022 $1,000.00
 
 
 
Henderson, NV 89002

HB 00356
10/23/2022 $30.00
GENE KRAMETBAUER 10/23/2022 $750.00
4450 PALISADES CANYON CIR
11/08/2022 $250.00

 
 
 
LAS VEGAS, NV 89129
11/08/2022 $10.00
Chad Christensen 10/23/2022 $5,000.00
3750 Las Vegas Blvd S #3508
10/23/2022 $5,000.00

 
 
 
Las Vegas, NV 89158
Daniel Brasov 10/23/2022 $5,000.00
3750 Las Vegas Blvd S #3508
10/23/2022 $5,000.00

 
 
 
Las Vegas, NV 89158
David Belding
395 E Sunset Rd 10/23/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
Richard Fabbro
38 Bretton Rd 10/23/2022 $250.00

 
 
 
Scarsdale, NY 10583
David Blumberg 10/23/2022 $2,000.00
415 Centre Island
10/29/2022 $1,000.00

 
 
 
Golden Beach, FL 33160
Alex Boggs 10/23/2022 $2,500.00
4159 Dover Rd
10/23/2022 $100.00

 
 
 
La Canada Flintridge, CA 91011
Robert Bagnato 10/23/2022 $10.00
40 Autumn Ln
10/23/2022 $250.00

 
 
 
Reno, NV 89511
Tom Klauer 10/23/2022 $500.00
330 Juniper Hill Rd
10/31/2022 $250.00

 
 
 
Reno, NV 89519
Tom Fourre
3514 McPherson St 10/23/2022 $500.00

 
 
 
Waxhaw, NC 28173
Scott Loughridge
3579 Red Rock St 10/23/2022 $2,000.00

 
 
 
Las Vegas, NV 89103
Lee Eliseian 10/23/2022 $500.00
3681 Mayberry Dr
10/31/2022 $500.00

 
 
 
Reno, NV 89509
Richard Schank 10/23/2022 $100.00
6162 Ocean View Dr
10/31/2022 $100.00

 
 
 
Oakland, CA 94618
Kenneth Alber 10/23/2022 $80.00
619 Cityview Ridge Dr
10/23/2022 $2,000.00
 
 
 
Henderson, NV 89012
James Buckley 10/23/2022 $100.00
6116 Blossom Knoll Ave
10/23/2022 $4.00
 
 
 
Las Vegas, NV 89085
Linda Carper 10/23/2022 $250.00
613 Rabbit Ridge Ct
10/23/2022 $10.00
 
 
 
Reno, NV 89511

Andy Masi 10/23/2022 $5,000.00


6445 S Teneya Way #150 10/23/2022 $400.00
 
 
 
Las Vegas, NV 89113 10/23/2022 $5,000.00
Creel Holdco LLC DBA Creel 10/23/2022 $5,000.00
 
 
 
6330 West Sunset Road

HB 00357
Las Vegas, NV 89118
Ronald Brooks 10/23/2022 $1,000.00
5655 Silver Creek Valley Dr #311
10/23/2022 $40.00

 
 
 
San Jose, CA 95138
Edward Stevenson 10/23/2022 $250.00
6000 Cartier Dr
10/23/2022 $10.00

 
 
 
Reno, NV 89511
John Turco 10/23/2022 $1,000.00
815 S Casino Center Blvd
10/23/2022 $40.00

 
 
 
Las Vegas, NV 89101
10/23/2022 $50.00
Kenneth Kleeman
7996 Oak Creek Dr 11/26/2022 $50.00

 
 
 
Reno, NV 89511
12/25/2022 $50.00
Michelle Koski
7635 Devonshire Ln 10/23/2022 $150.00

 
 
 
Reno, NV 89511
10/23/2022 $50.00
Jae Park 10/23/2022 $2.00
8657 W Sahara Ave
10/30/2022 $100.00

 
 
 
Las Vegas, NV 89117
10/30/2022 $4.00
Terrance Shirey
750 E Warm Springs Rd 10/23/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
David Semas 10/23/2022 $100.00
7 Marisol
10/23/2022 $2,500.00

 
 
 
Newport Coast, CA 92657
Theresa Santos 10/23/2022 $50.00
3005 Rustic Manor Cir
12/31/2022 $500.00

 
 
 
Reno, NV 89509
Cory Santos 10/23/2022 $200.00
3005 Rustic Manor Cir
12/31/2022 $500.00

 
 
 
RENO, NV 89509
Elizabeth Coyne
2595 Painted River Trail 10/23/2022 $500.00

 
 
 
Reno, NV 89523
Janice Colvin 10/23/2022 $200.00
2549 Sun Reef Rd
10/23/2022 $5,000.00

 
 
 
Las Vegas, NV 89128
Jill Bell
2785 Josephine Dr 10/23/2022 $500.00
 
 
 
Henderson, NV 89044
James Clark
2777 Paradise Rd #3701 10/23/2022 $1,000.00
 
 
 
Las Vegas, NV 89109
10/23/2022 $100.00
10/23/2022 $100.00
Gordon Zumwalt 10/23/2022 $4.00
2866 Rio Vista Dr
10/23/2022 $4.00
 
 
 
Minden, NV 89423
10/26/2022 $100.00
10/26/2022 $4.00
William Sullivan
2877 Paradise Rd 10/23/2022 $2,500.00
 
 
 
Las Vegas, NV 89109

HB 00358
James Fuchs
2901 Red Arrow Dr 10/23/2022 $1,000.00

 
 
 
Las Vegas, NV 89135
Rick Thomas 10/23/2022 $1,000.00
2939 Moose Ridge Dr
10/23/2022 $40.00

 
 
 
Reno, NV 89523
Sean Hoel
2405 Northshore Dr 10/23/2022 $250.00

 
 
 
Reno, NV 89519
Nathan Judd
242 Terragona Breeze Dr 10/23/2022 $500.00

 
 
 
Las Vegas, NV 89138
Micah Phillips 10/23/2022 $20.00
1958 Larkspur Ranch Ct
10/23/2022 $500.00

 
 
 
Henderson, NV 89012
10/23/2022 $2.00
Elaine Lazell 10/23/2022 $50.00
12 Mashie Ct
10/24/2022 $25.00

 
 
 
Springfield, IL 62707
10/31/2022 $50.00
Stephen Seink
12 Spellbound Ct 10/23/2022 $1,000.00

 
 
 
Henderson, NV 89012
Ginny Wood
13 S High Point Rd 10/23/2022 $150.00

 
 
 
Round Lake, IL 60073
Michael Lane
12024 Vento Forte Ave 10/23/2022 $250.00

 
 
 
Las Vegas, NV 89138
Patrick Migliorini 10/23/2022 $100.00
1213 S Gertruda Ave
10/23/2022 $4.00

 
 
 
Redondo Beach, CA 90277
Buenas Noches LLC
10845 Griffith Peak Drive #520 10/23/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Erna Bailey
1045 Desert Jewel Ct 10/23/2022 $150.00

 
 
 
Reno, NV 89511
Artistic Iron Works
105 W Charleston Blvd 10/23/2022 $5,000.00

 
 
 
Las Vegas, NV 89102
Amber Turner
1008 Marsha Ln 10/23/2022 $1,000.00  
 
 
Gardnerville, NV 89460
Tamara Patrick 10/23/2022 $250.00
10128 Via Verona
10/23/2022 $10.00
 
 
 
Reno, NV 89511
Jlynn Grahamnair 10/23/2022 $50.00
15250 Ashwood Ln
11/08/2022 $250.00
 
 
 
Chino Hills, CA 91709
David Sajdak 10/23/2022 $4.00
1500 S 6th St
10/23/2022 $100.00
 
 
 
Las Vegas, NV 89104
Cristi Milazzo 10/23/2022 $100.00
1638 Broken Bow Rd
10/23/2022 $2,500.00
 
 
 
Gardnerville, NV 89410

HB 00359
Ying Yu 10/23/2022 $20.00
14170 Squirrel Hollow Ln
10/23/2022 $500.00

 
 
 
Saratoga, CA 95070
Alan Hilton 10/23/2022 $100.00
143 Denio Dr
10/23/2022 $4.00

 
 
 
Dayton, NV 89403
Mynda Smith 10/23/2022 $5,000.00
18 Garden Rain Dr
10/23/2022 $200.00

 
 
 
Las Vegas, NV 89135
10/23/2022 $125.00
10/24/2022 $75.00
Rima Demarais
170 Imperial Ave 11/02/2022 $100.00

 
 
 
Westport, CT 6880
11/06/2022 $50.00
11/06/2022 $2.00

Daniel McGrath 10/23/2022 $50.00


1881 Stablegate Ave 10/23/2022 $2.00

 
 
 
Henderson, NV 89012 10/30/2022 $100.00
Mitchell Ogron
1918 Bannie Ave 10/23/2022 $5,000.00

 
 
 
Las Vegas, NV 89102
Kathy Siegfried
1830 Masters Way 10/23/2022 $2,500.00

 
 
 
Chadds Ford, PA 19317
Robert Siegfried
1830 Masters Way 10/23/2022 $2,500.00

 
 
 
Chadds Ford, PA 19317
Michael Melnicke
1637 50th St 10/24/2022 $1,000.00

 
 
 
Brooklyn, NY 11204
Michael Dayton 10/24/2022 $250.00
1851 Steamboat Pkwy #7504
11/26/2022 $500.00

 
 
 
Reno, NV 89521
David Smith 10/24/2022 $40.00
181 Stoney Creek Rd
10/24/2022 $1,000.00

 
 
 
Gardnerville, NV 89460
Mathew Werber 10/24/2022 $4.00
1430 Shewmaker Ct
10/24/2022 $100.00

 
 
 
Reno, NV 89509
David Lewis
1465 Morning Sun Way 10/24/2022 $250.00
 
 
 
Las Vegas, NV 89110
Skyracer Consulting LLC
12381 Skyracer Drive 10/24/2022 $1,000.00
 
 
 
Las Vegas, NV 89138
John Gianoli
1 Iron Drive 10/24/2022 $200.00
 
 
 
Ely, NV 89301
10/24/2022 $50.00
Steve Smith 10/24/2022 $2.00
10641 Apple Mill Dr
10/31/2022 $2.00
 
 
 
Reno, NV 89521
10/31/2022 $50.00
Oxborrow Trucking Inc 10/24/2022 $250.00
 
 
 
2050 Kleppe Lane

HB 00360
Sparks, NV 89431
Jun Ye
2121 Bryant St 10/24/2022 $202.20

 
 
 
Palo Alto, CA 94301
10/24/2022 $50.00

Joe Vidal 10/26/2022 $20.00


2103 Mountain Echo Ave 11/01/2022 $20.00

 
 
 
Henderson, NV 89074 11/08/2022 $15.00
11/08/2022 $20.00
Wendi Miller
214 N Royal Ascot Dr 10/24/2022 $5,000.00

 
 
 
Las Vegas, NV 89144
V Is For Victory 10/24/2022 $4,000.00
1930 Village Center Circle #3-179
10/24/2022 $5,000.00

 
 
 
Las Vegas, NV 89134
Thomas Murphrey 10/24/2022 $200.00
1953 Alcova Ridge Dr
10/31/2022 $200.00

 
 
 
Las Vegas, NV 89135
Maurice Gallagher 10/24/2022 $5,000.00
1980 Festival Plaza Drive #770
10/24/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Kevin Elder 10/24/2022 $5,000.00
24 Painted Feather Way
10/24/2022 $5,000.00

 
 
 
Las vegas, NV 89135
J. Stephen Pullum
250 International Pkwy 10/24/2022 $1,000.00

 
 
 
Lake Mary, FL 32746
Antoinette Stanfield
232 Gold Leaf Lane 10/24/2022 $200.00

 
 
 
Carson City, NV 89706
Charlotte M. Bible 10/24/2022 $1,000.00
275 Antelope Village Cir
10/24/2022 $40.00

 
 
 
Henderson, NV 89012
10/24/2022 $250.00
KIM BACCHUS 10/24/2022 $10.00
2702 LAKERIDGE Shores E
10/26/2022 $1,000.00

 
 
 
RENO, NV 89519
12/06/2022 $250.00
David Andreas 10/24/2022 $32.95
2605 87th Ter E
10/30/2022 $68.95
 
 
 
Palmetto, FL 34221
10/24/2022 $50.00
10/24/2022 $50.00
Scott Waller 11/26/2022 $50.00
3111 Bel Air Dr #5A
11/26/2022 $50.00
 
 
 
Las Vegas, NV 89109
12/25/2022 $50.00
12/31/2022 $50.00
10/24/2022 $10.00
Sharisse Chavez 10/24/2022 $250.00
320 timbercreek Ct
10/31/2022 $100.00
 
 
 
Reno, NV 89511
10/31/2022 $25.00

HB 00361
10/24/2022 $2.00
James Shephard
7500 W Camp Wisdom Rd Cowan 10/24/2022 $25.00
#203 10/24/2022 $50.00

 
 
 
Dallas, TX 75236
10/31/2022 $35.00
David Clark
7456 Brothers Ln 10/24/2022 $1,000.00

 
 
 
Washoe Valley, NV 89704
George Del Carlo 10/24/2022 $250.00
874 Ophir Peak Rd
10/24/2022 $10.00

 
 
 
INCLINE VILLAGE, NV 89451
Thomas Adams
8608 Villa Ridge Dr 10/24/2022 $2,500.00

 
 
 
Las Vegas, NV 89134
Mark Wimbush
605 Rose Peak Ct 10/24/2022 $250.00

 
 
 
Reno, NV 89511
Richard Temple
57 S Concord Forest Cir 10/24/2022 $500.00

 
 
 
The Woodlands, TX 77381
Sean Characky
5478 Valensole Ave 10/24/2022 $5,000.00

 
 
 
Las Vegas, NV 89141
Rukshana Hussain 10/24/2022 $4.00
655 Angel Aura St
10/24/2022 $100.00

 
 
 
Las Vegas, NV 89138
E. A. Collis
360 Coconut Row 10/24/2022 $500.00

 
 
 
Palm Beach, FL 33480
Ronald Allen
3605 Taurus Dr 10/24/2022 $250.00

 
 
 
Racine, WI 53406
Sean Aldabbagh
3470 Callahan Ave 10/24/2022 $300.00

 
 
 
Las Vegas, NV 89120
Scott Smith 10/24/2022 $200.00
3411 Cheechako Dr
10/24/2022 $8.00

 
 
 
RENO, NV 89519
Kenneth Kreider
3440 White Mountain Ct 10/24/2022 $250.00

 
 
 
Reno, NV 89511
Steven Sultan
35554 Laurel Tree Ct 10/24/2022 $250.00  
 
 
Winchester, CA 92596
Selvin Passen 10/24/2022 $500.00
401 E Las Olas Blvd #1260
10/31/2022 $1,000.00
 
 
 
Fort Lauderdale, FL 33301
Tom Newton
4525 Alpes Way 10/24/2022 $500.00
 
 
 
Reno, NV 89511
Thomas Westfall
444 Flower St 10/24/2022 $500.00
 
 
 
Los Angeles, CA 90071
Todd Roberts 10/24/2022 $5,000.00
4270 San Alivia Ct
10/24/2022 $5,000.00
 
 
 
Las Vegas, NV 89141

HB 00362
10/24/2022 $35.00
10/31/2022 $2.00

Bob Tennison 10/31/2022 $20.22


5 Oak Hill Way 11/06/2022 $5.00

 
 
 
Stuart, FL 34996 11/06/2022 $20.00
11/08/2022 $20.00
11/08/2022 $5.00
Marshall Cromer 10/24/2022 $500.00
4701 Oakport St
11/01/2022 $500.00

 
 
 
Oakland, CA 94601
Matt Womble
515 N Flagler Dr 10/24/2022 $250.00

 
 
 
West Palm Beach, FL 33401

Greg Dye 10/24/2022 $4,000.00


5111 Convair Dr 11/01/2022 $1,500.00

 
 
 
Carson City, NV 89706 11/01/2022 $60.00
Scott Sibley
930 S 4th St 100 10/24/2022 $5,000.00

 
 
 
Las Vegas, NV 89101
Healthy Kitchen LLC dba Bowlology 10/24/2022 $5,000.00
9107 West Russell Road
10/24/2022 $5,000.00

 
 
 
Las Vegas, NV 89148
Nextgen Technology LLC 10/24/2022 $5,000.00
9107 West Russell Road
10/24/2022 $5,000.00

 
 
 
Las Vegas, NV 89148
Mathew Smith
9533 Orient Express Ct 10/24/2022 $5,000.00

 
 
 
Las Vegas, NV 89145
Lawrence Masini
PO Box 1518 10/24/2022 $500.00

 
 
 
Yerington, NV 89447
Richard Parra
PO Box 13975 10/24/2022 $250.00

 
 
 
San Diego, CA 92170
Robert Whiteley
9777 Jamies Jewel Way 10/24/2022 $250.00

 
 
 
Las Vegas, NV 89149
Alexander Aviation LLC 10/24/2022 $5,000.00
9970 West Cheyenne Avenue
10/24/2022 $5,000.00
 
 
 
Las Vegas, NV 89129
Garrett Toft 10/24/2022 $500.00
9804 Moonridge Ct
10/24/2022 $20.00
 
 
 
Las Vegas, NV 89134
John Estill 10/24/2022 $2,000.00
PO Box 320
10/26/2022 $2,000.00
 
 
 
Gerlach, NV 89412

Joanne Chao 10/25/2022 $500.00


PO Box 18182 11/05/2022 $10.00
 
 
 
Reno, NV 89511
11/05/2022 $250.00
Albert Siniscal 10/25/2022 $50.00
 
 
 
93 Quail Run Rd
Henderson, NV 89014 10/25/2022 $50.00
10/31/2022 $50.00

HB 00363
11/05/2022 $12.50
11/05/2022 $50.00
11/08/2022 $50.00
Jim Coover
930 Tahoe Blvd 802-383 10/25/2022 $2,500.00

 
 
 
Incline Village, NV 89451
Brad Friedmutter 10/25/2022 $40.00
4022 Dean Martin Dr
10/25/2022 $1,000.00

 
 
 
Las Vegas, NV 89103
Rex Massey
5450 Goldenrod Dr 10/25/2022 $250.00

 
 
 
Reno, NV 89511
Kevin Mitnick
5455 S Fort Apache Rd #108-166 10/25/2022 $250.00

 
 
 
Las Vegas, NV 89148
David Ritch 10/25/2022 $250.00
5747 Indigo Run Dr
10/25/2022 $10.00

 
 
 
Reno, NV 89511
William Paulos
29 Cascade Creek Ln 10/25/2022 $2,500.00

 
 
 
Las Vegas, NV 89113

Annette Fiala 10/26/2022 $100.00


208 E Levi Ave 10/31/2022 $2,500.00

 
 
 
Las Vegas, NV 89183
11/08/2022 $10.00
Valley Health System LLC
2075 East Flamingo Road 10/26/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
Bruce Breslow
2055 Blue Boy Lane 10/26/2022 $250.00

 
 
 
Reno, NV 89521
Don Maland
2000 Angel Ridge Dr 10/26/2022 $250.00

 
 
 
Reno, NV 89521
k J Brown LLC
2333 Fairview Drive 10/26/2022 $500.00

 
 
 
Carson City, NV 89701
Sierra Executive Solutions Inc
2235 Green Vista Drive #309 10/26/2022 $500.00

 
 
 
Sparks, NV 89431
James Marchesi
2187 Orchard Mist Court 10/26/2022 $2,000.00
 
 
 
Las Vegas, NV 89135
Gardner Engineering Inc
270 East Parr Boulevard 10/26/2022 $5,000.00
 
 
 
Reno, NV 89512
Nevada Housing Alliance
316 California Avenue #428 10/26/2022 $5,000.00
 
 
 
Reno, NV 89509
Todd Rawle
301 West 3540 North Street 10/26/2022 $2,500.00
 
 
 
Provo, UT 84604
NRA Political Victory Fund
11250 Waples Mill Road 10/26/2022 $4,500.00
 
 
 
Fairfax, VA 22030

HB 00364
Committee to Elect Ken Gray
1128 Cheatgrass Drive 10/26/2022 $250.00

 
 
 
Dayton, NV 89403
Alan Liebman
11005 Montano Ranch Court 10/26/2022 $150.00

 
 
 
Reno, NV 89511
Premiere Holdings, Inc.
11035 Lavender Hill Drive 10/26/2022 $5,000.00
#160-439

 
 
 
Las Vegas, NV 89135
Lisa Piazza Patin
12365 High Vista Drive 10/26/2022 $200.00

 
 
 
Reno, NV 89511
Jan Leggett
12375 Creek Crest Drive 10/26/2022 $5,000.00

 
 
 
Reno, NV 89511
Sierra Rental & Transportation
Company Inc 10/26/2022 $2,500.00
1305 Kleppe Lane

 
 
 
Sparks, NV 89431
Allegiant Air LLC 10/26/2022 $5,000.00
1201 North Town Center Drive
10/26/2022 $5,000.00

 
 
 
Las Vegas, NV 89144
Darlene Ruedy
10656 Fort Morgan Way 10/26/2022 $200.00

 
 
 
Reno, NV 89521
Jin Tu
10711 Patina Hills Ct 10/26/2022 $2,500.00

 
 
 
Las Vegas, NV 89135
Geoffrey Lavell
1090 Wigwam Pkwy 10/26/2022 $1,000.00

 
 
 
Henderson, NV 89074
John Krmpotic
1 E 1st St #1400 10/26/2022 $250.00

 
 
 
Reno, NV 89501
S3 Development Company, LLC
1 East Liberty Street #444 10/26/2022 $2,500.00

 
 
 
Reno, NV 89501
Maralene Martin
10280 Copper Cloud Drive 10/26/2022 $1,000.00

 
 
 
RENO, NV 89511
Sandra Mazolewski
10238 Via Bianca 10/26/2022 $250.00
 
 
 
Reno, NV 89511
Marjorie Kenny
10254 Via Como 10/26/2022 $250.00
 
 
 
Reno, NV 89511
Jerry Matsumura
1394 Amado Ct 10/26/2022 $250.00
 
 
 
Reno, NV 89511
Raymond Avansino
165 West Liberty Street 10/26/2022 $5,000.00
 
 
 
Reno, NV 89501
James Mace
15005 Edmands Drive 10/26/2022 $2,500.00
 
 
 
Reno, NV 89511
A-1 Steel Inc 10/26/2022 $5,000.00
 
 
 
1523 South Stanford Way

HB 00365
Sparks, NV 89431
USA Cash Services Management Inc
1752 Combe Road 10/26/2022 $3,000.00

 
 
 
Ogden, UT 84403
MVP Development Inc
1701 South Sutro Terrace 10/26/2022 $5,000.00

 
 
 
Carson City, NV 89706
D & D Plumbing Inc
1655 Greg Court 10/26/2022 $1,000.00

 
 
 
Sparks, NV 89431
Holly Wilson 10/26/2022 $5,000.00
761 Dragon Ridge Drive
10/26/2022 $5,000.00

 
 
 
Henderson, NV 89012
Plenium Builders
825 Steneri Way 10/26/2022 $2,500.00

 
 
 
Sparks, NV 89431
QC HOLDINGS INC
8208 MELROSE DRIVE 10/26/2022 $5,000.00

 
 
 
LENEXA, KS 66214
Larry Levingston
7859 Edmonton Park 10/26/2022 $500.00

 
 
 
Germantown, TN 38138
Andy Mersha
801 Aquitaine Ct 10/26/2022 $1,500.00

 
 
 
Las Vegas, NV 89145
Burt Garavaglia
575 McDonald Drive 10/26/2022 $250.00

 
 
 
Incline Village, NV 89451
Margaret Ciorciari
5905 Flowering Sage Court 10/26/2022 $250.00

 
 
 
Reno, NV 89511
Darin Balaam dba Friends of Darin
Balaam 10/26/2022 $1,000.00
5953 Axis Drive

 
 
 
Sparks, NV 89436
Jason Jaeger
6592 North Decatur Boulevard #115 10/26/2022 $5,000.00

 
 
 
Las Vegas, NV 89131
Jeffrey Fine
650 S Main St 10/26/2022 $1,000.00

 
 
 
Las Vegas, NV 89101
Jose Refugio Banuelos
6500 Rio Vista Street 10/26/2022 $5,000.00
 
 
 
Las Vegas, NV 89131
Richard DeLong
6544 Champetre Court 10/26/2022 $250.00
 
 
 
Reno, NV 89511
Susan Cote
6800 Oak Grass Court 10/26/2022 $400.00
 
 
 
Reno, NV 89511
Harris Law Practice LLC
6151 Lakeside Drive #2100 10/26/2022 $250.00
 
 
 
Reno, NV 89511
Judith Coulter Wros
403 Hill Street 10/26/2022 $250.00
 
 
 
Reno, NV 89501

HB 00366
Western States Contracting, Inc. 10/26/2022 $5,000.00
4129 W. Cheyenne Ave. Ste. B
10/26/2022 $5,000.00

 
 
 
N. Las Vegas, NV 89032
Racetrack Television Network 10/26/2022 $5,000.00
4075 Volunteer Boulevard
10/26/2022 $5,000.00

 
 
 
Henderson, NV 89044
Samantha Aldabbagh 10/26/2022 $250.00
3470 Callahan Ave
10/26/2022 $10.00

 
 
 
Las Vegas, NV 89120
Karen Bingham
340 Juniper Hill Road 10/26/2022 $4,000.00

 
 
 
Reno, NV 89519
Jan Rawle
340 Stone Brook Lane 10/26/2022 $2,500.00

 
 
 
Provo, UT 84604
James Coyne
36 Brookridge Drive 10/26/2022 $500.00

 
 
 
Henderson, NV 89052
Joshua Aldabbagh
4570 S Eastern Ave #28 10/26/2022 $300.00

 
 
 
Las Vegas, NV 89119
Honey Badger Investments LLC 10/26/2022 $5,000.00
4270 San Alivia Court
10/26/2022 $5,000.00

 
 
 
Las Vegas, NV 89141
Donald Nelson
4342 Cantamar Court 10/26/2022 $250.00

 
 
 
Sparks, NV 89436
Mark Knobel
4165 Powderkeg Cir 10/26/2022 $250.00

 
 
 
Reno, NV 89519
Nevada Disseminator Service Inc 10/26/2022 $5,000.00
4175 Cameron Street #B-10
10/26/2022 $5,000.00

 
 
 
Las Vegas, NV 89103
Roberts Investment Company Inc 10/26/2022 $5,000.00
4175 Cameron Street #B-10
10/26/2022 $5,000.00

 
 
 
Las Vegas, NV 89103
Simeon Ting 10/26/2022 $150.00
511 E 73rd St #25
11/08/2022 $100.00

 
 
 
New York, NY 10021
Community Choice Financial
5165 Emerald Parkway #100 10/26/2022 $5,000.00

 
 
 
Dublin, OH 43017
Miller Foundation
5176 Fading Sunset Drive 10/26/2022 $1,500.00
 
 
 
Las Vegas, NV 89135
Jill Marchesi
4755 Clay Peak Drive 10/26/2022 $5,000.00
 
 
 
Las Vegas, NV 89129
LLG Holdings
5 Wild Horse Canyon Drive 10/26/2022 $250.00
 
 
 
Sparks, NV 89434
Joe Willardsen 10/26/2022 $4.00
9061 W Post Rd
10/26/2022 $100.00
 
 
 
Las Vegas, NV 89148
1864 PAC 10/26/2022 $1,000.00
 
 
 
PO Box 10904

HB 00367
Reno, NV 89510
Savage & Son
PO Box 11800 10/26/2022 $5,000.00

 
 
 
Reno, NV 89510
Wilde Brough
HC 60 Box 156 10/26/2022 $1,000.00

 
 
 
Wells, NV 89835
Moody Weiske Contractors
PO Box 3296 10/26/2022 $2,500.00

 
 
 
Reno, NV 89505
Mark Munson 10/26/2022 $357.77
PO Box 2021
10/31/2022 $357.77

 
 
 
Belton, TX 76513
Jeffery Siri
PO Box 2071 10/26/2022 $1,000.00

 
 
 
Reno, NV 89505
David TRUE
PO Box 2360 10/26/2022 $5,000.00

 
 
 
Casper, WY 82602
Benjamin Scott Lurie
PO Box 370774 10/26/2022 $2,500.00

 
 
 
Las Vegas, NV 89137
Midtown Investments LLC
PO Box 401424 10/26/2022 $500.00

 
 
 
Las Vegas, NV 89140
David W Wilson 10/26/2022 $5,000.00
761 Dragon Ridge Drive
10/26/2022 $5,000.00

 
 
 
Henderson, NV 89012
K A Banuelos
6500 Rio Vista Street 10/26/2022 $5,000.00

 
 
 
Las Vegas, NV 89131
Friends of Victoria Seaman 10/27/2022 $5,000.00
PO Box 751271
10/27/2022 $4,000.00

 
 
 
Las Vegas, NV 89136
Nevada Pic A Part LLC
330 South Rampart Boulevard #340 10/27/2022 $2,500.00

 
 
 
Las Vegas, NV 89145
Raymond Conrad
401 Quay Commons #1801 10/27/2022 $1,000.00

 
 
 
Sarasota, FL 34236
Harlan Crow
3819 Maple Avenue 10/27/2022 $5,000.00
 
 
 
DALLAS, TX 75219
Jeffrey Ramer
1487 Cilento Court 10/27/2022 $200.00
 
 
 
Henderson, NV 89052
Manufactured Home Community
Owners PAC
10/27/2022 $5,000.00
1201 Terminal Way Ste 220
 
 
 
Reno, NV 89502
John Breslow 10/28/2022 $5,000.00
11035 Lavender Hill Drive #160-156
10/28/2022 $5,000.00
 
 
 
Las Vegas, NV 89135
Bryan Iriye
11716 Oakland Hills Drive 10/28/2022 $5,000.00
 
 
 
Las Vegas, NV 89141

HB 00368
David A. Giannotti
19 Green Spun Dr 10/28/2022 $5,000.00

 
 
 
Las Vegas, NV 89141
Chapman Dodge
3175 East Sahara Avenue 10/28/2022 $2,500.00

 
 
 
Las Vegas, NV 89104
Dawn Madrigrano 10/28/2022 $5,000.00
28 Vintage Valley Drive
10/28/2022 $5,000.00

 
 
 
Las Vegas, NV 89141
Brazil Granite Co LLC 10/28/2022 $5,000.00
3710 West Sunset Road
10/28/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
Pura Vida 1 LLC 10/28/2022 $5,000.00
3710 West Sunset Road
10/28/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
Sunset VV LLC 10/28/2022 $5,000.00
3710 West Sunset Road
10/28/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
Duane Roberts
4100 Newport Place #400 10/28/2022 $5,000.00

 
 
 
Newport Beach, CA 92660
David Daniels
36 Olympia Canyon Way 10/28/2022 $5,000.00

 
 
 
Las Vegas, NV 89141
J Patrick Mulcahy 10/28/2022 $5,000.00
44 Olympia Canyon Way
11/04/2022 $5,000.00

 
 
 
Las Vegas, NV 89141
JLTM LLC 10/28/2022 $5,000.00
6415 South Tenaya Way #105
10/28/2022 $5,000.00

 
 
 
Las Vegas, NV 89113
Royce Hackworth
PO Box 2370 10/28/2022 $250.00

 
 
 
Elko, NV 89803
Champion American Values
PO Box 2485 10/28/2022 $1,000.00

 
 
 
Springfield, VA 22152
Robert Anderson
PO Box 2294 10/28/2022 $5,000.00

 
 
 
Minden, NV 89423
Susan Anderson
PO Box 2294 10/28/2022 $4,000.00

 
 
 
Minden, NV 89423
Commerce Park Medical LLC 10/28/2022 $5,000.00
PO Box 777547
10/28/2022 $5,000.00
 
 
 
Henderson, NV 89077
Chapman Chrysler Jeep
930 Auto Show Drive 10/28/2022 $2,500.00
 
 
 
Henderson, NV 89014
Robert Rodie
9480 Gateway Dr 10/29/2022 $250.00
 
 
 
Reno, NV 89521
Eli Dawson
963 Topsy Ln 10/29/2022 $1,000.00
 
 
 
Carson City, NV 89705
Cathryn Benitez 10/29/2022 $100.00
 
 
 
PO Box 176

HB 00369
Jamul, CA 91935 10/29/2022 $4.00
Gerald Schlief
5773 Woodway Dr #800 10/29/2022 $2,500.00

 
 
 
Houston, TX 77057
Larry Duerr
455 Lakeview Dr 10/29/2022 $200.00

 
 
 
Verdi, NV 89439
Todd Slusher
4775 W Teco Ave #210 10/29/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
Fredrick Kammernan 10/29/2022 $4.00
378 Harrier Ln

 
 
 
Mesquite, NV 89027 10/29/2022 $100.00
Robert Goldberg
255 N Sierra St #2314 10/29/2022 $2,500.00

 
 
 
Reno, NV 89501
Michael Carducci 10/29/2022 $500.00
3021 Hammerwood Dr

 
 
 
Las Vegas, NV 89135 10/29/2022 $20.00
Greg Struhl 10/29/2022 $1,000.00
3001 Westwood Dr

 
 
 
Las Vegas, NV 89109 11/06/2022 $1,000.00
10/29/2022 $25.00
Patrick Zarate 10/29/2022 $100.00
191 Hillhaven Ct
11/02/2022 $50.00

 
 
 
Ventura, CA 93003
11/02/2022 $2.00
Kenneth Misch 10/29/2022 $20.00
1794 Amarone Way

 
 
 
Henderson, NV 89015 10/29/2022 $500.00
John Morotti 10/30/2022 $5,000.00
11372 Villa Giovanni Ct

 
 
 
Las Vegas, NV 89141 10/30/2022 $5,000.00
Adam Beren
1739 Duckcross Cove 10/30/2022 $2,000.00

 
 
 
Wichita, KS 67206
Ellen Beren
1739 Duckcross Cove 10/30/2022 $2,000.00

 
 
 
Wichita, KS 67206
James Taylor 10/30/2022 $100.00
1603 Duhamel Way
 
 
 
North Las Vegas, NV 89032 10/30/2022 $4.00
Scott Scherer 10/30/2022 $100.00
2025 Horse Prairie Rd
 
 
 
Reno, NV 89521 10/30/2022 $25.00
Michael Wendling
2815 Corte Esmeralda 10/30/2022 $250.00
 
 
 
San Clemente, CA 92673

Jeffrey Morris 10/30/2022 $100.00


7265 Tara Ave 12/03/2022 $100.00
 
 
 
Las Vegas, NV 89117 12/31/2022 $100.00
Richard Steinberg 10/30/2022 $25.00
 
 
 
97 Quail Run Rd
Henderson, NV 89014 10/31/2022 $50.00
11/06/2022 $25.00

HB 00370
11/08/2022 $25.00
Alex Yemenidjian 10/31/2022 $4,000.00
One Hughes Center Dr #1902
10/31/2022 $5,000.00

 
 
 
Las Vegas, NV 89169
Arda Yemenidjian 10/31/2022 $5,000.00
One Hughes Center Dr #1902
10/31/2022 $5,000.00

 
 
 
Las Vegas, NV 89169
Southwest Airlines 10/31/2022 $400.98
PO Box 36611
10/31/2022 $400.98

 
 
 
Dallas, TX 75235
ELKO CONVENTION & VISITORS
AUTHORITY
10/31/2022 $200.00
700 MOREN WAY

 
 
 
ELKO, NV 89801
David Lanferman 10/31/2022 $100.00
700 Illinois St
11/08/2022 $50.00

 
 
 
San Francisco, CA 94107
Jeffrey Iverson
840 S Rancho Dr #4-613 10/31/2022 $1,000.00

 
 
 
Las Vegas, NV 89106
Dene E. Krametbauer
8055 Romine Ct 10/31/2022 $500.00

 
 
 
Las Vegas, NV 89149
Leanne Chilton 10/31/2022 $1,000.00
800 Lacy Ln
10/31/2022 $1,000.00

 
 
 
Las Vegas, NV 89107
Gregory Munson 10/31/2022 $100.00
5509 Timber Crest Ave
10/31/2022 $4.00

 
 
 
Las Vegas, NV 89131
Harris Simmons
475 E Oak Forest Rd 10/31/2022 $500.00

 
 
 
Salt Lake City, UT 84103
Alberto Milo
6390 SW 120th St 10/31/2022 $500.00

 
 
 
Pinecrest, FL 33156
Rafael Velez
500 D St 10/31/2022 $250.00

 
 
 
Petaluma, CA 94952
10/31/2022 $100.00
Michael Barnes 11/06/2022 $100.00
5245 Vista Blvd Ste F3 PMB 306
11/08/2022 $25.00

 
 
 
Sparks, NV 89436
11/08/2022 $100.00
Daniel Warren 10/31/2022 $20.00
35 Hidden Lake Dr
10/31/2022 $500.00
 
 
 
Reno, NV 89521
Li Chen
3237 S Torrey Pines Dr 10/31/2022 $2,500.00
 
 
 
Las Vegas, NV 89146
Taylor Boyd
20 Sun Glow Ln 10/31/2022 $500.00
 
 
 
Las Vegas, NV 89135
robert williams 10/31/2022 $35.00
 
 
 
1972 pulaski dr
Beaufort, SC 29906 10/31/2022 $1.40
11/06/2022 $1.60
11/06/2022 $40 00
HB 00371
11/06/2022 $40.00
11/08/2022 $12.50
11/08/2022 $50.00
Todd Tibbetts
2165 Big Pine Dr 10/31/2022 $250.00

 
 
 
Hiawassee, GA 30546
Merrie Jo Leite 10/31/2022 $250.00
2171 Stage Stop Dr
10/31/2022 $10.00

 
 
 
Henderson, NV 89052
Polaris Wellness Center LLC
11553 Bohemian Forest Ave 10/31/2022 $2,500.00

 
 
 
Las Vegas, NV 89138

Wayne Riggs 10/31/2022 $50.00


1141 Mohave Dr 12/03/2022 $50.00

 
 
 
Mesquite, NV 89027 12/31/2022 $50.00
10/31/2022 $1,000.00
Azam Hakim
10437 Orkiney Dr 10/31/2022 $1,000.00

 
 
 
Las Vegas, NV 89144
11/06/2022 $1,000.00
Mark Elston 11/01/2022 $8.00
10395 Thomas Creek Rd
11/01/2022 $200.00

 
 
 
RENO, NV 89511
Gary Pestello
10198 Via Verona 11/01/2022 $125.00

 
 
 
Reno, NV 89511
Charles Johnson 11/01/2022 $10.00
13100 Welcome Way
11/01/2022 $250.00

 
 
 
RENO, NV 89511
Ileana Heath
1600 S Valley View Blvd 11/01/2022 $1,000.00

 
 
 
Las Vegas, NV 89102
William R Boyd 11/01/2022 $5,000.00
20 Sun Glow Lane
11/01/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Sean Johnson
30 Ridge Blossom Road 11/01/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Larry Blumberg
3002 Foxridge Rd 11/01/2022 $250.00

 
 
 
Dothan, AL 36303
Kelly Roberts
4100 Newport Place #400 11/01/2022 $5,000.00
 
 
 
Newport Beach, CA 92660
Rita Golleher
50 Greenhorn Road 11/01/2022 $250.00
 
 
 
Hailey, ID 83333
Robert Winkel
4785 Caughlin Parkway 11/01/2022 $500.00
 
 
 
Reno, NV 89519
Marianne Boyd Johnson 11/01/2022 $5,000.00
6465 South Rainbow Boulevard
11/01/2022 $5,000.00
 
 
 
Las Vegas, NV 89118
State Of Nevada Association Of
Providers
529 West 300 South Street 11/01/2022 $200.00
 
 
 
Orem, UT 84058

HB 00372
George Alexander 11/01/2022 $100.00
809 Pont Chartrain Dr
11/01/2022 $25.00

 
 
 
LAS VEGAS, NV 89145
Advanced Orthopedics & Sports
Medicine
11/01/2022 $5,000.00
7195 Advanced Way

 
 
 
Las Vegas, NV 89113
Dennis Ehrreich
PO Box 309 11/01/2022 $500.00

 
 
 
West Wareham, MA 2576
Patricia Hinds
7 Mountain Cove Ct 11/02/2022 $500.00

 
 
 
Henderson, NV 89052
Glen Amador
7432 Doe Avenue 11/02/2022 $2,500.00

 
 
 
Las Vegas, NV 89117
Peter Kyte
7407 Lemon Gulch Way 11/02/2022 $400.00

 
 
 
Castle Rock, CO 80108
Mark Brenner 11/02/2022 $10.00
5846 N 46th St
11/02/2022 $250.00

 
 
 
Phoenix, AZ 85018
Lauren Kitt Carter 11/02/2022 $5,000.00
5950 Canoga Ave
11/02/2022 $5,000.00

 
 
 
Los Angeles, CA 91367
Steven Solomon
4405 Belclaire Ave 11/02/2022 $5,000.00

 
 
 
Dallas, TX 75205
Albert Babbitt 11/02/2022 $2,000.00
39 Panorama Crest Ave
11/02/2022 $80.00

 
 
 
Las Vegas, NV 89135
S and D Wholesale
3260 East Charleston Boulevard 11/02/2022 $5,000.00

 
 
 
Las Vegas, NV 89104
Chad Roy
37 Pebble Dunes Ct 11/02/2022 $5,000.00

 
 
 
Las Vegas, NV 89141
noah herrera
2672 sunday grace dr 11/02/2022 $1,000.00

 
 
 
HENDERSON, NV 89052
Ken Hill
2005 Barber St 11/02/2022 $500.00

 
 
 
Knoxville, TN 37920
Grand Sierra Resort & Casino 11/02/2022 $5,000.00
2500 East 2nd Street
11/02/2022 $5,000.00
 
 
 
Reno, NV 89502
Rahul Sodhi
1350 East Flamingo Road #G 11/02/2022 $2,500.00
 
 
 
Las Vegas, NV 89119
Hitesh Chokshi
11129 Scotscraig Court 11/02/2022 $250.00
 
 
 
Las Vegas, NV 89141
11/02/2022 $5,000.00
Keith Flatt
12 Wild Dunes 11/02/2022 $400.00
 
 
 
Las Vegas, NV 89113
11/02/2022 $5,000.00

HB 00373
Ashok Mirchundani
10570 Hope Mills Dr 11/02/2022 $2,500.00

 
 
 
Las Vegas, NV 89135
National Shooting Sports Foundation
11/03/2022 $5,000.00
Inc
6 Corporate Drive #650 11/03/2022 $5,000.00

 
 
 
Shelton, CT 6484
Omar Habbas
675 North 1 Street 11/03/2022 $5,000.00
Ste. 1000

 
 
 
San Jose, CA 95112-5137
Capitol Hill Group
6135 Kansas Avenue Northeast 11/04/2022 $2,500.00

 
 
 
Washington, DC 20011
Highland Holding Group LLC
16 Vintage Valley Drive 11/04/2022 $2,500.00

 
 
 
Las Vegas, NV 89141
Larry Carter
22 Innisbrook Ave 11/04/2022 $1,000.00

 
 
 
Las Vegas, NV 89113
Nathan Hillstad
255 Desatoya Court 11/04/2022 $1,500.00

 
 
 
Reno, NV 89511
Sahara 11/04/2022 $5,000.00
2535 South Las Vegas Boulevard
11/04/2022 $5,000.00

 
 
 
Las Vegas, NV 89109
Sarah Hummel
9824 Winter Palace Dr 11/04/2022 $10,000.00

 
 
 
Las Vegas, NV 89145
R & J Joy Inc
PO Box 19219 11/04/2022 $5,000.00

 
 
 
Reno, NV 89511
Ward Pearce 11/05/2022 $500.00
PO Box 50337
11/05/2022 $20.00

 
 
 
Sparks, NV 89435
Rusty Graf 11/05/2022 $4.00
2741 Bayo Ct
11/05/2022 $100.00

 
 
 
Las Vegas, NV 89102
Fritz Kummer 11/05/2022 $100.00
2834 Bellini Dr
11/05/2022 $2,500.00

 
 
 
Henderson, NV 89052

Roger Westra 11/05/2022 $25.00


3162 Olivia Heights Ave 11/05/2022 $100.00
 
 
 
Henderson, NV 89052 11/08/2022 $100.00
Joel Dowling
146 W Ridley Ave 11/05/2022 $400.00
 
 
 
Norwood, PA 19074
Patricia Miller 11/05/2022 $8.00
17530 Bain spring rd
11/05/2022 $200.00
 
 
 
Reno, NV 89521
Jeffrey Daniels 11/05/2022 $400.00
3802 NE 207th St
11/05/2022 $16.00
 
 
 
Aventura, FL 33180
Hawk Hill Management Company LLC 11/06/2022 $5,000.00
416 Randolph Ave
11/06/2022 $5,000.00
 
 
 
Seattle, WA 98122

HB 00374
11/06/2022 $5,000.00
Patrick Lewis 11/06/2022 $5,000.00
1620 Bayonne Dr
11/06/2022 $5,000.00

 
 
 
Las Vegas, NV 89134
11/06/2022 $5,000.00
Hugh Bassewitz
15 Morning Glow Ln 11/06/2022 $500.00

 
 
 
Las Vegas, NV 89135
Loren Monroe
1513 Highwood Dr 11/06/2022 $1,000.00

 
 
 
Mc Lean, VA 22101

Lenore Frank 11/06/2022 $100.00


2269 Maywood Ave 11/06/2022 $4.00

 
 
 
San Jose, CA 95128 11/08/2022 $25.00
Kathryn Bahneman
8720 Carlitas Joy Ct 11/06/2022 $500.00

 
 
 
Las Vegas, NV 89117
Scott Bahneman
8720 Carlitas Joy Ct 11/06/2022 $500.00

 
 
 
Las Vegas, NV 89117
Edward Bartell
PO Box 130 11/06/2022 $1,000.00

 
 
 
Orovada, NV 89425
James Gipson 11/06/2022 $2,900.00
9663 Santa Monica Blvd
11/06/2022 $116.00

 
 
 
Beverly Hills, CA 90210
Miller-Meeks For Congress
PO Box 183 11/07/2022 $2,000.00

 
 
 
Hudson, WI 54016
Meruelo Group LLC 11/07/2022 $5,000.00
9550 Firestone Boulevard
11/07/2022 $5,000.00

 
 
 
Downey, CA 90241
Odyssey Realty LLC
PO Box 34976 11/07/2022 $500.00

 
 
 
Las Vegas, NV 89133
John Francis Miller
2361 Villandry Court 11/07/2022 $1,000.00

 
 
 
Henderson, NV 89074
E James Greenwald
10000 Dryden Drive 11/07/2022 $1,000.00

 
 
 
Reno, NV 89511
Fuji Food Products Inc 11/07/2022 $5,000.00
14420 Bloomfield Avenue
11/07/2022 $5,000.00
 
 
 
Santa Fe Springs, CA 90670
Cayenne Investments LLC 11/07/2022 $5,000.00
63101 Nels Anderson Road
11/07/2022 $5,000.00
 
 
 
Bend, OR 97701
Meruelo Media LLC 11/07/2022 $5,000.00
4975 West Pico Boulevard
11/07/2022 $5,000.00
 
 
 
Los Angeles, CA 90019
Dennis Bassford
4380 92nd Avenue Southeast 11/07/2022 $5,000.00
 
 
 
Mercer Island, WA 98040
Victor Muro 11/07/2022 $2,500.00
 
 
 
38 Quail Hollow Drive
Henderson, NV 89014

HB 00375
Ronald Soto 11/08/2022 $40.00
3750 Las Vegas Blvd S #3904
11/08/2022 $1,000.00

 
 
 
Las Vegas, NV 89158
Robert Anderson
43725 Monterey Ave 11/08/2022 $1,000.00

 
 
 
Palm Desert, CA 92260
KLRT Utah Properties LLC
4270 Cameron Street #2 11/08/2022 $2,000.00

 
 
 
Las Vegas, NV 89103
Michael Dermody
4795 Caughlin Pkwy #100 11/08/2022 $5,000.00

 
 
 
Reno, NV 89519
11/08/2022 $50.00
Adriane Milner
4819 Beaconsfield St 11/08/2022 $50.00

 
 
 
Las Vegas, NV 89147
11/08/2022 $2.00
Roy Edgington for Mayor
516 Pioneer Court 11/08/2022 $500.00

 
 
 
Fernley, NV 89408
LaPour Partners
5525 S Decatur Blvd 11/08/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
James Marx
1501 Windhaven Cir 11/08/2022 $200.00

 
 
 
Las Vegas, NV 89117
Garrett Thompson 11/08/2022 $500.00
10489 Hope Mills Dr
11/08/2022 $20.00

 
 
 
Las Vegas, NV 89135

Jay Parmer 11/08/2022 $250.00


13085 Broili Dr 11/08/2022 $10.00

 
 
 
Reno, NV 89511 12/10/2022 $500.00
Gregory Yankovsky 11/08/2022 $100.00
2165 Mt City St
11/08/2022 $4.00

 
 
 
Henderson, NV 89052
David Podber 11/08/2022 $4.00
2125 Rainbow Falls Dr
11/08/2022 $100.00

 
 
 
Las Vegas, NV 89134
marlene wheeler rennie 11/08/2022 $5,000.00
PO Box 90192
11/08/2022 $5,000.00

 
 
 
Henderson, NV 89009

Franko Marretti 11/08/2022 $400.00


9345 W Sunset Rd #101 11/08/2022 $5,000.00
 
 
 
Las Vegas, NV 89148 11/08/2022 $5,000.00
JML Holdings LLC 11/08/2022 $5,000.00
9331 Cool Creek Avenue
11/08/2022 $5,000.00
 
 
 
Las Vegas, NV 89147
Neil McQueary
HC 60 Box 677 11/08/2022 $1,000.00
 
 
 
Ruby Valley, NV 89833
Thomas Mikulich
7134 Nodding Thistle Court 11/18/2022 $2,500.00
 
 
 
Las Vegas, NV 89178
Frank J Fertitta IV 11/18/2022 $5,000.00
 
 
 
10801 West Charleston Boulevard

HB 00376
#600 11/18/2022 $5,000.00
Las Vegas, NV 89135
Kelley Ann Fertitta
10801 West Charleston Boulevard 11/18/2022 $5,000.00
#600 11/18/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Nicco Fertitta
10801 West Charleston Boulevard 11/18/2022 $5,000.00
#600 11/18/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Victoria G Fertitta-Crowe
10801 West Charleston Boulevard 11/18/2022 $5,000.00
#600 11/18/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Scott Kreeger 11/18/2022 $5,000.00
908 Pont Chartrain Drive
11/18/2022 $5,000.00

 
 
 
Las Vegas, NV 89145
Michael Britt 11/18/2022 $2,500.00
9 Tapadero Lane
12/02/2022 $2,500.00

 
 
 
Las Vegas, NV 89135
Angelia Teresa Fertitta 11/18/2022 $5,000.00
PO Box 379045
11/18/2022 $5,000.00

 
 
 
Las Vegas, NV 89137
Frank J Fertitta III 11/18/2022 $5,000.00
PO Box 379045
11/18/2022 $5,000.00

 
 
 
Las Vegas, NV 89137
Jill Fertitta 11/18/2022 $5,000.00
PO Box 379045
11/18/2022 $5,000.00

 
 
 
Las Vegas, NV 89137
Lorenzo Fertitta 11/18/2022 $5,000.00
PO Box 379045
11/18/2022 $5,000.00

 
 
 
Las Vegas, NV 89137
Teresa Fertitta 11/18/2022 $5,000.00
PO Box 379045
11/18/2022 $5,000.00

 
 
 
Las Vegas, NV 89137
Victoria K Fertitta 11/18/2022 $5,000.00
PO Box 379045
11/18/2022 $5,000.00

 
 
 
Las Vegas, NV 89137
Andrew Abboud 11/19/2022 $200.00
9 Club Vista Dr
11/19/2022 $5,000.00

 
 
 
Henderson, NV 89052
David Rosenstein 11/26/2022 $40.00
1336 Dream Valley St
11/26/2022 $1,000.00
 
 
 
Henderson, NV 89052
Pharmaceutical Care Management
Association
325 7th Street Northwest 11/28/2022 $2,500.00
 
 
 
9th floor
Washington, DC 20004
TransCanada USA Services Inc
717 Texas Street #2400 11/28/2022 $5,000.00
 
 
 
Houston, TX 77002
Motorola Solutions Inc.
500 W Monrose 11/28/2022 $4,000.00
 
 
 
Chicago, IL 60661
DFA LLC 12/01/2022 $5,000.00
8350 Eastgate Road
12/01/2022 $5,000.00
 
 
 
Henderson, NV 89015

HB 00377
Xtreme Cubes Corporation 12/01/2022 $5,000.00
8350 Eastgate Road
12/01/2022 $5,000.00

 
 
 
Henderson, NV 89015
Xtreme Manufacturing LLC 12/01/2022 $5,000.00
8350 Eastgate Road
12/01/2022 $5,000.00

 
 
 
Henderson, NV 89015
Ahern Rentals Inc 12/01/2022 $5,000.00
1401 Mineral Avenue
12/01/2022 $5,000.00

 
 
 
Las Vegas, NV 89106
Don & Paul LLC 12/01/2022 $5,000.00
1401 Mineral Avenue
12/01/2022 $5,000.00

 
 
 
Las Vegas, NV 89106
Christopher Fiumara
1505 South Pavilion Center Drive 12/02/2022 $500.00

 
 
 
Las Vegas, NV 89135
Stephen Cootey
11633 Glowing Sunset Lane 12/02/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Robert Finch
30 Moonfire Drive 12/02/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Durango Warm Springs LLC 12/02/2022 $5,000.00
8975 South Pecos Road #6A
12/02/2022 $5,000.00

 
 
 
Henderson, NV 89074
La Costa Village Inc 12/02/2022 $5,000.00
8975 South Pecos Road #6A
12/02/2022 $5,000.00

 
 
 
Henderson, NV 89074
LVG Ventures LLC 12/02/2022 $5,000.00
8975 South Pecos Road #6A
12/02/2022 $5,000.00

 
 
 
Henderson, NV 89074
SBW Management & Leasing 350I
12/02/2022 $5,000.00
LLC
8975 South Pecos Road #6A 12/02/2022 $5,000.00

 
 
 
Henderson, NV 89074
SWG Inc 12/02/2022 $5,000.00
8975 South Pecos Road #6A
12/02/2022 $5,000.00

 
 
 
Henderson, NV 89074
Kord Nichols
52 Grey Feather Drive 12/02/2022 $5,000.00

 
 
 
Las Vegas, NV 89135
Jeffrey Welch 12/02/2022 $5,000.00
4219 Bronze Ridge Street
12/02/2022 $2,500.00
 
 
 
Las Vegas, NV 89135
Biggest Little Investments, LLP
3652 S Virginia St 12/02/2022 $2,600.00
Suite C7
 
 
 
Reno, NV 89502
Monica Pappas
6485 S Rainbow Blvd 12/03/2022 $2,500.00
 
 
 
Las Vegas, NV 89118
Rew Goodenow 12/03/2022 $500.00
10070 Raintree Ct
12/03/2022 $20.00
 
 
 
Reno, NV 89511
Nevada Builders Alliance
1000 N Division St Suite 102 12/06/2022 $2,500.00
 
 
 
Carson City, NV 89701

HB 00378
Dixon Hydrologic, PLLC
10299 Culiacan Pass Trail 12/06/2022 $500.00

 
 
 
Reno, NV 89521
Karl S. Hall
1080 Mount Rose Street 12/06/2022 $500.00

 
 
 
Reno, NV 89509
Reno Carson Messenger Service
185 Martin Street 12/06/2022 $500.00

 
 
 
Reno, NV 89509
Silver State Government Relations
204 North Minnesota Street 12/06/2022 $1,420.00

 
 
 
Carson City, NV 89703

Nevada Mining Association Inc 12/06/2022 $2,500.00


3185 Lakeside Drive 12/27/2022 $2,500.00

 
 
 
Reno, NV 89509 12/27/2022 $5,000.00
Nancy Flanigan
2750 Holcomb Ranch Lane 12/06/2022 $500.00

 
 
 
Reno, NV 89511
TDC Operating LLC
550 West Plumb Lane #B506 12/06/2022 $1,500.00

 
 
 
Reno, NV 89509
CORE West Inc
7150 Cascade Valley Court 12/06/2022 $5,000.00

 
 
 
Las Vegas, NV 89128
Liberty Dental Plan Corporation
340 Commerce 12/06/2022 $5,000.00
Suite 100 12/06/2022 $5,000.00

 
 
 
Irvine, CA 92602
Liberty Dental Plan of Nevada, Inc
340 Commerce 12/06/2022 $5,000.00
Suite 100 12/06/2022 $5,000.00

 
 
 
Irvine, CA 92602
Committee to Improve NV Economy
and Education System 12/06/2022 $1,000.00
410 South Minnesota Street

 
 
 
Carson City, NV 89703
AngloGold Ashanti
4601 Dtc Boulevard 12/06/2022 $5,000.00
Suite 550 12/06/2022 $5,000.00

 
 
 
Denver, CO 80237
Lesley Pittman
5190 Rio Pinar Drive 12/06/2022 $500.00

 
 
 
Reno, NV 89509
Andrew J. Mackay
5353 Desertstone Drive 12/06/2022 $250.00  
 
 
Sparks, NV 89436
Charles Jeannes
4790 Caughlin Pkwy #441 12/06/2022 $2,500.00
 
 
 
Reno, NV 89519
Whittemore Group Inc.
Po Box 8069 12/06/2022 $1,000.00
 
 
 
Reno, NV 89507
Nevada Wildlife Coalition PAC
PO Box 70143 12/06/2022 $2,500.00
 
 
 
Reno, NV 89570
Charter Communications 12/06/2022 $5,000.00
PO Box 94188
12/06/2022 $5,000.00
 
 
 
Palatin, IL 60094

HB 00379
Building Nevadas Future PAC
PO Box 5984 12/06/2022 $2,500.00

 
 
 
Reno, NV 89513
Perry Di Loreto
985 Damonte Ranch Parkway #310 12/06/2022 $500.00

 
 
 
Reno, NV 89521
NAIOP Northern Nevada
P.O. Box 7115 12/06/2022 $2,500.00

 
 
 
RENO, NV 89510
John Alex Tanchek
P.O. Box 9607 12/06/2022 $500.00

 
 
 
Reno, NV 89507
United Services Automobile
Association 12/06/2022 $5,000.00
P.O. Box 34330

 
 
 
San Antonio, TX 78265
Meruelo Enterprises Inc 12/08/2022 $5,000.00
9550 Firestone Boulevard
12/08/2022 $5,000.00

 
 
 
Downey, CA 90241
Peppermill Casinos Inc
90 West Grove Street #600 12/08/2022 $5,000.00

 
 
 
Reno, NV 89509
Cantamar Property Management Inc 12/08/2022 $5,000.00
9550 Firestone Boulevard #105
12/08/2022 $5,000.00

 
 
 
Downey, CA 90241
Monterey Insurance Company Inc 12/08/2022 $5,000.00
9550 Firestone Boulevard #105
12/08/2022 $5,000.00

 
 
 
Downey, CA 90241
Albert Seeno
4021 Port Chicago Highway 12/08/2022 $5,000.00

 
 
 
Concord, CA 94520
Sandra Seeno
4021 Port Chicago Highway 12/08/2022 $5,000.00

 
 
 
Concord, CA 94520
Michael Alonso
3805 Frost Lane 12/08/2022 $5,000.00

 
 
 
Reno, Nv 89511
Natale Carsali
380 Brinkby Avenue #B 12/08/2022 $5,000.00

 
 
 
Reno, NV 89509
William Paganetti
380 Brinkby Avenue #B 12/08/2022 $5,000.00

 
 
 
Reno, NV 89509
Boyd Social Gaming LLC 12/08/2022 $5,000.00
6465 South Rainbow Boulevard
12/08/2022 $5,000.00
 
 
 
Las Vegas, NV 89118
California Hotel Finance Company 12/08/2022 $5,000.00
6465 South Rainbow Boulevard
12/08/2022 $5,000.00
 
 
 
Las Vegas, NV 89118
BGM Co Inc 12/08/2022 $5,000.00
6465 South Rainbow Boulevard
12/08/2022 $5,000.00
 
 
 
Las Vegas, NV 89118
Nevada Palace LLC 12/08/2022 $5,000.00
255 Boulder Highway
12/08/2022 $5,000.00
 
 
 
Las Vegas, NV 89122
KLOS Radio LLC 12/08/2022 $5,000.00
 
 
 
2600 West Olive Avenue #800

HB 00380
Burbank, CA 91505 12/08/2022 $5,000.00
Lewis Roca
201 East Washington Street #1200 12/08/2022 $5,000.00

 
 
 
Phoenix, AZ 85004
Norine Seeno
1850 Mount Diablo Boulevard #440 12/08/2022 $5,000.00

 
 
 
Walnut Creek, CA 94596
Thomas Seeno
1850 Mount Diablo Boulevard #440 12/08/2022 $5,000.00

 
 
 
Walnut Creek, CA 94596
Cox Communications 12/08/2022 $5,000.00
1700 Vegas Dr

 
 
 
Las Vegas, NV 89106 12/08/2022 $5,000.00
Fujisan Franchising Corp 12/08/2022 $5,000.00
14420 Bloomfield Avenue

 
 
 
Santa Fe Springs, CA 90670 12/08/2022 $5,000.00
Nevada Beer Wholesalers Association
PAC
1 East Liberty Street #300 12/08/2022 $5,000.00

 
 
 
Reno, NV 89501
Behavioral Health Solutions 12/10/2022 $5,000.00
2200 Paseo Verde Parkway #190

 
 
 
Henderson, NV 89052 12/10/2022 $200.00
Debra Struhsacker 12/10/2022 $20.00
30 Sharps Cir

 
 
 
Reno, NV 89519 12/10/2022 $500.00
12/10/2022 $1,000.00
Pete Ciarrocchi 12/10/2022 $200.00
489 Bristol Pike
12/10/2022 $5,000.00

 
 
 
Bensalem, PA 19020
12/10/2022 $40.00
Greater Las Vegas Chamber of
Commerce BizPAC 12/12/2022 $5,000.00
575 Symphony Park Avenue #100 12/12/2022 $5,000.00

 
 
 
Las Vegas, NV 89106
International Union Of Operation
Engineers 12/12/2022 $5,000.00
150 Corson Street 12/12/2022 $5,000.00

 
 
 
Pasadena, CA 91103
3535 LV NewCo LLC dba The Linq 12/13/2022 $5,000.00
3535 South Las Vegas Boulevard

 
 
 
Las Vegas, NV 89109 12/13/2022 $5,000.00
Caesars Palace 12/13/2022 $5,000.00
3570 Las Vegas Blvd., South  
 
 
Las Vegas, NV 89109 12/13/2022 $5,000.00
Flamingo Las Vegas Operating Co LLC 12/13/2022 $5,000.00
3555 Las Vegas Boulevard South
 
 
 
Las Vegas, NV 89109 12/13/2022 $5,000.00
Harrah's Las Vegas Inc 12/13/2022 $5,000.00
3475 South Las Vegas Boulevard
 
 
 
Las Vegas, NV 89109 12/13/2022 $5,000.00
Paris Las Vegas 12/13/2022 $5,000.00
3655 Las Vegas Blvd. South
 
 
 
Las Vegas, NV 89019 12/13/2022 $5,000.00
Planet Hollywood Resort 12/13/2022 $5,000.00
3667 South Las Vegas Boulevard
 
 
 
Las Vegas, NV 89109 12/13/2022 $5,000.00

HB 00381
Rio Properties Inc dba Rio Suite Hotel
12/13/2022 $5,000.00
& Casino
3700 West Flamingo Road 12/13/2022 $5,000.00

 
 
 
Las Vegas, NV 89103
Corner Investment Company LLC dba
12/13/2022 $5,000.00
The Cromwell
3595 South Las Vegas Boulevard 12/13/2022 $5,000.00

 
 
 
Las Vegas, NV 89109
Bally's Las Vegas 12/13/2022 $5,000.00
3645 South Las Vegas Boulevard
12/13/2022 $5,000.00

 
 
 
Las Vegas, NV 89109
Caesars Enterprise Services LLC 12/15/2022 $5,000.00
1 Harrahs Court
12/15/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
California Hotel & Casino 12/16/2022 $5,000.00
P.O. Box 630
12/16/2022 $5,000.00

 
 
 
Las Vegas, NV 89101
Association of Gaming Equipment
Manufacturing 12/16/2022 $5,000.00
PO Box 50049 12/16/2022 $5,000.00

 
 
 
Henderson, NV 89016
Davita 12/16/2022 $5,000.00
PO Box 4328
12/16/2022 $2,000.00

 
 
 
Federal Way, WA 98063
Southwest Gas Corporation 12/16/2022 $5,000.00
PO Box 98510
12/16/2022 $5,000.00

 
 
 
Las Vegas, NV 89193
Fremont Hotel & Casino
PO Box 630 12/16/2022 $5,000.00

 
 
 
Las Vegas, NV 89101
Main Street Station Casino Brewery &
12/16/2022 $5,000.00
Hotel
PO Box 630 12/16/2022 $5,000.00

 
 
 
Las Vegas, NV 89101
Prominence Management Services 12/16/2022 $5,000.00
1510 Meadow Wood Lane
12/16/2022 $5,000.00

 
 
 
Reno, NV 89502
Vacations-Hawaii Inc 12/16/2022 $5,000.00
1585 Kapiolani Boulevard #900
12/16/2022 $5,000.00

 
 
 
Honolulu, HI 96814
Anthem Blue Cross Blue Shield
3075 Vandercar Way 12/16/2022 $5,000.00

 
 
 
Cincinnati, OH 45209
Home Building Industry PAC 12/16/2022 $5,000.00
4175 South Riley Street #100
12/16/2022 $5,000.00
 
 
 
Las Vegas, NV 89147
NVHBA PAC 12/16/2022 $5,000.00
4175 South Riley Street #100
12/16/2022 $5,000.00
 
 
 
Las Vegas, NV 89147
Builders Association of Northern
12/16/2022 $5,000.00
Nevada PAC
5484 Reno Corporate Drive 12/16/2022 $5,000.00
 
 
 
Reno, NV 89511
Boyd Development Corporation 12/16/2022 $5,000.00
6465 South Rainbow Boulevard
12/16/2022 $5,000.00
 
 
 
Las Vegas, NV 89118
Axenia Cobzac 12/16/2022 $1,000.00
 
 
 
6512 Averill Creek Ave
Las Vegas, NV 89118

HB 00382
Nevada Power Company dba NV
Energy 12/16/2022 $5,000.00
6226 West Sahara Avenue 12/16/2022 $5,000.00

 
 
 
Las Vegas, NV 89151
NV Energy Inc 12/16/2022 $5,000.00
6226 West Sahara Avenue
12/16/2022 $5,000.00

 
 
 
Las Vegas, NV 89146
Sierra Pacific Power Company DBA
NV Energy 12/16/2022 $5,000.00
6100 Neil Road 12/16/2022 $5,000.00

 
 
 
Reno, NV 89511
Bassam Said Al-Owir
767 Latina Ct. 12/16/2022 $5,000.00

 
 
 
Henderson, NV 89012-7221
James E. Nave 12/17/2022 $5,000.00
2385 E Tropicana Ave
12/17/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
Nevada Gold Mines LLC 12/19/2022 $5,000.00
1655 Mountain City Highway
12/19/2022 $5,000.00

 
 
 
Elko, NV 89801
UP Railroad Company 12/19/2022 $5,000.00
1400 Douglas Street #1560
12/19/2022 $5,000.00

 
 
 
Omaha, NE 68179
Juul Labs Inc 12/19/2022 $5,000.00
1000 F Street Northwest #800
12/19/2022 $5,000.00

 
 
 
Washington, DC 20004
Mandalay Bay Hotel & Casino 12/19/2022 $5,000.00
3950 Las Vegas Blvd. South
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
MGM Aviation Corp 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
MGM Grand Hotel & Casino 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
MGM Hospitality LLC 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
MGM Interactive LLC 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
MGM Public Policy LLC 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00  
 
 
Las Vegas, NV 89177
MGM Resorts Development 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00
 
 
 
Las Vegas, NV 89177
MGM Resorts Land Holdings LLC 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00
 
 
 
Las Vegas, NV 89177
MGM Resorts Retail 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00
 
 
 
Las Vegas, NV 89177
MGM Resorts Venue Management 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00
 
 
 
Las Vegas, NV 89177

HB 00383
MGMM Insurance Company 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
New York New York Hotel & Casino 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
Park District Holdings 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
Park MGM LLC 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
Park Theater 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
Shadow Creek 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
The Signature Condominiums LLC 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
Vdara Condo Hotel 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
VidiAd 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
Molson Coors Beverage Company
PO Box 482 12/19/2022 $2,000.00

 
 
 
Milwaukee, WI 53201
550 Leasing Company II LLC 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
Arena Land Holdings LLC 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
Aria Resort & Casino 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
Bellagio Hotel & Casino 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00
 
 
 
Las Vegas, NV 89177
Destron Inc 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00
 
 
 
Las Vegas, NV 89177
Grand Garden Arena Management 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00
 
 
 
Las Vegas, NV 89177
Las Vegas Arena Management 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00
 
 
 
Las Vegas, NV 89177
Luxor Hotel & Casino 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00
 
 
 
Las Vegas, NV 89177

HB 00384
Mandalay Place 12/19/2022 $5,000.00
PO Box 77123
12/19/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
Silver State Property Holdings
701 South Carson Street 12/20/2022 $5,000.00
Suite 200 12/20/2022 $5,000.00

 
 
 
Carson City, NV 89701
Desertlink Investments LLC 12/20/2022 $5,000.00
6226 West Sahara Avenue MS 03A
12/20/2022 $5,000.00

 
 
 
Las Vegas, NV 89146
Craig Road Animal Hospital 12/21/2022 $5,000.00
5051 West Craig Road
12/21/2022 $5,000.00

 
 
 
Las Vegas, NV 89130
Las Vegas Paiute Tribe
1 Paiute Drive 12/21/2022 $2,500.00

 
 
 
Las Vegas, NV 89106
Trop East Plaza LLC 12/21/2022 $5,000.00
2385 East Tropicana Avenue
12/21/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
CMNT LLC dba South Valley Animal
Hospital 12/21/2022 $5,000.00
2385 East Tropicana Avenue 12/21/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
JBAM LLC dba South Buffalo Springs
Animal Hospital 12/21/2022 $5,000.00
2385 East Tropicana Avenue 12/21/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
Butler Snow PAC
PO Box 6010 12/21/2022 $2,000.00

 
 
 
Ridgeland, MA 39158
Zuffa LLC 12/21/2022 $5,000.00
PO Box 26959
12/21/2022 $5,000.00

 
 
 
Las Vegas, NV 89126
FedEx Corporation PAC
942 South Shady Grove Road 12/22/2022 $5,000.00
1st floor

 
 
 
Memphis, TN 38120
Wynn Las Vegas 12/22/2022 $5,000.00
3131 Las Vegas Boulevard South
12/22/2022 $5,000.00

 
 
 
Las Vegas, NV 89109
Operating Engineers Local No 3
Statewide PAC 12/22/2022 $5,000.00
1620 South Loop Road 12/22/2022 $5,000.00

 
 
 
Alameda, CA 94502
Quality Care Consultants
1603 Villa Rica Dr 12/25/2022 $3,000.00  
 
 
Henderson, NV 89052
Abbie Friedman
28 Painted Feather Way 12/25/2022 $3,000.00
 
 
 
Las Vegas, NV 89135
Jenny Lee 12/25/2022 $120.00
4484 S Pecos Rd #100
12/25/2022 $3,000.00
 
 
 
Las Vegas, NV 89121
James Kemp 12/25/2022 $40.00
7012 Shire Ridge Ave
12/25/2022 $1,000.00
 
 
 
Las Vegas, NV 89131
Adam Muslusky 12/25/2022 $5,000.00
 
 
 
7305 Enchanted Rock Ave
Las Vegas, NV 89113 12/25/2022 $200.00

HB 00385
Republic Dumpco Inc 12/27/2022 $5,000.00
770 East Sahara Avenue
12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89104
REPUBLIC ENVIRONMENTAL
TECHNOLOGIES INC 12/27/2022 $5,000.00
770 EAST SAHARA AVENUE 12/27/2022 $5,000.00

 
 
 
LAS VEGAS, NV 89104
Republic Silver State Disposal Inc 12/27/2022 $5,000.00
770 East Sahara Avenue
12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89104
Valley Electric Association Inc
800 E Highway 372 12/27/2022 $2,000.00

 
 
 
Pahrump, NV 89041
Plaster Development Co Inc 12/27/2022 $5,000.00
801 South Rancho Drive #E4
12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89106
Thaddeus Yurek 12/27/2022 $5,000.00
815 San Gabriel Avenue
12/27/2022 $5,000.00

 
 
 
Henderson, NV 89002
Schulman Development LLC
840 South Rancho Drive #4-572 12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89106
Alamo Title Holding Company
866 Riverside Avenue 12/27/2022 $5,000.00
Bldg 5, 6th floor 12/27/2022 $5,000.00

 
 
 
Jacksonville, FL 32204
Steven Chesin
8714 Mayport Drive 12/27/2022 $2,500.00

 
 
 
Las Vegas, NV 89131
Daniel Anderson 12/27/2022 $5,000.00
7021 North Cuckoo Clock Street
12/27/2022 $5,000.00

 
 
 
North Las Vegas, NV 89084
Natalie Willis
620 Chervil Valley Drive 12/27/2022 $2,500.00

 
 
 
Las Vegas, NV 89138
Nevada State Apartment Association 12/27/2022 $5,000.00
6276 South Rainbow Boulevard #110
12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
The Aviator 12/27/2022 $5,000.00
6655 South Eastern Avenue #200
12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
Pahrump Nugget Hotel & Casino 12/27/2022 $5,000.00
681 South Highway 160
12/27/2022 $5,000.00  
 
 
Pahrump, NV 89408
Lakeside Casino & RV Park 12/27/2022 $5,000.00
5870 Homestead Road
12/27/2022 $5,000.00
 
 
 
Pahrump, NV 89048
Nevada Subcontractors Association
12/27/2022 $5,000.00
PAC
5795 South Rogers Street 12/27/2022 $5,000.00
 
 
 
Las Vegas, NV 89118
Cooper Roofing & Solar LLC 12/27/2022 $5,000.00
5795 South Rogers Street #A
12/27/2022 $5,000.00
 
 
 
Las Vegas, NV 89118
Chicago Title And Trust
601 Riverside Avenue 12/27/2022 $5,000.00
Bldg 5, 6th floor 12/27/2022 $5,000.00
 
 
 
Jacksonville, FL 32204

HB 00386
Chicago Title Company
601 Riverside Avenue 12/27/2022 $5,000.00
Bldg 5, 6th floor 12/27/2022 $5,000.00

 
 
 
Jacksonville, FL 32204
Chicago Title Insurance Company
601 Riverside Avenue 12/27/2022 $5,000.00
Bldg 5, 6th floor 12/27/2022 $5,000.00

 
 
 
Jacksonville, FL 32204
Commonwealth Land Title Insurance
Company 12/27/2022 $5,000.00
601 Riverside Avenue
12/27/2022 $5,000.00

 
 
 
Bldg 5, 6th floor
Jacksonville, FL 32204
Fidelity National Financial
601 Riverside Avenue 12/27/2022 $5,000.00
Bldg 5, 6th floor 12/27/2022 $5,000.00

 
 
 
Jacksonville, FL 32204
Fidelity National Title Insurance
Company 12/27/2022 $5,000.00
601 Riverside Avenue
12/27/2022 $5,000.00

 
 
 
Bldg 5, 6th floor
Jacksonville, FL 32204
Fntg Holdings LLC
601 Riverside Avenue 12/27/2022 $5,000.00
Bldg 5, 6th floor 12/27/2022 $5,000.00

 
 
 
Jacksonville, FL 32204
Fnts Holdings LLC
601 Riverside Avenue 12/27/2022 $5,000.00
Bldg 5 6th floor 12/27/2022 $5,000.00

 
 
 
Jacksonville, FL 32204
National Title Insurance of New York
Inc 12/27/2022 $5,000.00
601 Riverside Avenue
12/27/2022 $5,000.00

 
 
 
Bldg 5, 6th floor
Jacksonville, FL 32204
Orion Manchester Development
601 Riverside Avenue 12/27/2022 $5,000.00
Bldg 5, 6th floor

 
 
 
Jacksonville, FL 32204
Rocky Mountain Support Services
601 Riverside Avenue 12/27/2022 $5,000.00
Bldg 5, 6th floor 12/27/2022 $5,000.00

 
 
 
JACKSONVILLE, FL 32204
Ovation Design & Development Inc 12/27/2022 $5,000.00
6021 South Fort Apache Road #100
12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89148
Security Title Agency Inc 12/27/2022 $5,000.00
3410 East University Drive #200
12/27/2022 $5,000.00
 
 
 
Phoenix, AZ 85034
Reno Sparks Indian Colony
34 Reservation Road 12/27/2022 $1,000.00
 
 
 
Reno, NV 89502
Power House Plastering Inc
3485 John Peter Lee Avenue 12/27/2022 $2,500.00
 
 
 
North Las Vegas, NV 89032
Nevada Society Of Architects AIA NV
PAC
12/27/2022 $5,000.00
401 South 4th Street #175
 
 
 
Las Vegas, NV 89101
The Griffin Company LLC 12/27/2022 $5,000.00
401 South Curry Street
12/27/2022 $5,000.00
 
 
 
Carson City, NV 89701

HB 00387
Louis Polish
4270 West Patrick Lane 12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
CO2 Monitoring LLC 12/27/2022 $5,000.00
4310 Cameron Street #7
12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89103
Diamond Sloan LLC
5052 South Jones Boulevard #110 12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
Broadcasters Open Air Marketplace
LLC
12/27/2022 $5,000.00
4695 Macarthur Court #1420

 
 
 
Newport Beach, CA 92660
Classic Door & Trim Co Inc
4625 South Wynn Road #1 12/27/2022 $1,000.00

 
 
 
Las Vegas, NV 89103
GRG Enterprises LLC 12/27/2022 $5,000.00
284 Flathead Avenue #200
12/27/2022 $5,000.00

 
 
 
Whitefish, MT 59937
Hirschi Masonry LLC
2912 East La Madre Way 12/27/2022 $5,000.00

 
 
 
North Las Vegas, NV 89081
Fisher Brothers Financial &
Development Company LLC 12/27/2022 $5,000.00
299 Park Avenue 12/27/2022 $5,000.00

 
 
 
New York, NY 10171
99 Restaurants Holdings LLC 12/27/2022 $5,000.00
3038 Sidco Drive
12/27/2022 $5,000.00

 
 
 
Nashville, TN 37204
O'Charley's LLC 12/27/2022 $5,000.00
3038 Sidco Drive
12/27/2022 $5,000.00

 
 
 
Nashville, TN 37204
Town Center Animal Hospital 12/27/2022 $5,000.00
2385 East Tropicana Avenue
12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
Durango Animal Hospital 12/27/2022 $5,000.00
2385 East Tropicana Avenue
12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89119
Dustin Petty
242 North 57th Street 12/27/2022 $1,500.00

 
 
 
Scottsdale, AZ 85257
Bicentennial Animal Hospital LLC dba
Inspirada Animal Hospital 12/27/2022 $5,000.00
2385 East Tropicana Avenue 12/27/2022 $5,000.00  
 
 
Las Vegas, NV 89119
Centennial Hills Animal Hospital 12/27/2022 $5,000.00
2385 East Tropicana Avenue
12/27/2022 $5,000.00
 
 
 
Las Vegas, NV 89119
Triple Contracting LLC
2335 Silver Wolf Drive 12/27/2022 $2,500.00
 
 
 
Henderson, NV 89011
Kaempfer Crowell 12/27/2022 $5,000.00
1980 Festival Plaza Drive #650
12/27/2022 $5,000.00
 
 
 
Las Vegas, NV 89135
Scott Donnelly 12/27/2022 $5,000.00
2121 Thoroughbred Road
12/27/2022 $5,000.00
 
 
 
Henderson, NV 89002

HB 00388
Core Group Investments LLC
1635 Village Center Circle #100 12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89134
Nevada Optometric PAC 12/27/2022 $5,000.00
1344 Disc Drive #185
12/27/2022 $5,000.00

 
 
 
Sparks, NV 89436
Jerry Petty
14586 West Village Parkway 12/27/2022 $1,500.00

 
 
 
Litchfield Park, AZ 85340
Cannae Holdings LLC 12/27/2022 $5,000.00
1701 Village Center Circle
12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89134
American Rental Association
1900 19th Street 12/27/2022 $2,500.00

 
 
 
Moline, IL 61265
Breakthru Beverage Nevada, LLC, 12/27/2022 $2,500.00
1849 West Cheyenne Avenue
12/27/2022 $5,000.00

 
 
 
North Las Vegas, NV 89032
Thomas j Burns
1833 Glenview Drive 12/27/2022 $1,000.00

 
 
 
Las Vegas, NV 89134
McDonald Carano
12/27/2022 $5,000.00
100 West Liberty Street
10th floor 12/27/2022 $5,000.00

 
 
 
Reno, NV 89501
Justin Manning
10091 West Park Run Drive #200 12/27/2022 $500.00

 
 
 
Las Vegas, NV 89145
Pattern PAC
1088 Sansome Street 12/27/2022 $2,500.00

 
 
 
San Francisco, CA 94111
Rachel Boehrer
1155 Kingston Hills Court 12/27/2022 $2,500.00

 
 
 
Henderson, NV 89002
Nielson Consulting LLC 12/27/2022 $5,000.00
9555 Hillwood Drive #103
12/27/2022 $5,000.00

 
 
 
Las Vegas, NV 89134
Caroline Nielson
9037 Waterfield Court 12/27/2022 $1,500.00

 
 
 
Las Vegas, NV 89134
Mary Alice Nielson 12/27/2022 $5,000.00
9037 Waterfield Court
12/27/2022 $5,000.00
 
 
 
Las Vegas, NV 89134
Nicholas Nielson
9037 Waterfield Court 12/27/2022 $2,500.00
 
 
 
Las Vegas, NV 89134
Scott M. Nielson 12/27/2022 $5,000.00
9037 Waterfield Ct.
12/27/2022 $5,000.00
 
 
 
Las Vegas, NV 89134
Lumen Technologies Service Group Llc
PO Box 4065 12/27/2022 $1,000.00
 
 
 
Monroe, LA 71211
Jon Porter 12/27/2022 $5,000.00
PO Box 60877
12/27/2022 $5,000.00
 
 
 
Boulder City, NV 89006
Nevadans For Reliable Renewable 12/30/2022 $5,000.00
 
 
 
Affordable Energy

HB 00389
9213 Pitching Wedge Drive
Las Vegas, NV 89134
UnitedHealth Group Inc 12/30/2022 $5,000.00
PO Box 1459
12/30/2022 $5,000.00

 
 
 
Minneapolis, MN 55440
GAI PAC 12/30/2022 $5,000.00
110-00 Rockaway Boulevard
12/30/2022 $5,000.00

 
 
 
Queens, NY 11420
R Trent Mcauliffe
1 East Liberty Street #600 12/30/2022 $1,000.00

 
 
 
Reno, NV 89501
Robert Kilby
1895 Plumas Street #4 12/30/2022 $5,000.00

 
 
 
Reno, NV 89509
Wells Fargo & Co Employee PAC
1700 K Street Northwest
8th floor 12/30/2022 $2,500.00

 
 
 
Washington, DC 20006
District Council Of Iron Workers
1660 San Pablo Avenue #C 12/30/2022 $5,000.00

 
 
 
Pinole, CA 94564
Rodney Atamian
1805 White Hawk Ct 12/30/2022 $1,250.00

 
 
 
Las Vegas, NV 89134
Kimberly Santos
14205 Prairie Flower Court 12/30/2022 $5,000.00

 
 
 
RENO, NV 89511
Nicole Steinhaus
2006 Pin Oak Avenue 12/30/2022 $500.00

 
 
 
Las Vegas, NV 89101
Law Office Of Jason H Weinstock
PLLC
12/30/2022 $1,000.00
2470 Saint Rose Parkway #310

 
 
 
Henderson, NV 89074
Wynn Resorts Ltd 12/30/2022 $5,000.00
3131 Las Vegas Boulevard South
12/30/2022 $5,000.00

 
 
 
Las Vegas, NV 89109
Expo & Convention Center LLC 12/30/2022 $5,000.00
3355 South Las Vegas Boulevard
12/30/2022 $5,000.00

 
 
 
Las Vegas, NV 89109
Venetian Las Vegas Gaming LLC 12/30/2022 $5,000.00
3355 South Las Vegas Boulevard
12/30/2022 $5,000.00

 
 
 
Las Vegas, NV 89109
Venetian Las Vegas Marketing Inc 12/30/2022 $5,000.00
3355 South Las Vegas Boulevard
12/30/2022 $5,000.00
 
 
 
Las Vegas, NV 89109
Las Vegas Jet LLC 12/30/2022 $5,000.00
3131 Las Vegas Boulevard South
12/30/2022 $5,000.00
 
 
 
Las Vegas, NV 89109
Wynn Golf LLC 12/30/2022 $5,000.00
3131 Las Vegas Boulevard South
12/30/2022 $5,000.00
 
 
 
Las Vegas, NV 89109
Terry Friedman & Julie Throop PLLC
300 South Arlington Avenue 12/30/2022 $1,000.00
 
 
 
Reno, NV 89501
Ida Ybarra 12/30/2022 $1,000.00
 
 
 
297 Pastel Cloud Street
Henderson, NV 89015

HB 00390
BLC Management Company LLC 12/30/2022 $5,000.00
4675 West Teco Avenue #250
12/30/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
MM Development Company Inc 12/30/2022 $5,000.00
4675 West Teco Avenue #250
12/30/2022 $5,000.00

 
 
 
Las Vegas, NV 89118
Zachary Huffman
4801 Spencer Street #228 12/30/2022 $300.00

 
 
 
Las Vegas, NV 89119
RAI Services Company 12/30/2022 $5,000.00
401 North Main Street
12/30/2022 $5,000.00

 
 
 
Winston-Salem, NC 27101
Mariano & Associates PLLC
3500 Lakeside Court #130 12/30/2022 $1,000.00

 
 
 
Reno, NV 89509
Locus Development Group LLC 12/30/2022 $5,000.00
6001 Talbot Lane
12/30/2022 $5,000.00

 
 
 
Reno, NV 89509
Yott Beckett
6900 South McCarran Boulevard
12/30/2022 $5,000.00
#3040

 
 
 
Reno, NV 89509
Behzadi Law Offices LLC
6655 West Sahara Avenue #A-208 12/30/2022 $4,000.00

 
 
 
Las Vegas, NV 89146
Bertoldo Baker Carter & Smith
7408 West Sahara Avenue 12/30/2022 $2,500.00

 
 
 
Las Vegas, NV 89117
Catkill Support Committee Pac 12/30/2022 $5,000.00
888 Resorts World Drive
12/30/2022 $5,000.00

 
 
 
Monticello, NY 12701
craig Kidwell
790 Commercial St 12/31/2022 $5,000.00

 
 
 
Elko, NV 89801
Marjorie Hauf
710 S 9th St 12/31/2022 $1,000.00

 
 
 
Las Vegas, NV 89101
Jonathan Roven
6119 Goodland Ave 12/31/2022 $150.00

 
 
 
North Hollywood, CA 91606
Richard Schonfeld
520 S 4th St 12/31/2022 $5,000.00
 
 
 
Las Vegas, NV 89101
Ferrari Reeder Public Affairs
527 Lander St 12/31/2022 $2,500.00
 
 
 
Reno, NV 89509
Hicks & Brasier PLLC
2630 South Jones Boulevard 12/31/2022 $1,000.00
 
 
 
Las Vegas, NV 89146
BillieMarie Morrison
1412 Via Merano St 12/31/2022 $1,000.00
 
 
 
Henderson, NV 89052
MGM Resorts Arena Holdings LLC 12/31/2022 $5,000.00
PO Box 77123
12/31/2022 $5,000.00
 
 
 
Las Vegas, NV 89177

HB 00391
Joel Santos
PO Box 41184 12/31/2022 $1,000.00

 
 
 
Reno, NV 89504
Metropolitan Marketing 12/31/2022 $5,000.00
PO Box 77123
12/31/2022 $5,000.00

 
 
 
Las Vegas, NV 89177
 
WRITTEN COMMITMENTS Report Period   # 4
 
Joseph Lombardo Governor Clark County
Name (print) Office (if applicable) District (if applicable)

WRITTEN COMMITMENTS FOR CONTRIBUTIONS IN EXCESS OF $100 OR,


WHEN ADDED TOGETHER FROM ONE ENTITY, THAT EXCEED $100
(Transfer Total Amount of All Written Commitments to Line 4 of Contributions Summary)

NAME AND ADDRESS OF PERSON, GROUP OR DATE OF AMOUNT OF


ORGANIZATION WHO MADE THE COMMITMENT COMMITMENT COMMITMENT
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HB 00392
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
IN KIND CONTRIBUTIONS Report Period   # 4
 
Joseph Lombardo Governor Clark County
Name (print) Office (if applicable) District (if applicable)

IN KIND CONTRIBUTIONS IN EXCESS OF $100 OR,


WHEN ADDED TOGETHER FROM ONE CONTRIBUTOR, THAT EXCEED $100
(Transfer Total Value of All In Kind Contributions to Line 5 of Contributions Summary)

NAME AND ADDRESS OF DATE OF DESCRIPTION VALUE OR COST CHECK NAME AND NAME AND
PERSON, GROUP OR IN KIND OF IN KIND OF IN KIND HERE IF ADDRESS OF 3rd ADDRESS OF
ORGANIZATION WHO MADE CONTRIBUTION CONTRIBUTION CONTRIBUTION LOAN PARTY IF LOAN PERSON, GROUP
IN KIND CONTRIBUTION OR ORGANIZATION

HB 00393
GUARANTEED BY WHO FORGAVE THE
3rd PARTY LOAN, IF
DIFFERENT THAN
CONTRIBUTOR
Mechanical Contractors
Association of Las Vegas
2640 South Jones Boulevard 10/07/2022 Catering Services $1,604.70

 
 
 
Suite 1
Las Vegas, NV 89146
Sheet Metal And Air
Conditioning Contractors'
National Association of
Southern Nevada 10/07/2022 Catering Services $1,604.69

 
 
 
2640 South Jones Boulevard
Suite 4
Las Vegas, NV 89146
Gary Pestello
10198 Via Verona 10/25/2022 Facility Fees $250.00

 
 
 
Reno, NV 89511
Donna Maland
10549 Santo Marco Court 10/25/2022 Facility Fees $250.00

 
 
 
Las Vegas, NV 89135
Flynn Giudici Government
Affairs
10/25/2022 Catering Services $2,388.69
708 North Center Street

 
 
 
Reno, NV 89501
Ashok Mirchundani
10570 Hope Mills Dr 11/02/2022 Facility Fees $6,500.00

 
 
 
Las Vegas, NV 89135
Real NV
Text Messaging
410 South Minnesota Street 11/14/2022 Services $5,000.00

 
 
 
Carson City, NV 89703
United Signs Inc
5234 South Procyon Street 11/15/2022 Sign Frames $7,500.00

 
 
 
Las Vegas, NV 89118
Alex Meruelo
2500 East 2nd Street 12/06/2022 Catering Services $4,790.00

 
 
 
Reno, NV 89502
 
HB 00394
WRITTEN COMMITMENTS FOR IN KIND
Report Period   # 4

 
 CONTRIBUTIONS

Joseph Lombardo Governor Clark County


Name (print) Office (if applicable) District (if applicable)

WRITTEN COMMITMENTS FOR IN KIND CONTRIBUTIONS IN EXCESS OF $100 OR,


WHEN ADDED TOGETHER FROM ONE ENTITY, THAT EXCEED $100
(Transfer Total Value of All In Kind Written Commitments to Line 6 of Contributions Summary)

NAME AND ADDRESS OF PERSON, GROUP OR DATE OF IN KIND VALUE OF IN KIND


ORGANIZATION WHO MADE THE IN KIND WRITTEN WRITTEN COMMITMENT
COMMITMENT WRITTEN COMMITMENT
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
HB 00395
 
 
 
 
EXPENSE CATEGORIES Report Period   # 4
 
Joseph Lombardo Governor Clark County
Name (print) Office (if applicable) District (if applicable)

EXPENSE CATEGORIES (NRS 294A.365)

 CATEGORIES  CODE

 Office expenses A

 Expenses related to volunteers B

 Expenses related to travel C

 Expenses related to advertising D

 Expenses related to paid staff E

 Expenses related to consultants F

 Expenses related to polling G

HB 00396
 Expenses related to special events H

 Expenses related to legal defense fund I

Goods and services provided in kind for which money would  otherwise
J
have been paid

Contributions made to: (i) another candidate; (ii) a nonprofit corporation


that is registered or required to be registered pursuant to NRS 294A.225;
(iii) a PAC that is registered or required to be registered pursuant to NRS K
294A.230; or (iv) a Recall Committee that is registered or required to be
registered pursuant to NRS 294A.250

 Fees for filing declarations of candidacy or acceptances of candidacy L

 Repayments or forgiveness of loans M

 Disposal of unspent contributions pursuant to NRS 294A.160 N

 Other miscellaneous expenses O

1   NRS 294A.362 requires “In Kind” contributions and expenses to be reported on a separate form, which is attached hereto.

MONETARY EXPENSES Report Period   # 4


 
Joseph Lombardo Governor Clark County
Name (print) Office (if applicable) District (if applicable)

MONETARY EXPENSES IN EXCESS OF $100


(Transfer Total Amount of All Campaign Expenses to Line 9 of Expenses Summary)

NAME AND ADDRESS OF PERSON, GROUP OR CATEGORY DATE OF AMOUNT OF


ORGANIZATION WHO RECEIVED THE PAYMENT EXPENSE
(NRS 294A.365) EXPENSE
FOR THE EXPENSE

Integrated Solutions: Political A 10/02/2022 $325.00


4142 Adams Avenue A 11/02/2022 $325.00
#103-550
San Diego, CA 92116 A 12/02/2022 $325.00

HB 00397
O 10/03/2022 $30.00
O 10/13/2022 $15.00
O 10/13/2022 $15.00
O 10/14/2022 $15.00
O 10/14/2022 $25.00
O 10/17/2022 $25.00
O 10/20/2022 $15.00
O 10/21/2022 $30.00
O 10/28/2022 $25.00

Nevada State Bank O 10/31/2022 $2.50


6505 N Buffalo Dr #10 O 10/31/2022 $30.00
Las Vegas, NV 89131 O 10/31/2022 $62.50
O 11/04/2022 $25.00
O 11/30/2022 $2.50
O 12/08/2022 $15.00
O 12/08/2022 $15.00
O 12/08/2022 $15.00
O 12/08/2022 $15.00
O 12/20/2022 $15.00
O 12/20/2022 $15.00
O 12/20/2022 $4.00
Spring Valley Market Place, LLC A 10/03/2022 $648.00
50 S Jones Blvd #100
Las Vegas, NV 89107 A 10/31/2022 $648.00
Biggest Little Investments, LLP A 10/03/2022 $1,300.00
3652 S Virginia St
Suite C7 A 10/31/2022 $1,300.00
Reno, NV 89502 A 11/04/2022 $650.00
Del Mar Advertising
901 Fremont St D 10/03/2022 $2,250.00
Unit 105 D 11/08/2022 $1,800.00
Las Vegas, NV 89101
The Tarrance Group Inc
201 N Union St G 10/03/2022 $19,405.00
Suite 410
Alexandria, VA 22314
D 10/03/2022 $271,832.74
D 10/07/2022 $423,691.58
D 10/13/2022 $199,292.12
Strategic Media Services
4601 Fairfax Drive D 10/13/2022 $250,000.00
Suite 730 D 10/21/2022 $727,023.14
Arlington, VA 22203
D 10/28/2022 $250,000.00
D 10/31/2022 $595,239.56
D 11/04/2022 $51,609.50
WinRed Technical Services, LLC O 10/06/2022 $1,941.10
1776 Wilson Boulevard #530
Arlington, VA 22209 O 10/10/2022 $178.87
O 10/15/2022 $2,530.59
O 10/23/2022 $5,598.25
O 10/24/2022 $1,700.81
O 10/24/2022 $661 34
HB 00398
O 10/24/2022 $661.34
O 10/25/2022 $319.52
O 10/26/2022 $681.83
O 10/29/2022 $581.58
O 10/30/2022 $654.81
O 10/31/2022 $1,686.61
O 11/01/2022 $231.12
O 11/02/2022 $1,314.20
O 11/05/2022 $271.10
O 11/06/2022 $1,510.71
O 11/08/2022 $1,457.15
O 11/08/2022 $44.95
O 11/19/2022 $255.10
O 11/26/2022 $68.38
O 12/03/2022 $152.61
O 12/06/2022 $965.33
O 12/10/2022 $546.66
O 12/17/2022 $359.73
O 12/25/2022 $569.70
O 12/31/2022 $681.64
O 10/06/2022 $137.60
O 10/10/2022 $8.00
O 10/15/2022 $56.00
O 10/23/2022 $348.00
Reach Right Digital Marketing, LLC O 10/24/2022 $56.00
6501 Red Hook Road PMB 927
St Thomas, VI 802 O 10/24/2022 $28.00
O 10/26/2022 $148.80
O 10/29/2022 $16.00
O 10/31/2022 $20.00
O 11/08/2022 $16.00
A, H 10/07/2022 $27.32
E 10/14/2022 $500.00
Diana Durkee
5176 Fading Sunset Dr E 10/31/2022 $500.00
Las Vegas, NV 89135 E 11/15/2022 $500.00
E 11/30/2022 $500.00
F, A 10/07/2022 $21,525.26
Red Rock Strategies
9500 West Flamingo Road F 11/04/2022 $42,563.70
Suite 203 A, D 11/30/2022 $4,142.20
Las Vegas, NV 89147
F 12/16/2022 $121,240.80
TMP Entertainment Film Inc
1400 Colorado St Suite C F 10/07/2022 $875.00
Boulder City, NV 89005
Media Placement Services D 10/14/2022 $5,000.00
PO Box 753771
Las Vegas, NV 89136 D 11/08/2022 $25,000.00
Department of the Treasury E 10/14/2022 $665.20
Internal Revenue Service
Ogden, UT 84201 E 10/31/2022 $665.20
E 11/15/2022 $665 20
HB 00399
E 11/15/2022 $665.20
E 11/30/2022 $2,195.20
E 10/14/2022 $15.00
E 10/25/2022 $172.53
Nevada DETR
2800 East Saint Louis Avenue E 10/31/2022 $15.00
Las Vegas, NV 89104
E 11/15/2022 $15.00
E 11/30/2022 $15.00
E 10/14/2022 $4,822.85
Matthew Brasseaux
4825 South Rainbow Boulevard E 10/31/2022 $4,822.85
Suite 212 E 11/15/2022 $4,822.85
Las Vegas, NV 89103
E 11/30/2022 $24,822.85
E 10/14/2022 $3,333.33
Elizabeth Ray E 10/31/2022 $3,333.33
1055 East Tropicana Avenue #442-D
Las Vegas, NV 89119 E 11/15/2022 $3,333.33
E 11/30/2022 $3,333.33
O 10/15/2022 $98.00
Pop Acta Media Inc
10 Fairway Drive O 10/23/2022 $56.00
Suite 180V O 10/31/2022 $17.50
Deerfield Beach, FL 33441
O 11/08/2022 $14.00
LVPMSA Charitable Foundation
801 S Rancho Dr, Ste A1 K 10/21/2022 $1,200.00
Las Vegas, NV 89106
Investment Concepts
REFUND OF CONTRIBUTION O 10/23/2022 $5,200.00
2009 Eagle Trace Way
Las Vegas, NV 89117
A 10/25/2022 $208.77

NV Energy A 10/31/2022 $164.97


6226 W Sahara Ave A 11/23/2022 $207.16
Las Vegas, NV 89146 A 12/01/2022 $100.89
A 12/20/2022 $339.97
V Is For Victory
REFUND OF CONTRIBUTION O 10/27/2022 $4,000.00
1930 Village Center Cir #3-179 O 10/27/2022 $5,000.00
Las Vegas, NV 89134
Carson Nugget Casino
507 North Carson Street H 10/28/2022 $715.00
Carson City, NV 89701
D 10/31/2022 $1,000.00
Tatango D 10/31/2022 $1,000.00
600 Stewart St Suite 400
Seattle, WA 98101 D 10/31/2022 $199.00
D 11/30/2022 $199.00
Remington Research Group
800 W 47th St D 10/31/2022 $1,500.00
Suite 200
Kansas City, MO 64112
Ace Specialties
900 Evangeline Dr A 10/31/2022 $1,170.24
Lafayette, LA 70501
The Gober Group PLLC F 10/31/2022 $5,850.90
PO Box 341016
Austin, TX 78734 F 11/08/2022 $1,390.00

HB 00400
Ralston Reports
2175 Spur Ct A 10/31/2022 $600.00
Las Vegas, NV 89135

RSVP Party Rentals A 10/31/2022 $557.99


4445 South Valley Vieww Blvd Ste 7 A 10/31/2022 $139.08
Las Vegas, NV 89103-4010 A 10/31/2022 $91.78
Hotel Midtown Atlanta
188 14Th St North East C 10/31/2022 $789.31
Atlanta, GA 30361-2003
Latin Chamber of Commerce
300 North 13th St H 10/31/2022 $450.00
LAS VEGAS, NV 89101
FLS Connect, LLC
7300 Hudson Blvd A, D 10/31/2022 $456.26
Suite 270 A, D 11/30/2022 $255.57
Saint Paul, MN 55128
C 10/31/2022 $372.01
Courtyard C 10/31/2022 $238.18
3870 S Carson St
Carson City, NV 89701 C 11/30/2022 $389.61
C 11/30/2022 $419.45
Saint John the Baptist Greek Orthodox Church
5300 El Camino Rd H 10/31/2022 $375.00
Las Vegas, NV 89118
In Compliance Inc.
PO Box 751271 F 10/31/2022 $11,845.50
Las Vegas, NV 89136
C 10/31/2022 $18.00
C 10/31/2022 $40.00
Harry Reid International Airport C 11/30/2022 $36.00
5757 Wayne Newton Blvd
Las Vegas, NV 89111 C 11/30/2022 $36.00
C 11/30/2022 $36.00
C 11/30/2022 $14.00
A 10/31/2022 $14.99
A 11/30/2022 $30.33
Amazon
410 Terry Ave N A 11/30/2022 $149.40
Seattle, WA 98109
A 11/30/2022 $14.99
A 11/30/2022 $145.57
A 10/31/2022 $9.53
A 10/31/2022 $36.55

Office Depot A 10/31/2022 $31.96


4827 Kietzke Ln A 10/31/2022 $57.96
Reno, NV 89509 A 10/31/2022 $43.34
A 10/31/2022 $95.11
A 11/30/2022 $13.07
Chevron C 10/31/2022 $40.55
6001 Bollinger CP RD
San Ramon, CA 94583 C 11/30/2022 $72.66
Albertsons A 10/31/2022 $62.73
10140 West Flamingo Rd
Las Vegas, NV 89147 A 10/31/2022 $137.41
A 10/31/2022 $52.24

HB 00401
0/3 / 0 $5
A 10/31/2022 $195.52
A 10/31/2022 $64.90
Walmart
4855 Kietzke Ln A 10/31/2022 $281.35
RENO, NV 89509
A 11/30/2022 $491.80

Triple George Grill C 10/31/2022 $69.41


206 North 3rd St C 10/31/2022 $72.64
Las Vegas, NV 89101 C 11/30/2022 $29.84
A 10/31/2022 $70.00

Clean Tastic, LLC A 10/31/2022 $140.00


7880 Fall Harvest Dr A 10/31/2022 $80.00
Las Vegas, NV 89147-3797 A 11/30/2022 $175.00
A 11/30/2022 $140.00
Monday.com A 10/31/2022 $150.00
800 South St Suite 640
Waltham, MA 2453 A 11/30/2022 $150.00
Rachel's Kitchen
3330 South Hualapai Way Ste 190 C 10/31/2022 $154.22
Las Vegas, NV 89117
Home Depot A 10/31/2022 $155.71
861 S Rainbow Blvd
Las Vegas, NV 89145-6238 A 10/31/2022 $27.87
A 10/31/2022 $119.16
A 10/31/2022 $262.23
Smiths A 11/30/2022 $59.39
10100 West Tropicana Ave
Las Vegas, NV 89147-8459 A 11/30/2022 $39.96
A 11/30/2022 $277.80
A 11/30/2022 $91.26
At&t A 10/31/2022 $117.65
208 S Akard S
Dallas, TX 75202-4208 A 11/30/2022 $117.65
O 10/31/2022 $85.43
DiBella Flowers O 10/31/2022 $85.43
2021 W Charleston Blvd
Las Vegas, NV 89102 O 10/31/2022 $88.52
O 11/30/2022 $181.67
A 10/31/2022 $90.00
Google A 10/31/2022 $48.43
1600 Amphitheatre Pkwy
Mountain View, CA 94043-1351 A 11/30/2022 $47.49
A 11/30/2022 $90.00
Ducks Unlimited
1 Waterfowl Way A 10/31/2022 $200.00
Memphis, TN 38120
Charter Communications A 10/31/2022 $142.96
PO Box 94188
Palatin, IL 60094 A 11/08/2022 $145.10
Cox Communications A 10/31/2022 $256.06
1700 Vegas Dr
Las Vegas, NV 89106 A 11/30/2022 $270.89
Starbucks H 10/31/2022 $266.22
3370 South Hualapai Way

HB 00402
Las Vegas, NV 89117
Majority Strategies, LLC
PO Box 679219 A, D 11/04/2022 $1,035.00
Dallas, TX 75267
Axiom Strategies
800 W 47th St
Suite 200 H, C 11/04/2022 $8,249.14
Kansas City, MO 64112
Autumn Productions D, F 11/04/2022 $24,860.00
PO Box 371553
Las Vegas, NV 89137 A, D 11/08/2022 $1,267.49
The Tarrance Group
201 N Union St
Suite 410 G 11/04/2022 $17,483.00
Alexandria, VA 22314
October Inc A, C, F 11/04/2022 $125,939.79
PO Box 370672
LAS VEGAS, NV 89137 A, C, F 11/30/2022 $147,786.88
Three Sticks Productions
2036 Whitecliff Dr G 11/04/2022 $27,150.00
Reno, NV 89521
MO Strategies Inc F 11/04/2022 $37,400.00
PO Box 4
Westfield, IN 46074 F 11/30/2022 $2,200.00
Patrick Lewis
REFUND OF CONTRIBUTION
O 11/05/2022 $10,000.00
1620 Bayonne Dr
Las Vegas, NV 89134
Fabulous Freddy's Car Wash
REFUND OF CONTRIBUTION
4350 S Durango O 11/08/2022 $200.00
Las Vegas, NV 89147
C 11/30/2022 $36.00
Spirit Airlines C 11/30/2022 $107.59
18121 East 8 Mile Rd Ste 100
Eastpointe, MI 48021-3241 C 11/30/2022 $120.59
C 11/30/2022 $165.59

Red Rock Hotel and Casino H 11/30/2022 $276.85


11011 West Charleston Blvd H 11/30/2022 $2,073.55
Las Vegas, NV 89135-1402 H 11/30/2022 $5,836.05

NATIONAL CAR RENTAL C 11/30/2022 $318.66


2001 E Plumb Ln C 11/30/2022 $493.73
Reno, NV 89502 C 11/30/2022 $350.46
C 11/30/2022 $179.84
C 11/30/2022 $177.84
Towneplace Suites
2625 East Jennings Way C 11/30/2022 $177.84
Elko, NV 89801 C 11/30/2022 $177.84
C 11/30/2022 $204.55
Southwest Airlines C 11/30/2022 $212.98
PO Box 36611
Dallas, TX 75235 C 11/30/2022 $342.98
C 11/30/2022 $400.98
C 11/30/2022 $400.98
C 11/30/2022 $400.98
C 11/30/2022 $400.98
C 11/30/2022 $350 98
HB 00403
C 11/30/2022 $350.98
C 11/30/2022 $216.70
Aloft
2015 Terminal Way C 11/30/2022 $216.70
Reno, NV 89502
C 11/30/2022 $223.70
Great Basin Brewing
5525 South Virginia St C 11/30/2022 $106.61
Reno, NV 89502-6085
Target
33 South 6th St Ste CC1 A 11/30/2022 $107.79
Minneapolis, MN 55402-3700
The Grid
1120 Taylor Pl C 11/30/2022 $111.89
Fallon, NV 89406-7878
ELKO CONVENTION & VISITORS AUTHORITY
700 MOREN WAY H 11/30/2022 $795.00
ELKO, NV 89801
Alliance Forge
5648 Spandrell Cir D 11/30/2022 $25,343.63
Sparks, NV 89436
 
 
IN KIND EXPENSES Report Period   # 4
 
Joseph Lombardo Governor Clark County
Name (print) Office (if applicable) District (if applicable)

IN KIND EXPENSES IN EXCESS OF $100


(Transfer Total Value of All In-Kind Expenses to Line 10 of Expenses Summary)

HB 00404
NAME AND ADDRESS OF PERSON, GROUP OR DESCRIPTION DATE OF IN KIND VALUE OR COST
ORGANIZATION WHO RECEIVED THE IN KIND OF IN KIND OF IN KIND
GOOD OR SERVICE EXPENSE EXPENSE EXPENSE

Mechanical Contractors Association of Las Vegas


2640 South Jones Boulevard Suite 1 Catering Services 10/07/2022 $1,604.70
Las Vegas, NV 89146
Sheet Metal And Air Conditioning Contractors'
National Association of Southern Nevada
Catering Services 10/07/2022 $1,604.69
2640 South Jones Boulevard Suite 4
Las Vegas, NV 89146
Gary Pestello
10198 Via Verona Facility Fees 10/25/2022 $250.00
Reno, NV 89511
Donna Maland
10549 Santo Marco Court Facility Fees 10/25/2022 $250.00
Las Vegas, NV 89135
Flynn Giudici Government Affairs
708 North Center Street Catering Services 10/25/2022 $2,388.69
Reno, NV 89501
Ashok Mirchundani
10570 Hope Mills Dr Facility Fees 11/02/2022 $6,500.00
Las Vegas, NV 89135
Real NV
410 South Minnesota Street Text Messaging Services 11/14/2022 $5,000.00
Carson City, NV 89703
United Signs Inc
5234 South Procyon Street Sign Frames 11/15/2022 $7,500.00
Las Vegas, NV 89118
Alex Meruelo
2500 East 2nd Street Catering Services 12/06/2022 $4,790.00
Reno, NV 89502

EL201
Revised: 8-13-13
NRS 294A.120; 294A.125;
294A.160; 294A.200;
294A.362; 294A.373
 
HB 00405
EXECUTIVE DIRECTOR’S EXHIBITS
EXHIBIT 41

HB 00406
STATE OF NEVADA

BEFORE THE NEVADA COMMISSION ON ETHICS

In re Bartolo Ramos, Public Works Ethics Complaint


Director, Lander County, Case No. 19-088C
State of Nevada,

Subject. /

ORDER ON DISPOSITIVE MOTIONS


NAC 281A.265

On April 21, 2022, the Executive Director filed a dispositive motion regarding two of
the alleged allegations relating to NRS 281A.400(3) and NRS 281A.420(1), (“ED’s
Motion”). On the same day, Subject Ramos (“Ramos”) filed a dispositive motion seeking
dismissal of all allegations referred to the Commission for proceedings (“Subject’s
Motion”). 1 Each party filed an opposition to the other party’s motion on May 2, 2022, and
their replies in support of their individual motions were filed on May 5, 2022.

On June 15, 2022, the Commission held a public hearing to consider oral
arguments on the motions. Rebecca Bruch, Esq. of Lemons, Grundy & Eisenberg
appeared on behalf of Ramos, who was present at the hearing. Associate Counsel
Elizabeth J. Bassett, Esq. appeared on behalf of Executive Director, Ross Armstrong, who
was present at the hearing.

A. RELEVANT PROCEDURAL BACKGROUND

1. On September 21, 2019, the Commission received an Ethics Complaint


(“Complaint”) from a member of the public (“Requester”) alleging the following violations
of the Ethics Law by Ramos: NRS 281A.400(1), (2), (3), (4) and (7), NRS 281A.420(1) and
(3), and NRS 281A.430.

2. On November 7, 2019, the Commission accepted jurisdiction and issued a


Notice of Complaint and Investigation pursuant to NRS 281A.715 directing the Executive
Director to investigate the allegations.

3. On November 20, 2019, Ramos provided the Commission an executed


Waiver of Statutory Time Requirement: Investigation & Review Panel.

4. On August 18, 2020, Ramos provided a response to the Complaint pursuant


to NRS 281A.720(2) to the Executive Director.

5. On June 16, 2021, a Review Panel issued a Review Panel Determination


and Referral Order (“Panel Determination”) determining there is just and sufficient cause

1
A Dispositive Motion may commonly be referred to as a Motion for Summary Judgment. This reference
does not confirm that NRCP 56 specifically applies to the proceedings. The provisions of the NRCP are not
directly applicable to administrative proceedings; however, it is not a due process error for an administrative
agency to reference these provisions. Dutchess Bus. Servs. v. Nev. State Bd. Of Pharm., 124 Nev 701, 191
P.3d 1159 (2008).

Order on Dispositive Motions


Page 1 of 14

HB 00407
for the Commission to render an opinion in this matter with respect to the alleged violations
of NRS 281A.400(1), (2), (3) and NRS 281A.420(1) and (3). The applications pertaining to
NRS 281A.400(4) and (7), and NRS 281A.430, were dismissed by the Review Panel for
lack of just and sufficient cause. 2

6. On July 8, 2021, after consultation with counsel for the parties, the
Commission, through its Commission Counsel, issued a Notice of Hearing and Scheduling
Order providing for discovery and setting hearing dates and other procedural matters for
the case, which was amended on three times thereafter.

7. On June 22, 2021, Ramos provided the Commission with a signed Waiver
of Notice Required under NRS 241.033(1) to Consider Character, Misconduct, or
Competence of Subject in Ethics Complaint Proceedings, and a Waiver of Statutory Time
Requirements; Adjudicatory Hearing.

8. On April 25, 2022, after consultation with counsel for the parties, the
Commission, through its Commission Counsel, issued a Third-Amended Scheduling Order
(“Scheduling Order”), which provided proper notice for the hearing on the motions set for
June 15, 2022.

B. FINDINGS OF FACTS 3

1. Ramos is currently the County Manager and prior to that time he was the Public
Works Director for about 6 years, including 2018 and 2019. SUBJ MSJ 00034; ED
MSJ 00081.

2. During 2018 and 2019, Ramos was a public employee as defined by NRS
281A.150, when he was the Public Works Director. ED MSJ 00081.

3. Jodee Ramos (“Jodee Ramos”) is Ramos’ sister, and she and Nettie Quintana
(“Quintana”) for all relevant periods were domestic partners during 2018 and 2019.
SUBJ MSJ 00010.

4. Quintana is the owner of JNM Materials and has subcontracted and contracted work
for Lander County for materials testing and inspection services. SUBJ MSJ 00004,
00035, and 00037; ED MSJ 00082.

5. Jodee Ramos was listed as an officer of JNM Materials with the Nevada Secretary
of State from February 2018 to May 2, 2019. SUBJ MSJ 00026-27.

6. In February 2018, Quintana submitted paperwork to obtain approval to provide


testing services to Lander County. SUBJ MSJ 00063.

7. After Quintana turned in the paperwork to Lander County, Bert Ramos and Keith
Westengard contacted her for work on various projects, which contact was as far
back as 2018. SUBJ MSJ 00063; ED OPP MSJ 00034.

2 Pursuant to NRS 281A.220, the members of the Review Panel are precluded from participating in any
proceedings of the Commission related to a matter after issuance of the Panel Determination.
3 References to record in support of Findings of Fact are not exclusive, and other supportive documentation
in the record may support the findings. Further, the Commission considered and relied upon the entire record
presented to consider the motions and its Findings of Fact reference support for the findings, but additional
support for this opinion may be located in the records of proceedings.

Order on Dispositive Motions


Page 2 of 14

HB 00408
8. Since JNM Materials was a service provider for Lander County, it could be selected
for pending projects and the services were performed by invoice on the assigned
project, without a written contract specific to the assigned project. SUBJ MSJ
00064.

9. JNM Materials’ standard rate it charged for testing services was 3%, which was
billed weekly on assigned projects. SUBJ MSJ 00064.

JNM Material’s Invoices for Public Works Projects

10. JNM Materials submitted invoices for payment with the following dates and amounts
to Lander County for work it performed on various Public Works projects, as its
testing services provider:

1. Invoice #24 – BM Airport Densities, Project #004, $3,110 (11/9/18). ED MSJ


00045.

2. Invoice #26 – Airport Pond Project, Project #001, $1,000 (12/21/18). ED MSJ
00049.

3. Invoice #27 – Spec Project White Knife, Project #PWP LA 2019-020, $3,000
(1/19/19). ED MSJ 00052.

4. Invoice #28 – White Knife Project, Project #PWP LA 2019-020, $2,825


(2/1/19). ED MSJ 00055.

5. Invoice #29 – Kayci Ave. Project, Project #001, $4,490 (2/1/19). ED MSJ
00057.

6. Invoice #30 - White Knife Project, Project # PWP LA 2019-020, $1,460


(2/8/19). ED MSJ 00059.

7. Invoice #31 - White Knife Project, Project # PWP LA 2019-020, $8,480


(2/18/19).

8. Invoice #32 - White Knife Project, Project # PWP LA 2019-020, $7,430


(2/22/19).

9. Invoice #33 - White Knife Project, Project # PWP LA 2019-020, $2,170


(3/1/19).

10. Invoice #34 – White Knife Project, Project # PWP LA 2019-020, $2,660
(3/10/19).

11. Invoice #35 - White Knife Project, Project # PWP LA 2019-020, $4,145
(3/15/19).

12. Invoice #36 – Fire Pond Lining Project, Project # PWP LA 2018-118, $6,900
(3/23/19). ED MSJ 00034.

13. Invoice #37 - White Knife Project, Project #PWP LA 2019-020, $4,045
(3/23/19). ED MSJ 00032.

14. Invoice #39 - White Knife Project, Project #PWP LA 2019-020, $4,195
(3/29/19). ED MSJ 00030.
Order on Dispositive Motions
Page 3 of 14

HB 00409
15. Invoice #40 - White Knife Project, Project # PWP LA 2019-020, $3,095
(4/6/19). ED MSJ 00037.

16. Invoice #41 – Austin Road Rehab Project #PWP LA 2019-021, $7,475
(4/6/19). ED MSJ 00038.

17. Invoice #42 - White Knife Project, Project #PWP LA 2019-020, $2,700
(4/14/19). ED MSJ 00040.

18. Invoice #43 – Austin Road Rehab, Project #PWP LA 2019-021, $11,055
(4/14/19). ED MSJ 00042.

11. Ramos authorized vouchers for processing of payment before the BOCC of JNM
Materials for Invoices numbered 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 39,
40, 41, 42, 43, indicating: “I certify that the foregoing claim is correct and just; that
the articles specified have been received by the proper officials of the Couty, the
Courts and/or Special Districts, or the services stated have been performed; and
they were necessary for, have been or will be applied to the county, Court or Special
District purposes.” ED MSJ 00083-86 (note: individual vouchers are not in
chronological date order); see also ED MSJ 00029, 31, 33, 36, 39, 41, 48, 51, 54,
56, 58, 62, 65, 67, 70, and 72.

12. The above list of JNM Materials’ invoices and supporting paperwork (including
vouchers) were presented to the BOCC in nine (9) public meetings held on
November 29, 2018, February 28, 2019, April 11, 2019, April 25, 2019, May 9, 2019,
May 23, 2019, June 13, 2019, June 27, 2019, and July 11, 2019, at which Ramos
was present but made no disclosure in the public meetings about his relationship
with JNM Materials. The BOCC approved payment to JNM Materials on the
submitted invoices. ED MSJ REPLY 00032-01649 (Board Meeting Packets).

13. Ramos did not disclose to his supervisor, former County Manager Westengard, that
Ms. Quintana and Jodee Ramos were domestic partners/spouses or that Ms.
Quintana owned JNM Materials prior to Ramos’ execution on the vouchers.

14. Ramos’ relationship with JNM Materials was first brought to Westengard’s attention
in the spring of 2019 by County staff. Prior to that, Westengard did not know that
Quintana was the owner of JNM Materials. ED MSJ00091; 00121-122.

15. Once the relationship was brought to Westengard’s attention, he sought legal
advice from the District Attorney’s Office, District Attorney Ted Herrerra, which
resulted in action being taken to remove Ramos from the process or reviewing and
signing of any vouchers for JNM Materials’ invoices. ED MSJ 00122-123.

16. DA Herrerra confirmed he did not talk to Ramos about the conflicts but
recommended remedial action. ED OPP MSJ 00096.

Order on Dispositive Motions


Page 4 of 14

HB 00410
Day Engineering Contract

17. The Day Engineering contract for repaving State Routes 212, 214, and 215, was
noticed as Item 4, and approved on August 9, 2018, by the BOCC. ED MSJ 00144-
46.

18. The scope of work for the Day Engineering contract confirmed that Lander County
would provide all testing services. ED MSJ 00191-93, at p. 000192.

19. Prior to the BOCC’s approval of the Day Engineering contract, It was Ramos’ idea
to change how testing services were to be provided on Public Works projects.
Instead of having the contractor provide testing services, a change was authorized
by County Manager Westengard to have Lander County provide the testing
services, as a carve out from the contract deliverables. ED MSJ 00115-17.

20. JNM Materials was the only local materials testing company, and Lander County
had a buy local policy that established a “preference” for informal procurements
requiring:

Departments shall consider the locality of consultants or businesses


and their sub-consultants when selecting providers for service
contracts. If there is more than one service provider being considered
and the providers are competitively matched in terms of other criteria,
local service providers should be selected.

In addition, the policy confirms that the “preference established in this policy shall
in no way be construed to inhibit, limit or restrict the right and obligation of the
County or Purchasing Agent to compare quality and fitness for use of services
proposed for purchase and compare the qualifications, character, responsibility and
fitness of all persons, firms, or corporations submitting bids or proposals. Nor shall
the preference established in this policy be construed to prohibit the right of the
County from giving any other preference permitted by law.” ED MSJ REPLY 00030;
SUBJ MSJ 00071-73 (Lander County Policy).

21. At the public meeting of August 9, 2018, Ramos in his capacity as Public Works
Director introduced the Day Engineering contract to the BOCC. ED MSJ 00145.

22. Ramos did not make a disclosure about his private commitment to JNM Materials
when the BOCC considered the Day Engineering contract at the BOCC meeting of
August 9, 2018. ED MSJ 00144-46.

23. JNM Materials provided the compaction and asphalt testing services on behalf of
Lander county for the Day Engineering Contract for repaving State Routes 212,
214, and 215. ED MSJ 00083.

24. In hiring for the work for the Day Engineering contract, Ramos, in his deposition,
confirmed that he and Westengard would authorize JNM Materials to work on the
projects:

RAMOS:· The foot in the door for JNM Material Testing is they were local.
It’s that simple. They were the only local option. That was the shoe in the
door for JNM.·It wasn't anything more or anything less.·It was that they were
local. That’s what the shoe in the door was.

MS. BRUCH:· But how, how did that happen?


Order on Dispositive Motions
Page 5 of 14

HB 00411
MS. BASSETT: Who did they meet with? Someone had to authorize them to
go out. Someone had to say how much you are going to charge.

RAMOS: Yes. And that was myself, Keith Westengard, and Marty Ugalde of
Day Engineering, because Marty is the one that was over ·the contract for
Day Engineering. Aaron Martinez was the one who said I can only do it for
five percent. If they can give you a better deal, put them boots on the ground.
So who hired them, that would have been myself and Keith Westengard.

ED MSJ REPLY 00031.

25. In the May 9, 2019, BOCC public meeting, under Agenda Item No. 11, entitled
“Update and information regarding the Public Works department presented by Bert
Ramos, Lander County public Works director, and all other matters properly related
thereto,” Ramos publicly affirmed his connection to JNM Materials when he was
providing information associated with construction cost savings. The minutes from
the BOCC meeting indicate Ramos provided the following information about the
relationship between his sister and Ms. Quintana:

Ramos: ...And then on another one – so I have on our inspection


services, we used to get a flat 5 percent rate from our engineer. They
-- of whatever the job was.
And if you add a change order to it, then you got five – they took 5
percent of that.
And that’s materials and everything else included. Well, I took that
away and we went with a local. And I know that it’s caused some stir
because my sister is involved and it’s a small community. I have
nothing to hide from anybody.
But my sister and Netty are dating. Everybody knows. Or I’m not
sure what they are. Bug – Yeah, how do you say that in public?

Unidentified Participant: I think they’re partners

Chairman Waits: Nepotism. Yeah.

Ramos: So – so anyway – and I’ve always went with the local


business. It's been something that I've done since I got hired in Austin.
My brother-in-law ran the NAPA. We always did business with them.
We get fair pricing. And so I know that it's caused some concern
amongst especially one commissioner. So I wanted to point out some
cost savings on the project since they've been with us.
We've saved $88,076. And that's over five projects. But that's not
including if we -- if we went and we included the -- the change orders
and other things, you -- you're talking another $75,000. So we would
have saved $163,076 so far in five projects with them.
And this is money we can put somewhere else. So it's -- it's
responsible.
.....We can't bid it because it's professional services.

SUBJ MSJ 00102-104.

Order on Dispositive Motions


Page 6 of 14

HB 00412
C. DISCUSSION AND CONCLUSIONS OF LAW

Introduction

Pursuant to NRS 281A.280, the Commission has jurisdiction over public


employees, as that term is defined in NRS 281A.150, and public officers, as that term is
defined in NRS 281A.160, if their conduct implicates a violation of Nevada’s Ethics in
Government Law, set forth in NRS Chapter 281A (“Ethics Law”). Ramos does not contest
jurisdiction in these proceedings, or the fact that he was a public employee under NRS
281A.150, at all relevant times.

After the Commission accepted jurisdiction, it directed the Executive Director to


investigate the allegations set forth in the Complaint for purposes of making a “just and
sufficient cause” recommendation to the Review Panel, which is comprised of 3 members
of the Commission. NRS 281A.725-281A.730. The Review Panel issued its Panel
Determination referring certain allegations to the Commission for proceedings and
dismissing other allegations.

Once a complaint is referred to the Commission for proceedings, the Commission


may rule on a dispositive motion. See NAC 281A.442. Accordingly, the Commission has
jurisdiction over Ramos and is provided authority to consider the motions and issue this
order. In considering whether there is a violation of the Ethics Law, NRS 281A.480(9)
establishes the burden of proof to be a “preponderance of the evidence,” which means
that the evidence is sufficient for the Commission to determine that the existence of the
contested fact is more probable than the nonexistence of the contested fact. See NRS
233B.0375.

In considering the motions, the Commission considered the record before it,
including without limitation, the Complaint, Ramos’s Response to the Complaint, filed
pleadings and supportive evidence in the form of public records, depositions, discovery
requests and responses. Further, each party presented oral arguments to the Commission
during the public meeting in support of their respective motion.

The Motions

In the pleadings, each party presents various contentions considered by the


Commission. As a general overview, the Executive Director contends Ramos negotiated
or secured the work to be performed by JNM Materials and then reviewed and approved
vouchers to process payment on JNM Materials’ invoices and that Ramos carved out
inspection services from Public Work’s contracts prior to the BOCC’s approval of the Day
Engineering contract, resulting in JNM Materials being selected to provide these
professional services under Lander County’s “buy local" preference, which conduct
violated NRS 281A.400(3) and NRS 281A.420(1).

Conversely, Ramos asserts the preponderance of evidence standard is not met


because there was no written contract between Lander County and JNM Materials for
application of NRS 281A.400(3). Instead of a written contract, Lander County would hire
professional services and pay for these services based upon invoicing. With respect to the
alleged violation of NRS 281A.420(1), Ramos contends he did not hide his sister’s
relationship, but followed Lander County’s preference to hire a local service supplier.
Further, because Lander County is a small jurisdiction, Ramos believed everyone knew
that his sister was related to Ms. Quintana, the owner of JNM Materials. Ramos seeks

Order on Dispositive Motions


Page 7 of 14

HB 00413
dismissal of all allegations set forth in the Complaint that were referred to the Commission
for proceedings, which are: NRS 281A.400(1), (2), (3) and NRS 281A.420(1) and (3). 4

As a precept to the consideration of the motions, Ramos has not contested the fact
that he is related to Jodee Ramos and Quintana, or that Quintana owns JNM Materials.
Therefore, under NRS 281A.065(3), Ramos holds a “commitment in a private capacity” to
Jodee Ramos and Quintana because they are related to him by blood or domestic
partnership, within the third degree of consanguinity or affinity.

Each party’s pleadings in support of their respective motion intertwined the


arguments and applied them to the contentions raised by the other party. Accordingly, this
order addresses each of the alleged violations that were referred to the Commission in
statutory order.

Alleged Violations - NRS 281A.400(1), (2), (3) and NRS 281A.420(1) and (3)

NRS 281A.400(1) – Using public position to seek economic opportunity


for public employee or for any person to whom the public employee
has a commitment in a private capacity, which would tend to
improperly influence a reasonable person to depart from public duties.

Ramos seeks dismissal of this alleged violation, asserting that he did not depart
from the faithful discharge of his public duties because JNM Materials’ services saved
Lander County money on the assigned Public Works Projects and he was complying with
Lander County’s policy to by local, and JNM Materials was the only local testing company.
In opposition, the Executive Director asserts the statutory prohibition serves to prevent
public employees from violating the public trust by taking official action for a personal
benefit.

All public employees, who are subject to the Ethics Law, have a responsibility to
comply with its provisions in fulfilling their public duties. NRS 281A.400(1), and all
provisions of the Ethics Law, are applied consistently with the legislatively established
policy set forth in NRS 281A.020(b), which provides “[a] public officer or employee must
commit himself or herself to avoid conflicts between the private interests of the public
officer or employee and those of the general public whom the public officer or employee
serves.”

The Commission does not grant judgment on NRS 281A.400(1) because additional
testimony is needed to consider the allegation and defense. Without limitation, Lander
County’s policy to “buy local,” by its stated terms, is an established preference rather than
a requirement, and it would assist the Commission to hear testimony relating to
circumstances in application of the policy to JNM Materials’ services, including the testing
services provided on the Public Works’ projects, vouchers, and the Day Engineering
Contract. It would assist the Commission to understand the details related to the claimed
savings by using JNM Materials, and what information was presented to Ramos’s
supervisor Westengard in this regard. It would assist the Commission to consider
testimony on the application of the “buy local” policy by Lander County when the
circumstances confirm the employee has a potential conflict under the Ethics Law, and

4 Inadvertently Ramos also sought dismissal of NRS 281A.430; however, at the hearing, it was confirmed
with the parties that the Review Panel Determination did not refer this allegation to the Commission for
further proceedings. The Review Panel dismissed the allegations relating to NRS 281A.400(4) and (7), and
NRS 281A.430, for lack of sufficient evidence. See Review Panel Determination issued on June 21, 2021.
Accordingly, any related argument was not germane to the proceedings.

Order on Dispositive Motions


Page 8 of 14

HB 00414
any other matters relating to the alleged violation of NRS 281A.400(1), including DA
Herrerra’s interpretation of this policy under such circumstances.

NRS 281A.400(2) - Using public position to secure or grant unwarranted


privileges for the public employee or for a person to whom he holds a
private commitment

Ramos seeks dismissal of this alleged violation contending his conduct was not
“unwarranted” based upon application of Lander County’s buy local policy, and because
of the significant savings resulting from using JNM Materials for testing services, and he
does not have the final say in approval of payment on invoices, which approval is
processed before and within the authority of the BOCC. The Executive Director contends
issues of fact remain as to whether there were savings and whether Ramos used
knowledge he acquired through his public position to provide an unwarranted benefit to
JNM Materials based upon the Commission’s holding in In re Sieren, Comm’n Op. 95-05
(1996).

For the reasons indicated above with respect to the alleged violation of NRS
281A.400(1), it would assist the Commission to hear testimony on the alleged violation of
NRS 281A.400(2). Accordingly, it does not grant Ramos’ requested dismissal.

NRS 281A.400(3) – Using public position to negotiate or execute a


contract with a person to whom you have a commitment in a private
capacity

The Executive Director seeks judgment on Ramos’ alleged violation of NRS


281A.400(3) based upon Ramos’s confirmed private commitment to Jodee Ramos,
Quintana, and JNM Materials, asserting Ramos either negotiated or executed a contract
to obtain testing services from JNM Materials. In contrast, Ramos asserts that no written
contract was signed by him, and he did not act as an agent of Lander County in the
negotiation of a contract.

The lack of a formal bid solicitation, traditional back and forth negotiation, or written
contract between Lander County and JNM Materials on the listed Public Works projects is
not determinative of the application of NRS 281A.400(3). State and local government
purchasing laws do not require every contract entered into by a County to be competitively
bid. Contracts not adapted to award by competitive solicitation include contracts for
professional services, such as those provided by JNM Materials to Lander County. See
NRS 332.115(1)(b). Contracts come in a variety of forms, from written contracts, purchase
orders, hand-shake deals, oral agreements, acceptance of goods, or services at an agreed
upon rate. 5

NRS 281A.400(3) does not state it requires a written contract to be applicable.


Instead, it applies to any form of contract. Basic contract principles require, for an
enforceable contract, an offer and acceptance, meeting of the minds, and consideration.
May v. Anderson, 121 Nev. 668, 119 P.3d 1254 (2005). In this matter, all material terms
of the contract for JNM Materials were known once it qualified to be a local provider, JNM
Materials’ rate of 3% was known to Ramos, its services were hired by Ramos and
Westengard, and the firm was assigned to individual Public Works Projects. The contract

5 The Commission makes a distinguishment between a contract and an invoice or voucher. An invoice was
sent after the testing services were provided in support of the fact that a contract was formed with JNM
Materials, and requests payment for services rendered. A voucher is a written authorization to disburse
payment. See definitions of invoice and voucher, Black’s Law Dictionary, 11 ed., at pages 956 and 1809,
respectively.

Order on Dispositive Motions


Page 9 of 14

HB 00415
formation was accomplished at a staff level, which included Ramos, albeit in a fairly
informal fashion. 6 Consistent with the contract formation is Ramos’s execution of vouchers
showing JNM Materials’ work was completed for the individual projects and the firm was
entitled to payment for services rendered. Thereafter, the BOCC paid invoices based upon
the work performed by JNM Materials.

Accordingly, a contract existed with JNM Materials for the work to be performed on
each of the listed Public Works’ projects. If there was no contract, JNM Materials would
not have been providing testing services or be entitled to payment for rendered services
on an individual project. It does not matter that the contract was not obtained by the
traditional solicitation, bidding process, and written contract approval by the BOCC.
Contracts may be established in a variety of ways, including by the conduct of the parties.
Implied in fact contracts are manifested by conduct. See Certified Fire Prot. Inc. v.
Precision Constr. Inc., 128 Nev. 371, 283 P.3d 250 (2012).

In considering whether Ramos negotiated a contract with JNM Materials, the


Commission applies the plain meaning to the term, “negotiate,” which is “to communicate
with another party for the purpose of reaching an understanding,” or “to bring about by
discussion or bargaining.” See Black’s Law Dictionary, 10th Ed., pgs. 1199-1120. Merriam
Webster’s Collegiate Dictionary, 11th Ed., at p. 830, similarly defines “negotiate” as: “to
carry on business; to confer with one another so as to arrive at the settlement of some
matter; to deal with (some matter or affair that requires ability for its successful handling)...
manage; to arrange for or bring about through conference, discussion and compromise.”

As the Public Works Director, Ramos was authorized to develop contracts for public
works. Ramos’s conduct in hiring and arranging for JNM Materials to work on Public Works
projects confirms he obtained the services to be provided for the individual projects.
Accordingly, the Commission finds that Ramos’s conduct is sufficient to establish either a
negotiation or contract formation for application of NRS 281A.400(3). Therefore, Ramos’s
conduct violated the statutory requirements.

NRS 281A.420(1) and (3) – Disclosure and Abstention Requirements

The Executive Director seeks judgment on NRS 281A.420(1) for Ramos’s alleged
violation of the statute by his failure to disclose his private commitments to Jodee Ramos,
Quintana, and JNM Materials, before acting on signing vouchers for payment processing
on the subject invoices and failing to advise the BOCC or the public about the potential
conflict in the 9 public meetings at which the invoices were considered for payment by the
BOCC. In addition, the alleged violation pertains to Ramos’s conduct in allegedly failing to
make a proper disclosure when he carved-out testing services from Public Works contracts
prior to the BOCC’s consideration and approval of the Day Engineering contract at the
August 9, 2018 BOCC public meeting, during which Ramos presented the item and made
no disclosures about the potential conflict.

In opposition, Ramos contends that he did not abuse his public position because
he was saving Lander County money by utilizing the services of JNM Materials, his
conduct was mitigated by July of 2019 when the invoice processing had been redirected
to County Manager Westengard, he did not have a final say in any contracts or work
performed on projects, the invoices were processed just as any other invoice would have

6
Although “it is understandable that public employees in Nevada’s small, rural counties may conduct
business with less formality than those in Nevada’s larger, more metropolitan areas. However, even in small,
rural counties, the formality of a public employee’s conduct should never be so relaxed that it offends the
public trust and ethical standards to which public employees are accountable. See In re Shangle, Comm’n
Op. No. 01-40 (2002).

Order on Dispositive Motions


Page 10 of 14

HB 00416
been by Purchasing and approved by the BOCC. Ramos further contends that at best he
had a vague and nebulous obligation to disclose his connection to JNM Materials,
everyone knew he was related to Jodee Ramos and Quintana, and the County Manager,
after obtaining legal advice, redirected invoicing processing. He also asserts his conduct
does not meet the willful standard under the Ethics Law because he did not know about
the requirements of the Ethics Law.

The disclosure requirements of NRS 281A.420(1) apply to each occasion where a


public employee’s pecuniary interests or private commitments relate to their public duties.
In relevant part, NRS 281A.420 states a public employee “shall not approve, disapprove,
vote, abstain from voting or otherwise act upon a matter:

(a) Regarding which the public officer or employee has accepted a gift or
loan;

(b) In which the public officer or employee has a significant pecuniary


interest;

(c) Which would reasonably be affected by the public officer’s or employee’s


commitment in a private capacity to the interests of another person...

 without disclosing information concerning the gift or loan, the significant pecuniary
interest, the commitment in a private capacity to the interests of the other person or the
nature of the representation or counseling of the private person that is sufficient to inform
the public of the potential effect of the action or abstention upon the person who provided
the gift or loan, upon the public officer’s or employee’s significant pecuniary interest, upon
the person to whom the public officer or employee has a commitment in a private capacity
or upon the private person who was represented or counseled by the public officer or
employee. Such a disclosure must be made at the time the matter is considered.

Public employees who are not members of a body that makes decisions shall make
the required disclosure to the supervisory head of the organization under NRS
281A.420(1). In addition, should the public officer/employee participate in a public meeting
that implicates a disclosable conflict, tit must also be disclosed to the public given the
requirements of NRS 281A.420(1) to properly inform the public. See In re Murnane,
Comm'n Op. No. 15-45A (2016), at p. 13. The interests of the person to whom there is a
private commitment, such as a relative, are statutorily attributed to the public
officer/employee based on the presumption that a person lacks independent judgment
toward the interests of those persons to whom there are private commitments. See In re
Public Officer, Comm'n Op. No. 13-71A (2014).

In considering whether Ramos violated NRS 281A.420(1), the Commission


confirms that an asserted lack of knowledge of the requirements of the Ethics Law does
not present an excuse or defense to the alleged violation. The provisions of NRS
281A.420(1) have been statutory in various forms since their original enactment in 1977.
The Ethics Law does not require specific knowledge about the requirements of its statutes
for the law to apply to the conduct of public officers and public employees. The law simply
requires either an omission or an intentional, as opposed to unintentional, act associated
with a duty imposed by the Ethics Law on the public officer or employee. See NRS
281A.170; see also, In re Public Employee, Comm’n OP. No. 19-051A (2019).

The facts confirm that Ramos failed to make proper disclosures to his supervisor
about his commitment in a private capacity to JNM Materials on each occasion that his
public duties related thereto, including hiring JNM Materials and signing the numerous
vouchers to process the invoices before the BOCC in public meetings. In addition, Ramos
Order on Dispositive Motions
Page 11 of 14

HB 00417
did not make any disclosures to his supervisor prior to the BOCC’s consideration of the
Day Engineering contract when Ramos’s conduct served to carve out materials testing
from the contract, which resulted in JNM Materials being selected to provide these services
through Public Works. At no time in the public meetings Ramos attended, at which the
above matters were considered by the BOCC, did he properly advise the public about his
conflict. NRS 281A.420(1) requires the disclosure, no matter to whom it is made, be
sufficient to inform the public of the potential effect of the action or abstention on the public
officer’s or employee’s interests and the interest of any person to whom NRS 281A.065
establishes a private commitment. See Murnane, Comm'n Op. No. 15-45A (2016), at
p. 13.

In making the determination that Ramos failed to properly disclose a conflict, the
Commission does not find that Westengard’s knowledge about the conflict obtained from
finance staff members or Ramos’s eventual recognition of the relationship during the May
9, 2019, BOCC meeting excused or constituted a proper disclosure by Ramos to his
supervisor or the public. A proper disclosure by the public employee must occur every time
a matter is considered which relates to a disclosable conflict. The Ethics Law does not
recognize a continuing disclosure, a disclosure by reference, or a disclosure made by
others. NRS 281A.420 requires the affected public employee to make the disclosure.
Knowledge of others about the conflict also does not excuse the failure to disclose. See In
re Stark, Comm’n Op. No. 10-48C (2012).

The purpose of disclosure is to provide sufficient information regarding the conflict


of interest to inform the supervisory head of the organization and the public of the nature
and extent of the conflict and the potential effect of the action or abstention on the public
officer's/employee's private interests and commitments. Silence based upon a prior
disclosure fails to inform the public or supervisory head of the organization about the
nature and extent of the conflict. See In re Public Officer, Comm’n Op. No. 16-14A (2016);
In re Buck, Comm'n Op. No. 11-63C (2011) (holding that incorporation by reference of a
public officer's prior disclosure, even though based upon the advice of counsel, did not
satisfy the disclosure requirements of NRS 281A.420(1)).

Notably, Ramos was in a management position as the Director of Public Works,


and his recommendations on such matters carried weight. The buy local policy was a
preference, not a requirement. Accordingly, the lack of a timely and proper disclosure of
these matters removed the ability of the County Manager and the BOCC to consider and
issue directions on how to avoid the conflict, including ascertaining whether they wanted
to solicit the professional services through a request for qualifications, or other process
permitted to local governments, or to hire JNM Materials, with the caveat that Ramos be
separated from such matters, as instructed by DA Herrerra, in mitigation. Either
Westengard or the BOCC, not Ramos who had a per se conflict that required a proper
disclosure, had authority to determine whether JNM Materials’ services were a good deal
and if the company should be selected for the Public Works projects needing testing
services. Indeed, once the Lander County District Attorney was advised about Ramos’s
conflict by Westengard, he directed that Ramos be fully separated from matters associated
with JNM Materials.

Based upon the record presented, the Commission determines that Ramos violated
NRS 281A.420(1) by failing on 12 occasions to properly disclose a conflict related to JNM
Materials. With regard to the allegations relating to Ramos’ alleged violation of NRS
281A.420(3), the Commission does not find judgment is appropriate for Ramos based
upon questions of fact associated with whether Ramos’s position as the Director of Public
Works was established by a Nevada statute or an ordinance of Lander County and if the
position of Public Works Director involves the exercise of power trust or duty so as to
classify Ramos as a “public officer” under the definition established in NRS 281A.160.
Order on Dispositive Motions
Page 12 of 14

HB 00418
D. CONCLUSION

Based upon the review of the record, filed pleadings, and in consideration of the
presentments of the parties, the Commission finds good cause to enter the following order:

IT IS HEREBY ORDERED:

1. The Executive Director’s Motion is GRANTED in part, and the Commission


finds Ramos violated NRS 281A.400(3) and NRS 281A.420(1).

2. With regard to the alleged violations on which partial judgment was granted
in favor of the Executive Director, which are NRS 281A.400(3) and NRS 281A.420(1), the
Commission will consider the mitigating factors set forth in NRS 281A.775 to determine
whether the violations should be classified as either non-willful or willful and if any
penalties or other corrective action should be imposed under the Ethics Law.

3. Subject Motion is DENIED, and the Commission reserves its determinations


on whether Ramos has violated the other alleged violations referred to the Commission
by the Review Panel, which are NRS 281A.400(1) and (2), and NRS 281A.420(3).

4. This order is not a final determination of any of the alleged violations on


which partial judgment was granted nor does it dispose of the other allegations referred
to the Commission.

5. Commission Counsel is directed to schedule a briefing schedule for the


parties and future hearings to consider any matters left unresolved by this order.

DATED this 19th day of July 2022.

NEVADA COMMISSION ON ETHICS

/s/ Brian Duffrin


Brian Duffrin
Commission Vice-Chair/
Presiding Officer

Order on Dispositive Motions


Page 13 of 14

HB 00419
CERTIFICATE OF SERVICE

I certify that I am an employee of the Nevada Commission on Ethics and that on


this day in Carson City, Nevada, I transmitted a true and correct copy of the foregoing
ORDER ON DISPOSITIVE MOTIONS via electronic mail to the Parties as follows:

Executive Director:

Ross E. Armstrong, Esq. Email: rarmstrong@ethics.nv.gov


Executive Director
Elizabeth J. Bassett, Esq. Email: ebassett@ethics.nv.gov
Associate Counsel
704 W. Nye Lane, Suite 204 cc: k.pedroza@ethics.nv.gov
Carson City, NV 89703

Subject:

Bartolo Ramos
c/o Rebecca Bruch, Esq. Email: rb@lge.net
Lemons, Grundy & Eisenberg Email: jenn@lge.net
6005 Plumas Street, Ste. 3
Reno, NV 89519

DATED: July 19, 2022


Employee of the Nevada Commission on Ethics

Order on Dispositive Motions


Page 14 of 14

HB 00420
BEFORE THE NEVADA COMMISSION ON ETHICS

In re Joseph M. Lombardo, Ethics Complaint


Sheriff of Clark County, Case Nos. 21-062C, 21-082C
State of Nevada,

Subject. /

NOTICE OF HEARING
NRS 281A.745

PLEASE TAKE NOTICE, the Nevada Commission on Ethics (“Commission”) will


hold a public meeting to consider Dispositive Motions or Stipulations regarding the
allegations submitted in Consolidated Ethics Complaints Case Nos. 21-062C, 21-082C
at the following time and location:

When: Tuesday, June 13, 2023 at 9:30 a.m.,


or as soon thereafter as the Commission is able to hear the matter

Where: State Bar of Nevada


9456 Double R Blvd, Suite B
Reno, NV 89521

And Via Zoom:


https://us06web.zoom.us/j/82536449687?pwd=UkNSdm1xRllSd3NFQlpQeC9LUmtMUT09
Zoom Meeting Telephone Number: 720-707-2699
Meeting ID: 825 3644 9687
Passcode: 262131

In all presentations before the Commission, the Parties must reference appropriate
authority set forth in NRS Chapter 281A, NAC Chapter 281A or Commission opinion
precedent, which may be located on the Commission’s website at www.ethics.nv.gov or
available through other legal research sources. The Parties must be prepared to provide
oral presentations to the Commission on any motions and stipulations.

DATED: May 24, 2023 /s/ Wayne Klomp


Wayne Klomp, Esq.
Great Basin Law
On Behalf of the Nevada Commission
on Ethics1

1 The Commission has retained outside counsel during the vacancy of the Commission Counsel position.
Notice of Hearing and Scheduling Order
Page 1 of 2

HB 00421
HB 00422
HB 00423
2/24/22

HB 00424
Agenda Item 5
STATE OF NEVADA

BEFORE THE NEVADA COMMISSION ON ETHICS

In re Raymond Spencer, Former Ethics Complaint


Lieutenant, Las Vegas Metropolitan Case No. 22-0102C
Police Department, State of Nevada,

Subject. /

PROPOSED
STIPULATED AGREEMENT

1. PURPOSE: This Stipulated Agreement resolves Ethics Complaint Case No. 22-
0102C before the Nevada Commission on Ethics (“Commission”) concerning Raymond
Spencer (“Spencer”), former Lieutenant, Las Vegas Metropolitan Police Department
(“LVMPD”).
2. JURISDICTION: At all material times, Spencer served as a Lieutenant in the Las
Vegas Metropolitan Police Department and was a public employee as defined in NRS
281A.150. The Ethics in Government Law (“Ethics Law”) set forth in NRS Chapter 281A
gives the Commission jurisdiction over elected and appointed public officers and public
employees whose conduct is alleged to have violated the provisions of NRS Chapter
281A. See NRS 281A.280. Accordingly, the Commission has jurisdiction over Spencer in
this matter.
3. PROCEDURAL HISTORY BEFORE COMMISSION:
a. On or about September 7, 2022, the Commission initiated Ethics Complaint
No. 22-0102C (“Ethics Complaint”), alleging that Spencer violated NRS 281A.400(2) and
(7).
b. On September 7, 2022, the Commission issued its Order on Jurisdiction
and Investigation accepting jurisdiction and directing the Executive Director to investigate
the allegations.
c. On September 7, 2022, staff of the Commission issued a Notice of
Complaint and Investigation under NRS 281A.720, stating that the Commission accepted

Stipulated Agreement
Case No. 22-102C
Page 1 of 6
jurisdiction to investigate the allegations regarding alleged violations of NRS 281A.400(2)
and (7).
d. On or about October 13, 2022, Spencer provided a written response to the
allegations.
e. In lieu of an adjudicatory hearing before the Commission, Spencer and the
Commission now enter into this Stipulated Agreement (“Agreement”).
4. STIPULATED FACTS:
a. Spencer was initially hired by the LVMPD in 2002 and was promoted to
Lieutenant of Homicide in 2018. Spencer retired from the LVMPD in May 2022.
b. Spencer declared his candidacy for a Las Vegas City Council seat in
December of 2021 and filed to become a candidate for Las Vegas City Council, Ward 6
for the 2022 Election. Spencer received the second highest number of votes in the June
2022 Primary Election but lost in the November general election.
c. At the time Spencer announced his candidacy, he was already publicly
known as a Lieutenant in LVMPD’s homicide division and, as such, was regularly
depicted in television and print news wearing his uniform and badge. Thus, in stories
about Spencer’s campaign for Las Vegas City Council, the media regularly featured pre-
existing photographs of Spencer wearing his LVMPD uniform and badge.
d. After he declared his candidacy, but prior to his retirement in May 2022,
Spencer created certain photographs and videos to support his campaign for Las Vegas
City Council. Spencer did not wear his LVMPD uniform or badge in any of the
photographs or videos he created for use in his campaign.
e. In connection with his candidacy for Las Vegas City Council, Spencer
created a Facebook page and Twitter account to share information about his background
with the electorate. Given his 20-year career with LVMPD, Spencer’s professional
background primarily consists of his career and public service in law enforcement.
f. To share information with the public about his background, Spencer posted
several pre-existing photographs of himself on his Twitter and Facebook pages wherein
he was wearing his LVMPD uniform or badge.

Stipulated Agreement
Case No. 22-102C
Page 2 of 6
g. The posting of the foregoing images (i) did not interfere with Spencer’s
duties as a LVMPD Lieutenant, (ii) did not violate any LVMPD policy, and (iii) did not pose
any cost to LVMPD or the public.
h. Spencer made efforts to avoid the potential misuse of this position in law
enforcement by affirmatively seeking information and guidance from the Nevada
Secretary of State.
i. After the Complaint in this matter was filed, Spencer cooperated with the
investigation by voluntarily sitting for an interview and responding to questions by email.
j. Spencer posted one video and several images on his campaign Facebook
and Twitter accounts in support of his campaign featuring him in his LVMPD uniform,
badge, and accoutrements.
5. TERMS / CONCLUSIONS OF LAW: Based on the foregoing, Spencer and the
Commission agree as follows:
a. Each of the stipulated facts enumerated in Section 4 of this Agreement is
agreed to by the parties.
b. Spencer’s actions constitute a single course of conduct resulting in one
violation of the Ethics Law, implicating the provisions of NRS 281A.400(7).
c. Allegations that Spencer violated NRS 281A.400(2) are hereby dismissed
by stipulation of the parties.
d. Based upon the consideration and application of the statutory mitigating
criteria set forth in NRS 281A.775, the Commission concludes that Spencer’s violation in
this case should be deemed a non-willful violation pursuant to NRS 281A.170 and the
imposition of a civil penalty is not appropriate for the following reasons:
1) Seriousness of Violation: The Commission has previously issued
opinions that underline the importance of avoiding the use of
government property for campaigns.

2) Previous History: Spencer has not previously been the subject of any
violation of the Ethics Law or previous ethics complaints.

3) Cost of Investigation and Proceedings: Spencer was diligent to


cooperate with and participate in the Commission’s investigation and
resolution of this matter. Because Spencer was willing to resolve the
matter prior to an adjudicatory hearing, significant Commission
resources were preserved.

Stipulated Agreement
Case No. 22-102C
Page 3 of 6
4) Prompt correction of the violation: Spencer responded immediately to
the Executive Director and presented voluntarily for an interview.

5) Financial Gain: Spencer did not recognize financial gain because was
not elected to City Council seat for which he ran.

6) Other Mitigating Factors: Spencer retired from the LVMPD in May 2022,
before the primary election, and since then has not become a public
employee or officer.

e. For his violation of NRS 281A.400(7), the parties agree that Spencer will
pay the sum of $500 pursuant to NRS 281A.785(1)(c) as a reasonable action to deter
similar violations or conduct. Spencer will make one lump sum payment within 60 days
following the approval of this Agreement.
f. This Agreement depends on and applies only to the specific facts,
circumstances and law related to the Ethics Complaint now before the Commission. Any
facts or circumstances that may come to light after its entry that are in addition to or differ
from those contained herein may create a different resolution of this matter.
g. This Agreement is intended to apply to and resolve only this specific
proceeding before the Commission and is not intended to be applicable to or create any
admission of liability by Spencer for any other proceeding against or involving Spencer.
If the Commission rejects this Agreement, none of the provisions herein shall be
considered by the Commission or be admissible as evidence in a hearing on the merits
in this matter.
6. WAIVER
a. Spencer knowingly and voluntarily waives his right to a hearing before the
full Commission on the allegations in Ethics Complaint Case No. 22-102C and all rights
he may be accorded with in regard to this matter pursuant to NRS Chapter 281A, the
regulations of the Commission (NAC Chapter 281A), the Nevada Administrative
Procedures Act (NRS Chapter 233B) and any other applicable provisions of law.
b. Spencer knowingly and voluntarily waives his right to any judicial review of
this matter as provided in NRS Chapter 281A, NRS Chapter 233B or any other applicable
provisions of law.

Stipulated Agreement
Case No. 22-102C
Page 4 of 6
7. ACCEPTANCE: We, the undersigned parties, have read this Stipulated
Agreement, understand each and every provision therein, and agree to be bound thereby
once approved by the Commission. In addition, the parties orally agreed to be bound by
the terms of this agreement during the regular meeting of the Commission on June 13,
2023.1

DATED this day of , 2023.


Raymond Spencer

FOR SUBJECT RAYMOND SPENCER

DATED this day of , 2023.


Samuel R. Mirkovich, Esq.
Campbell & Williams

FOR ROSS E. ARMSTRONG, ESQ.


Executive Director
Nevada Commission on Ethics

DATED this day of , 2023.


Elizabeth J. Bassett, Esq.
Associate Counsel
Nevada Commission on Ethics

1Subject waived any right to receive written notice pursuant to NRS 241.033 of the time and place of the
Commission’s meeting to consider his character, alleged misconduct, professional competence, or physical
or mental health.

Stipulated Agreement
Case No. 22-102C
Page 5 of 6
Approved as to form by:
FOR NEVADA COMMISSION ON ETHICS

DATED this day of , 2023.


Wayne Klomp, Esq.
Great Basin Law

The above Stipulated Agreement is accepted by the Nevada Commission on Ethics:

DATED this day of , 2023.

By: By:
Kim Wallin, CPA, CMA, CFM James Oscarson
Chair Commissioner

By: By:
Barbara Gruenewald, Esq. Thoran Towler, Esq.
Commissioner Commissioner

Stipulated Agreement
Case No. 22-102C
Page 6 of 6
STATE OF NEVADA

BEFORE THE NEVADA COMMISSION ON ETHICS

In re Raymond Spencer, Former Lieutenant, Ethics Complaint


Las Vegas Metropolitan Police Department, Case No. 22-102C
State of Nevada,

Subject. /

REVIEW PANEL DETERMINATION AND REFERRAL ORDER


NRS 281A.730; NAC 281A.440

The Nevada Commission on Ethics (“Commission”) instructed the Executive


Director to investigate alleged violations of NRS 281A.400(2) and (7) in the captioned
matter regarding the conduct of Raymond Spencer (“Subject”).

Spencer is a public officer as defined in NRS 281A.160 and 281A.180, and the
Commission has jurisdiction over this matter pursuant to NRS 281A.280 because the
allegations contained in the Complaint relate to Spencer’s conduct as a public officer and
have associated implications under the Ethics Law.

On January 18, 2023, a Review Panel consisting of Commissioner Teresa Lowry,


Esq. (Presiding Officer), and Vice-Chair Brian Duffrin and Commissioner Amanda Yen,
Esq., considered the following: (1) Ethics Complaint (2) Order on Jurisdiction and
Investigation; (3) Spencer’s Response to the Complaint; and (4) Executive Director’s
Recommendation to the Review Panel with Summary of Investigatory Findings and
Relevant Evidentiary Exhibits. 1

The Review Panel unanimously finds and concludes that the facts establish
credible evidence to support a determination that just and sufficient cause exists for the
Commission to render an opinion in the matter regarding the alleged violations of NRS
281A.400(2) and (7).

///

///

///

1Allmaterials provided to the Review Panel, except the Ethics Complaint and the Order on Jurisdiction and
Investigation, represent portions of the investigatory file and remain confidential pursuant to NRS 281A.750.

Review Panel Determination and Referral Order


Page 1 of 3
IT IS HEREBY ORDERED:

Based upon the just and sufficient cause determination, the Review Panel refers
this Ethics Complaint to the Commission for further proceedings, which may include
rendering an opinion on whether Spencer violated NRS 281A.400(2) and (7).

Dated this 18th day of January, 2023.

REVIEW PANEL OF THE NEVADA COMMISSION ON ETHICS

By: /s/ Teresa Lowry By: /s/ Amanda Yen


Teresa Lowry Amanda Yen, Esq.
Commissioner/Presiding Officer Commissioner

By: /s/ Brian Duffrin


Brian Duffrin
Commissioner

Review Panel Determination and Referral Order


Page 2 of 3
CERTIFICATE OF MAILING

I certify that I am an employee of the Nevada Commission on Ethics and that on


this day in Carson City, Nevada, I transmitted a true and correct copy of the foregoing
REVIEW PANEL DETERMINATION AND REFERRAL ORDER via U.S. Certified Mail
and electronic mail addressed as follows:

Ross E. Armstrong, Esq. Email: rarmstrong@ethics.nv.gov


Executive Director
Elizabeth J. Bassett, Esq. Email: ebassett@ethics.nv.gov
Nevada Commission on Ethics
704 W. Nye Lane, Suite 204
Carson City, NV 89703

Raymond Spencer
c/o Samuel R. Mirkovich, Esq. Email: srm@cwlawlv.com
Campbell & Williams
710 South Seventh St. Certified Mail No.: 9171 9690 0935 0037 6406 41
Las Vegas, NV 89101

Dated: 1/19/23
Employee, Nevada Commission on Ethics

Review Panel Determination and Referral Order


Page 3 of 3
1/23/23
BEFORE THE NEVADA COMMISSION ON ETHICS

In re Raymond Spencer, Former Ethics Complaint


Lieutenant, Las Vegas Metropolitan Case No. 22-102C
Police Department,
State of Nevada,

Subject. /

NOTICE OF HEARING
NRS 281A.745
NOTICE OF HEARING TO CONSIDER STIPULATED AGREEMENT
NRS 281A.745

PLEASE TAKE NOTICE, the Nevada Commission on Ethics (“Commission”) will


hold a public meeting to consider a Proposed Stipulated Agreement regarding the
allegations submitted in Ethics Complaint No. 22-102C at the following time and location:

When: Wednesday, June 13, 2023 at 9:30 a.m.

Where: State Bar of Nevada


9456 Double R Blvd, Suite B
Reno, NV 89521

And via Zoom at:

https://us06web.zoom.us/j/82536449687?pwd=UkNSdm1xRllSd3NFQlpQeC9LUmtMUT09
Zoom Meeting Telephone Number: 720-707-2699
Meeting ID: 825 3644 9687
Passcode: 262131

If the Proposed Stipulated Agreement is approved, it will serve as the final written
opinion in this matter pursuant to NRS 281A.135.

DATED: May 24, 2023 /s/ Wayne Klomp


Wayne Klomp, Esq.
Great Basin Law
On Behalf of the Nevada Commission
on Ethics1

1 The Commission has retained outside counsel during the vacancy of the Commission Counsel position.
Notice of Hearing and Scheduling Order
Page 1 of 2
Agenda Item 6
Executive Director Report – June 2023

Education and Outreach


• Tovuti ready for soft launch
• Summer training scheduled/completed so far
o Genoa Town Board - June
o State Board of Medical Examiners - June
o GOED – July
o Tax Commission – July
o Attorney General’s Office - July
o Nevada State Contractors Board - September

Legislative Update
• Regular 2023 Legislative Session ended June 5
• Monitoring final bill status
• Will produce a Legislative Session briefing document

Budget Update
• Focus turns to closing out FY 2023
o Largest reversion will be in Cat 01 - Personnel
• Budget implementation for FY 2024
o Public Information Officer

Annual Report Planning


• The Commission approves the Annual Report at its second meeting of the fiscal year
• Major topics – progress on goals, upcoming priorities, and data

Submitted: Ross E. Armstrong, Executive Director


Date: 6/6/2023

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