Electronically Filed

9/13/2023 5:00 PM
Steven D.Grierson
CLERK OF THE COURT

1 ANOA
BRADLEY S. SCHRAGER, ESQ. (SBN 10217)
2 DANIEL BRAVO, ESQ. (SBN 13078)
BRAVO SCHRAGER LLP
3 6675 South Tenaya Way, Suite 200
Las Vegas, Nevada 89113 Electronically Filed
4 Tele.: (702) 996-1724 Sep 14 2023 09:59 AM
Email: bradley@bravoschrager.com Elizabeth A. Brown
5 Email: daniel@bravoschrager.com
Attorneys for Defendants Clerk of Supreme Court
6

7 IN THE EIGHTH JUDICIAL DISTRICT COURT

8 OF THE STATE OF NEVADA IN AND FOR CLARK COUNTY

9
CLARK COUNTY SCHOOL DISTRICT, Case No.: A-23-874996-C
10
Plaintiff, Dept. No.: 8
11
vs.
12 NOTICE OF APPEAL
CLARK COUNTY EDUCATION
13 ASSOCIATION; MARIE NEISESS, in
her capacity as President of the Clark
14 County Education Association; JAMES
FRAZEE, in his capacity as Vice
15 President of the Clark County
Education Association; JOHN
16 VELLARDITA, in his capacity as
Executive Director of the Clark County
17 Education Association; and DOES 1-10,
inclusive,
18
Defendants.
19

20

21 Defendants CLARK COUNTY EDUCATION ASSOCIATION, MARIE

22 NEISESS, JAMES FRAZEE, and JOHN VELLARDITA (collectively, “CCEA” or

23 “Defendants”), by and through undersigned counsel, hereby appeals to the Supreme

24 Court of the State of Nevada, pursuant to NRAP 3A(b)(3), the district court’s order

25 / / /

26 / / /

27 / / /

28

Docket 87290 Document 2023-30072

Case Number: A-23-874996-C
1 granting a preliminary injunction, entered on September 13, 2023. A true and correct

2 copy of the district court’s order is attached hereto as Exhibit A.

3 DATED this 13th day of September, 2023.

5 BRAVO SCHRAGER LLP

7 By: /s/ Bradley S. Schrager

BRADLEY S. SCHRAGER, ESQ. (SBN 10217)
8 DANIEL BRAVO, ESQ. (SBN 13078)
6675 South Tenaya Way, Suite 200
9 Las Vegas, Nevada 89113
Tele.: (702) 996-1724
10 Email: bradley@bravoschrager.com
Email: daniel@bravoschrager.com
11 Attorneys for Defendants
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1 CERTIFICATE OF SERVICE

2 I hereby certify that on this 13th day of September, 2023, a true and correct

3 copy of NOTICE OF APPEAL was served by electronically filing with the Clerk of

4 the Court using the Odyssey eFileNV system and serving all parties with an email-

5 address on record, pursuant to Administrative Order 14-2 and Rule 9 of the

6 N.E.F.C.R.

8
By: /s/ Dannielle Fresquez
9 Dannielle Fresquez, an Employee of
BRAVO SCHRAGER LLP
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 Electronically Filed
9/13/2023 4:40 PM
Steven D.Grierson
CLERK OF THE COURT

1 NEO
BRADLEY S. SCHRAGER, ESQ. (SBN 10217)
2 DANIEL BRAVO, ESQ. (SBN 13078)
BRAVO SCHRAGER LLP
3 6675 South Tenaya Way, Suite 200
Las Vegas, Nevada 89113
4 Tele.: (702) 996-1724
Email: bradley@bravoschrager.com
5 Email: daniel@bravoschrager.com

6 Attorneys for Defendants

7
IN THE EIGHTH JUDICIAL DISTRICT COURT
8
OF THE STATE OF NEVADA IN AND FOR CLARK COUNTY
9

10
CLARK COUNTY SCHOOL Case No. A-23-874996-C
11 DISTRICT,
Dept. No.: 8
12 Plaintiff,

13 vs. NOTICE OF ENTRY

14 CLARK COUNTY EDUCATION

ASSOCIATION; MARIE NEISESS, in
15 her capacity as President of the Clark
County Education Association; JAMES
16 FRAZEE, in his capacity as Vice
President of the Clark County
17 Education Association; JOHN
VELLARDITA, in his capacity as
18 Executive Director of the Clark County
Education Association; and DOES 1-10,
19 inclusive,,

20 Defendant.

21

22 ///

23 ///

24 ///

25 ///

26 ///

27 ///

28

Case Number: A-23-874996-C

1 NOTICE OF ENTRY

2 NOTICE IS HEREBY GIVEN that a PRELIMINARY INJUNCTION was

3 entered in the above-captioned matter on the 13th day of September, 2023. A true

4 and correct copy is attached hereto as Exhibit A.

6 DATED this 13th day of September, 2023.

7 BRAVO SCHRAGER LLP

9 By: /s/ Bradley S. Schrager

BRADLEY S. SCHRAGER, ESQ. (SBN 10217)
10 DANIEL BRAVO, ESQ. (SBN 13078)
6675 South Tenaya Way, Suite 200
11 Las Vegas, Nevada 89113
Tele.: (702) 996-1724
12 Email: bradley@bravoschrager.com
Email: daniel@bravoschrager.com
13
Attorneys for Defendants
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1 CERTIFICATE OF SERVICE

2 I hereby certify that on this 13th day of September, 2023, a true and correct

3 copy of NOTICE OF ENTRY was served by electronically filing with the Clerk of the

4 Court using the Odyssey eFileNV system and serving all parties with an email-

5 address on record, pursuant to Administrative Order 14-2 and Rule 9 of the

6 N.E.F.C.R.

8
By: /s/ Dannielle Fresquez
9 Dannielle Fresquez, an Employee of
BRAVO SCHRAGER LLP
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 ELECTRONICALLY SERVED
9/13/2023 3:30 PM Electronically Filed
09/13/2023 3:28 PM

1 ORPI
ETHAN D. THOMAS, ESQ.
2 Nevada Bar No. 12874
ANDREW S. CLARK, ESQ.
3
Nevada Bar No. 14854
4 LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway
5 Suite 300
Las Vegas, Nevada 89169.5937
6 Telephone: 702.862.8800
Fax No.: 702.862.8811
7
Email: edthomas@littler.com
8 Email: asclark@littler.com

9 CRYSTAL J. HERRERA, ESQ.

Nevada Bar No. 12396
10 OFFICE OF THE GENERAL COUNSEL
CLARK COUNTY SCHOOL DISTRICT
11
5100 West Sahara Avenue
12 Las Vegas, Nevada 89146
Phone: (702) 799-5373
13 herrec4@nv.ccsd.net
14 Attorneys for Plaintiff
15 Clark County School District
DISTRICT COURT
16
CLARK COUNTY, NEVADA
17

18 CLARK COUNTY SCHOOL DISTRICT,

19 Plaintiff, Case No.: A-23-874996-C

20
v. Dept. No.: 8
21
CLARK COUNTY EDUCATION
22 ASSOCIATION; MARIE NEISESS, in her PRELIMINARY INJUNCTION
capacity as President of the Clark County
23 Education Association; JAMES FRAZEE, in
his capacity as Vice President of the Clark
24
County Education Association; JOHN
25 VELLARDITA, in his capacity as Executive
Director of the Clark County Education
26 Association; and DOES 1-10, inclusive,
27 Defendants.
28

Case Number: A-23-874996-C

 1 This matter comes before the Court on Plaintiff Clark County School District’s (hereinafter

2 the “District” or “CCSD”) Emergency Motion for Temporary Restraining Order and Preliminary

3 Injunction on Order Shortening Time against Defendants Clark County Education Association,

4 Marie Neisess, James Frazee, and John Vellardita (“Defendants”).

5 WHEREUPON, the Court considered the Emergency Motion for Temporary Restraining

6 Order and Preliminary Injunction on Order Shortening Time, the declarations attached thereto, the

7 documents submitted therewith, and other arguments and evidence presented to the Court, the Court

8 hereby orders as follows:

9 The Court finds that a strike has occurred as defined in NRS 288.074. IT IS HEREBY

10 ORDERED that CCSD’s Emergency Motion for Preliminary Injunction is GRANTED.

11 IT IS FURTHER ORDERED THAT:

12 1. In accordance with NRS 288.705(2), Defendants and the bargaining unit they represent

13 are enjoined and prohibited from continuing the strike and any other actions which

14 amount to a strike, as defined in NRS 288.074; and

15 2. Defendants are ordered to communicate the terms of this Order with all of the CCEA

16 bargaining unit.

17 _______________________________
DISTRICT COURT JUDGE
18 Respectfully Submitted by:
19

20

21
______________________
22
ETHAN D. THOMAS, ESQ.
23 ANDREW S. CLARK, ESQ.
LITTLER MENDELSON, P.C.
24 CRYSTAL J. HERRERA, ESQ.
OFFICE OF THE GENERAL COUNSEL
25 CLARK COUNTY SCHOOL DISTRICT
26
Approved by:
27
/s/ Daniel Bravo
28

Page 2 of 2
 1
CSERV
2
DISTRICT COURT
3 CLARK COUNTY, NEVADA
4

6 Clark County School District, CASE NO: A-23-874996-C

Plaintiff(s)
7 DEPT. NO. Department 8
vs.
8
Clark County Education
9
Association, Defendant(s)
10

11
AUTOMATED CERTIFICATE OF SERVICE
12
This automated certificate of service was generated by the Eighth Judicial District
13 Court. The foregoing Order Granting Preliminary Injunction was served via the court’s
14 electronic eFile system to all recipients registered for e-Service on the above entitled case as
listed below:
15
Service Date: 9/13/2023
16
Ethan Thomas edthomas@littler.com
17

18 Crystal Herrera herrec4@nv.ccsd.net

19 Elsa Pena penaec@nv.ccsd.net

20 Joanne Conti jconti@littler.com

21
Maribel Rodriguez mrodriguez@littler.com
22
Andrew Clark asclark@littler.com
23
Jenny Sharpe jsharpe@littler.com
24
Dannielle Fresquez dannielle@bravoschrager.com
25

26 Bradley Schrager bradley@bravoschrager.com

27 Daniel Bravo daniel@bravoschrager.com

28
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 EIGHTH JUDICIAL DISTRICT COURT
CASE SUMMARY
CASE NO. A-23-874996-C
Clark County School District, Plaintiff(s) § Location: Department 8
vs. § Judicial Officer: Peterson, Jessica K.
Clark County Education Association, Defendant(s) § Filed on: 07/31/2023
§ Cross-Reference Case A874996
§ Number:

CASE INFORMATION

Case Type: Other Civil Matters

Case
07/31/2023 Open
Status:

DATE CASE ASSIGNMENT

Current Case Assignment

Case Number A-23-874996-C
Court Department 8
Date Assigned 07/31/2023
Judicial Officer Peterson, Jessica K.

PARTY INFORMATION
Lead Attorneys
Plaintiff Clark County School District Herrera, Crystal J.
Retained
702-382-1500(W)

Defendant Clark County Education Association Schrager, Bradley S.

Retained
702-341-5200(W)

Frazee, James Schrager, Bradley S.

Retained
702-341-5200(W)

Neisess, Marie Schrager, Bradley S.

Retained
702-341-5200(W)

Vellardita, John Schrager, Bradley S.

Retained
702-341-5200(W)

DATE EVENTS & ORDERS OF THE COURT INDEX

EVENTS
07/31/2023 Complaint
Filed By: Plaintiff Clark County School District
[1] Clark County School District's Complaint for Declaratory and Injunctive Relief

07/31/2023 Initial Appearance Fee Disclosure

Filed By: Plaintiff Clark County School District
[2] Initial Appearance Fee Disclosure

07/31/2023 Summons Electronically Issued - Service Pending

Party: Plaintiff Clark County School District
[3] Summons - Clark County Education Association

PAGE 1 OF 5 Printed on 09/14/2023 at 8:23 AM

 EIGHTH JUDICIAL DISTRICT COURT
CASE SUMMARY
CASE NO. A-23-874996-C
07/31/2023 Summons Electronically Issued - Service Pending
Party: Plaintiff Clark County School District
[4] Summons - James Frazee

07/31/2023 Summons Electronically Issued - Service Pending

Party: Plaintiff Clark County School District
[5] Summons - John Vellardita

07/31/2023 Summons Electronically Issued - Service Pending

Party: Plaintiff Clark County School District
[6] Summons - Marie Neisess

08/01/2023 Motion for Temporary Restraining Order

[7] Emergency Motion Injunctive Relief (For Filing)

08/01/2023 Acceptance of Service

Filed By: Plaintiff Clark County School District
[8] Acceptance of Service

08/01/2023 Notice of Entry

Filed By: Plaintiff Clark County School District
[9] Notice of Entry of Order Shortening Time on Plaintiff's Emergency Motion for Temporary
Restraining Order and Preliminary Injunction

08/08/2023 Initial Appearance Fee Disclosure

[10] Defendants' Initial Appearance Fee Disclosure

08/08/2023 Opposition to Motion For Protective Order

Filed By: Defendant Clark County Education Association; Defendant Neisess,
Marie; Defendant Frazee, James; Defendant Vellardita, John
[11] Defendants' Opposition to Clark County School District's Emergency Motion for
Temporary Restraining Order and Preliminary Injunction on Order Shortening Time

08/10/2023 Media Request and Order

[12] CCSD CCEA DC REQUEST

08/10/2023 Media Request and Order

[13] ccsd

08/11/2023 Media Request and Order

[14] CCSD CCEA 082223

08/15/2023 Reply in Support

Filed By: Plaintiff Clark County School District
[15] Reply in Support of Clark County School District's Emergency Motion for Temporary
Restraining Order and Preliminary Injunction on Order Shortening Time

08/18/2023 Notice
Filed By: Defendant Clark County Education Association
[16] Notice of Change of Firm Name and Address

08/21/2023 Motion
Filed By: Defendant Clark County Education Association; Defendant Neisess,
Marie; Defendant Frazee, James; Defendant Vellardita, John

PAGE 2 OF 5 Printed on 09/14/2023 at 8:23 AM

 EIGHTH JUDICIAL DISTRICT COURT
CASE SUMMARY
CASE NO. A-23-874996-C
[17] Defendants' Anti-Slapp Special Motion to Dismiss Pursuant to N.R.S. 41.660

08/21/2023 Clerk's Notice of Hearing

[18] Clerk's Notice of Hearing

08/21/2023 Media Request and Order

[19] Media Request and Order Allowing Camera Access to Court Proceedings

08/24/2023 Court Recorders Invoice for Transcript

[20] Recording fee for 8/22/23 Hearing

08/25/2023 Transcript of Proceedings

[21] Transcript of 8/22/2023 Hearing

08/25/2023 Order
[22] Order Denying Plaintiff Clark County School District's Emergency Motion For
Temporary Restraining Order And Preliminary Injunction

08/28/2023 Notice of Entry of Order

Filed By: Defendant Clark County Education Association; Defendant Neisess,
Marie; Defendant Frazee, James; Defendant Vellardita, John
[23] Notice of Entry of Order

08/30/2023 Answer
Filed By: Defendant Clark County Education Association; Defendant Neisess,
Marie; Defendant Frazee, James; Defendant Vellardita, John
[24] Defendants' Answer

09/05/2023 Opposition to Motion to Dismiss

Filed By: Plaintiff Clark County School District
[25] Opposition to Defendants' Anti-Slapp Special Motion to Dismiss Pursuant to N.R.S.
41.660

09/05/2023 Appendix
Filed By: Plaintiff Clark County School District
[26] Appendix in Support of Opposition to Defendants' Anti-Slapp Special Motion to Dismiss
Pursuant to N.R.S. 41.660

09/05/2023 Errata
Filed By: Plaintiff Clark County School District
[27] Errata to Opposition to Defendants' Anti-Slapp Special Motion to Dismiss Pursuant to
N.R.S. 41.660

09/11/2023 Order Shortening Time

[28] Emergency Motion For Temporary Restraining Order And Preliminary Injunction On
Order Shortening Time

09/12/2023 Notice of Entry

Filed By: Plaintiff Clark County School District
[29] Notice of Entry of Order Shortening Time on Plaintiff's Emergency Motion for Temporary
Restraining Order and Preliminary Injunction

09/12/2023 Reply in Support

Filed By: Defendant Clark County Education Association; Defendant Neisess,
Marie; Defendant Frazee, James; Defendant Vellardita, John

PAGE 3 OF 5 Printed on 09/14/2023 at 8:23 AM

 EIGHTH JUDICIAL DISTRICT COURT
CASE SUMMARY
CASE NO. A-23-874996-C
[30] Reply in Support of Defendants' Anti-Slapp Special Motion to Dismiss Pursuant to N.R.S.
41.660

09/12/2023 Opposition
Filed By: Defendant Clark County Education Association; Defendant Neisess,
Marie; Defendant Frazee, James; Defendant Vellardita, John
[31] Defendants' Opposition to Clark County School District's Renewed Emergency Motion
for Temporary Restraining Order and Preliminary Injunction on Order Shortening Time

09/12/2023 Media Request and Order

[32] Media Request and Order Allowing Camera Access to Court Proceedings

09/12/2023 Media Request and Order

[33] Media Request and Order Allowing Camera Access to Court Proceedings

09/12/2023 Media Request and Order

[34] Media Request and Order Allowing Camera Access to Court Proceedings

09/12/2023 Supplemental Points and Authorities

Filed by: Plaintiff Clark County School District
[35] Supplement to Emergency Motion for Temporary Restraining Order and Preliminary
Injunction on Order Shortening Time

09/12/2023 Media Request and Order

[36] Media Request and Order Allowing Camera Access to Court Proceedings

09/12/2023 Media Request and Order

[37] Media Request and Order Allowing Camera Access to Court Proceedings

09/12/2023 Supplemental Points and Authorities

Filed by: Plaintiff Clark County School District
[38] Supplement to Emergency Motion for Temporary Restraining Order and Preliminary
Injunction on Order Shortening Time

09/13/2023 Order Granting Preliminary Injunction

[39] Preliminary Injunction

09/13/2023 Notice of Entry

Filed By: Defendant Clark County Education Association; Defendant Neisess,
Marie; Defendant Frazee, James; Defendant Vellardita, John
[40] Notice of Entry

09/13/2023 Notice of Appeal

Filed By: Defendant Clark County Education Association; Defendant Neisess,
Marie; Defendant Frazee, James; Defendant Vellardita, John
[41] Notice of Appeal

HEARINGS
08/22/2023 Hearing (8:00 AM) (Judicial Officer: Peterson, Jessica K.)
Clark County School District's Emergency Motion for Temporary Restraining Order and
Preliminary Injunction on Order Shortening Time
Denied;
Journal Entry Details:
Colloquy regarding reviewing the contract, using hyperlinks, and the Courts exhibit
procedures. Mr. Thomas provided argument regarding freedom of speech, and whether or not
a strike may be illegal by definition. Court acknowledged that Saturday August 26th is the

PAGE 4 OF 5 Printed on 09/14/2023 at 8:23 AM

 EIGHTH JUDICIAL DISTRICT COURT
CASE SUMMARY
CASE NO. A-23-874996-C
deadline for reaching an agreement. Arguments by Counsel regarding concerns of the court
and Mr. Vallardita's statements. COURT ORDERED, Clark County School District's
Emergency Motion for Temporary Restraining Order and Preliminary Injunction on Order
Shortening Time, DENIED. Mr. Shrager will prepare the order.;

09/13/2023 Motion for Temporary Restraining Order (11:00 AM) (Judicial Officer: Eller, Crystal)
OST

09/19/2023 Motion to Dismiss (10:00 AM) (Judicial Officer: Peterson, Jessica K.)
Defendants' Anti-Slapp Special Motion to Dismiss Pursuant to N.R.S. 41.660
DATE FINANCIAL INFORMATION

Defendant Clark County Education Association

Total Charges 337.00
Total Payments and Credits 337.00
Balance Due as of 9/14/2023 0.00

Plaintiff Clark County School District

Total Charges 350.00
Total Payments and Credits 350.00
Balance Due as of 9/14/2023 0.00

PAGE 5 OF 5 Printed on 09/14/2023 at 8:23 AM

 DISTRICT COURT CIVIL COVER SHEET
County, Nevada
Case No.
(Assigned by Clerk's Office)
CASE NO:A-23-874996-C
I. Party Information (provide both home and mailing addresses if different) Department 8
Plaintiff(s) (name/address/phone): Defendant(s) (name/address/phone):
CLARK COUNTY SCHOOL DISTRICT Clark County Education Association, Marie Neisess, James Frazee, John Vellardita

Attorney (name/address/phone): Attorney (name/address/phone):

Ethan D. Thomas, Esq., Andrew S. Clark, Esq. Littler Mendelson, P.C.
3960 Howard Hughes Parkway, Ste. 300, Las Vegas, NV 89169 (702) 862-8800
Crystal Herrera, Esq., Office of the General Counsel, Clark County School District, 5100 West Sahara Avenue

Las Vegas, NV 89146 (702) 799-5373

II. Nature of Controversy (please select the one most applicable filing type below)
Civil Case Filing Types
Real Property Torts
Landlord/Tenant Negligence Other Torts
Unlawful Detainer Auto Product Liability
Other Landlord/Tenant Premises Liability Intentional Misconduct
Title to Property Other Negligence Employment Tort
Judicial Foreclosure Malpractice Insurance Tort
Other Title to Property Medical/Dental Other Tort
Other Real Property Legal
Condemnation/Eminent Domain Accounting
Other Real Property Other Malpractice
Probate Construction Defect & Contract Judicial Review/Appeal
Probate (select case type and estate value) Construction Defect Judicial Review
Summary Administration Chapter 40 Foreclosure Mediation Case
General Administration Other Construction Defect Petition to Seal Records
Special Administration Contract Case Mental Competency
Set Aside Uniform Commercial Code Nevada State Agency Appeal
Trust/Conservatorship Building and Construction Department of Motor Vehicle
Other Probate Insurance Carrier Worker's Compensation
Estate Value Commercial Instrument Other Nevada State Agency
Over $200,000 Collection of Accounts Appeal Other
Between $100,000 and $200,000 Employment Contract Appeal from Lower Court
Under $100,000 or Unknown Other Contract Other Judicial Review/Appeal
Under $2,500
Civil Writ Other Civil Filing
Civil Writ Other Civil Filing
Writ of Habeas Corpus Writ of Prohibition Compromise of Minor's Claim
Writ of Mandamus Other Civil Writ Foreign Judgment
Writ of Quo Warrant Other Civil Matters
Business Court filings should be filed using the Business Court civil coversheet.

July 31, 2023

Date Signature of initiating party or representative

See other side for family-related case filings.

Nevada AOC - Research Statistics Unit Form PA 201

Pursuant to NRS 3.275 Rev 3.1

Case Number:A-23-874996-C
 Electronically Filed
09/13/2023 3:28 PM

1 ORPI
ETHAN D. THOMAS, ESQ.
2 Nevada Bar No. 12874
ANDREW S. CLARK, ESQ.
3
Nevada Bar No. 14854
4 LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway
5 Suite 300
Las Vegas, Nevada 89169.5937
6 Telephone: 702.862.8800
Fax No.: 702.862.8811
7
Email: edthomas@littler.com
8 Email: asclark@littler.com

9 CRYSTAL J. HERRERA, ESQ.

Nevada Bar No. 12396
10 OFFICE OF THE GENERAL COUNSEL
CLARK COUNTY SCHOOL DISTRICT
11
5100 West Sahara Avenue
12 Las Vegas, Nevada 89146
Phone: (702) 799-5373
13 herrec4@nv.ccsd.net
14 Attorneys for Plaintiff
15 Clark County School District
DISTRICT COURT
16
CLARK COUNTY, NEVADA
17

18 CLARK COUNTY SCHOOL DISTRICT,

19 Plaintiff, Case No.: A-23-874996-C

20
v. Dept. No.: 8
21
CLARK COUNTY EDUCATION
22 ASSOCIATION; MARIE NEISESS, in her PRELIMINARY INJUNCTION
capacity as President of the Clark County
23 Education Association; JAMES FRAZEE, in
his capacity as Vice President of the Clark
24
County Education Association; JOHN
25 VELLARDITA, in his capacity as Executive
Director of the Clark County Education
26 Association; and DOES 1-10, inclusive,
27 Defendants.
28
 1 This matter comes before the Court on Plaintiff Clark County School District’s (hereinafter

2 the “District” or “CCSD”) Emergency Motion for Temporary Restraining Order and Preliminary

3 Injunction on Order Shortening Time against Defendants Clark County Education Association,

4 Marie Neisess, James Frazee, and John Vellardita (“Defendants”).

5 WHEREUPON, the Court considered the Emergency Motion for Temporary Restraining

6 Order and Preliminary Injunction on Order Shortening Time, the declarations attached thereto, the

7 documents submitted therewith, and other arguments and evidence presented to the Court, the Court

8 hereby orders as follows:

9 The Court finds that a strike has occurred as defined in NRS 288.074. IT IS HEREBY

10 ORDERED that CCSD’s Emergency Motion for Preliminary Injunction is GRANTED.

11 IT IS FURTHER ORDERED THAT:

12 1. In accordance with NRS 288.705(2), Defendants and the bargaining unit they represent

13 are enjoined and prohibited from continuing the strike and any other actions which

14 amount to a strike, as defined in NRS 288.074; and

15 2. Defendants are ordered to communicate the terms of this Order with all of the CCEA

16 bargaining unit.

17 _______________________________
DISTRICT COURT JUDGE
18 Respectfully Submitted by:
19

20

21
______________________
22
ETHAN D. THOMAS, ESQ.
23 ANDREW S. CLARK, ESQ.
LITTLER MENDELSON, P.C.
24 CRYSTAL J. HERRERA, ESQ.
OFFICE OF THE GENERAL COUNSEL
25 CLARK COUNTY SCHOOL DISTRICT
26
Approved by:
27
/s/ Daniel Bravo
28

Page 2 of 2
 1
CSERV
2
DISTRICT COURT
3 CLARK COUNTY, NEVADA
4

6 Clark County School District, CASE NO: A-23-874996-C

Plaintiff(s)
7 DEPT. NO. Department 8
vs.
8
Clark County Education
9
Association, Defendant(s)
10

11
AUTOMATED CERTIFICATE OF SERVICE
12
This automated certificate of service was generated by the Eighth Judicial District
13 Court. The foregoing Order Granting Preliminary Injunction was served via the court’s
14 electronic eFile system to all recipients registered for e-Service on the above entitled case as
listed below:
15
Service Date: 9/13/2023
16
Ethan Thomas edthomas@littler.com
17

18 Crystal Herrera herrec4@nv.ccsd.net

19 Elsa Pena penaec@nv.ccsd.net

20 Joanne Conti jconti@littler.com

21
Maribel Rodriguez mrodriguez@littler.com
22
Andrew Clark asclark@littler.com
23
Jenny Sharpe jsharpe@littler.com
24
Dannielle Fresquez dannielle@bravoschrager.com
25

26 Bradley Schrager bradley@bravoschrager.com

27 Daniel Bravo daniel@bravoschrager.com

28
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 Electronically Filed
9/13/2023 4:40 PM
Steven D.Grierson
CLERK OF THE COURT

1 NEO
BRADLEY S. SCHRAGER, ESQ. (SBN 10217)
2 DANIEL BRAVO, ESQ. (SBN 13078)
BRAVO SCHRAGER LLP
3 6675 South Tenaya Way, Suite 200
Las Vegas, Nevada 89113
4 Tele.: (702) 996-1724
Email: bradley@bravoschrager.com
5 Email: daniel@bravoschrager.com

6 Attorneys for Defendants

7
IN THE EIGHTH JUDICIAL DISTRICT COURT
8
OF THE STATE OF NEVADA IN AND FOR CLARK COUNTY
9

10
CLARK COUNTY SCHOOL Case No. A-23-874996-C
11 DISTRICT,
Dept. No.: 8
12 Plaintiff,

13 vs. NOTICE OF ENTRY

14 CLARK COUNTY EDUCATION

ASSOCIATION; MARIE NEISESS, in
15 her capacity as President of the Clark
County Education Association; JAMES
16 FRAZEE, in his capacity as Vice
President of the Clark County
17 Education Association; JOHN
VELLARDITA, in his capacity as
18 Executive Director of the Clark County
Education Association; and DOES 1-10,
19 inclusive,,

20 Defendant.

21

22 ///

23 ///

24 ///

25 ///

26 ///

27 ///

28

Case Number: A-23-874996-C

1 NOTICE OF ENTRY

2 NOTICE IS HEREBY GIVEN that a PRELIMINARY INJUNCTION was

3 entered in the above-captioned matter on the 13th day of September, 2023. A true

4 and correct copy is attached hereto as Exhibit A.

6 DATED this 13th day of September, 2023.

7 BRAVO SCHRAGER LLP

9 By: /s/ Bradley S. Schrager

BRADLEY S. SCHRAGER, ESQ. (SBN 10217)
10 DANIEL BRAVO, ESQ. (SBN 13078)
6675 South Tenaya Way, Suite 200
11 Las Vegas, Nevada 89113
Tele.: (702) 996-1724
12 Email: bradley@bravoschrager.com
Email: daniel@bravoschrager.com
13
Attorneys for Defendants
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1 CERTIFICATE OF SERVICE

2 I hereby certify that on this 13th day of September, 2023, a true and correct

3 copy of NOTICE OF ENTRY was served by electronically filing with the Clerk of the

4 Court using the Odyssey eFileNV system and serving all parties with an email-

5 address on record, pursuant to Administrative Order 14-2 and Rule 9 of the

6 N.E.F.C.R.

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By: /s/ Dannielle Fresquez
9 Dannielle Fresquez, an Employee of
BRAVO SCHRAGER LLP
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 ELECTRONICALLY SERVED
9/13/2023 3:30 PM Electronically Filed
09/13/2023 3:28 PM

1 ORPI
ETHAN D. THOMAS, ESQ.
2 Nevada Bar No. 12874
ANDREW S. CLARK, ESQ.
3
Nevada Bar No. 14854
4 LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway
5 Suite 300
Las Vegas, Nevada 89169.5937
6 Telephone: 702.862.8800
Fax No.: 702.862.8811
7
Email: edthomas@littler.com
8 Email: asclark@littler.com

9 CRYSTAL J. HERRERA, ESQ.

Nevada Bar No. 12396
10 OFFICE OF THE GENERAL COUNSEL
CLARK COUNTY SCHOOL DISTRICT
11
5100 West Sahara Avenue
12 Las Vegas, Nevada 89146
Phone: (702) 799-5373
13 herrec4@nv.ccsd.net
14 Attorneys for Plaintiff
15 Clark County School District
DISTRICT COURT
16
CLARK COUNTY, NEVADA
17

18 CLARK COUNTY SCHOOL DISTRICT,

19 Plaintiff, Case No.: A-23-874996-C

20
v. Dept. No.: 8
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CLARK COUNTY EDUCATION
22 ASSOCIATION; MARIE NEISESS, in her PRELIMINARY INJUNCTION
capacity as President of the Clark County
23 Education Association; JAMES FRAZEE, in
his capacity as Vice President of the Clark
24
County Education Association; JOHN
25 VELLARDITA, in his capacity as Executive
Director of the Clark County Education
26 Association; and DOES 1-10, inclusive,
27 Defendants.
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Case Number: A-23-874996-C

 1 This matter comes before the Court on Plaintiff Clark County School District’s (hereinafter

2 the “District” or “CCSD”) Emergency Motion for Temporary Restraining Order and Preliminary

3 Injunction on Order Shortening Time against Defendants Clark County Education Association,

4 Marie Neisess, James Frazee, and John Vellardita (“Defendants”).

5 WHEREUPON, the Court considered the Emergency Motion for Temporary Restraining

6 Order and Preliminary Injunction on Order Shortening Time, the declarations attached thereto, the

7 documents submitted therewith, and other arguments and evidence presented to the Court, the Court

8 hereby orders as follows:

9 The Court finds that a strike has occurred as defined in NRS 288.074. IT IS HEREBY

10 ORDERED that CCSD’s Emergency Motion for Preliminary Injunction is GRANTED.

11 IT IS FURTHER ORDERED THAT:

12 1. In accordance with NRS 288.705(2), Defendants and the bargaining unit they represent

13 are enjoined and prohibited from continuing the strike and any other actions which

14 amount to a strike, as defined in NRS 288.074; and

15 2. Defendants are ordered to communicate the terms of this Order with all of the CCEA

16 bargaining unit.

17 _______________________________
DISTRICT COURT JUDGE
18 Respectfully Submitted by:
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______________________
22
ETHAN D. THOMAS, ESQ.
23 ANDREW S. CLARK, ESQ.
LITTLER MENDELSON, P.C.
24 CRYSTAL J. HERRERA, ESQ.
OFFICE OF THE GENERAL COUNSEL
25 CLARK COUNTY SCHOOL DISTRICT
26
Approved by:
27
/s/ Daniel Bravo
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Page 2 of 2
 1
CSERV
2
DISTRICT COURT
3 CLARK COUNTY, NEVADA
4

6 Clark County School District, CASE NO: A-23-874996-C

Plaintiff(s)
7 DEPT. NO. Department 8
vs.
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Clark County Education
9
Association, Defendant(s)
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AUTOMATED CERTIFICATE OF SERVICE
12
This automated certificate of service was generated by the Eighth Judicial District
13 Court. The foregoing Order Granting Preliminary Injunction was served via the court’s
14 electronic eFile system to all recipients registered for e-Service on the above entitled case as
listed below:
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Service Date: 9/13/2023
16
Ethan Thomas edthomas@littler.com
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18 Crystal Herrera herrec4@nv.ccsd.net

19 Elsa Pena penaec@nv.ccsd.net

20 Joanne Conti jconti@littler.com

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Maribel Rodriguez mrodriguez@littler.com
22
Andrew Clark asclark@littler.com
23
Jenny Sharpe jsharpe@littler.com
24
Dannielle Fresquez dannielle@bravoschrager.com
25

26 Bradley Schrager bradley@bravoschrager.com

27 Daniel Bravo daniel@bravoschrager.com

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A‐23‐874996‐C

DISTRICT COURT
CLARK COUNTY, NEVADA

Other Civil Matters COURT MINUTES August 22, 2023

A-23-874996-C Clark County School District, Plaintiff(s)

vs.
Clark County Education Association,
Defendant(s)

August 22, 2023 8:00 AM Hearing

HEARD BY: Peterson, Jessica K. COURTROOM: RJC Courtroom 15A

COURT CLERK: Rene Watson

RECORDER: Shannon Emmons

REPORTER:

PARTIES
PRESENT: Clark County School District Plaintiff

JOURNAL ENTRIES

- Colloquy regarding reviewing the contract, using hyperlinks, and the Courts exhibit procedures.
Mr. Thomas provided argument regarding freedom of speech, and whether or not a strike may be
illegal by definition. Court acknowledged that Saturday August 26th is the deadline for reaching an
agreement. Arguments by Counsel regarding concerns of the court and Mr. Vallardita's statements.
COURT ORDERED, Clark County School District's Emergency Motion for Temporary Restraining
Order and Preliminary Injunction on Order Shortening Time, DENIED. Mr. Shrager will prepare the
order.

PRINT DATE: 09/14/2023 Page 1 of 1 Minutes Date: August 22, 2023

 EIGHTH JUDICIAL DISTRICT COURT CLERK'S OFFICE
NOTICE OF DEFICIENCY
ON APPEAL TO NEVADA SUPREME COURT

BRADLEY S. SCHRAGER, ESQ.

6675 S. TENAYA WAY, STE. 200
LAS VEGAS, NV 89113

DATE: September 14, 2023

CASE: A-23-874996-C

RE CASE: CLARK COUNTY SCHOOL DISTRICT vs. CLARK COUNTY EDUCATION ASSOCIATION; ET AL.

NOTICE OF APPEAL FILED: September 13, 2023

YOUR APPEAL HAS BEEN SENT TO THE SUPREME COURT.

PLEASE NOTE: DOCUMENTS NOT TRANSMITTED HAVE BEEN MARKED:

$250 – Supreme Court Filing Fee (Make Check Payable to the Supreme Court)**
- If the $250 Supreme Court Filing Fee was not submitted along with the original Notice of Appeal, it must be
mailed directly to the Supreme Court. The Supreme Court Filing Fee will not be forwarded by this office if
submitted after the Notice of Appeal has been filed.

$24 – District Court Filing Fee (Make Check Payable to the District Court)**

$500 – Cost Bond on Appeal (Make Check Payable to the District Court)**
- NRAP 7: Bond For Costs On Appeal in Civil Cases
- Previously paid Bonds are not transferable between appeals without an order of the District Court.

Case Appeal Statement

- NRAP 3 (a)(1), Form 2

Order

Notice of Entry of Order

NEVADA RULES OF APPELLATE PROCEDURE 3 (a) (3) states:

“The district court clerk must file appellant’s notice of appeal despite perceived deficiencies in the notice, including the failure to
pay the district court or Supreme Court filing fee. The district court clerk shall apprise appellant of the deficiencies in writing,
and shall transmit the notice of appeal to the Supreme Court in accordance with subdivision (g) of this Rule with a notation to the
clerk of the Supreme Court setting forth the deficiencies. Despite any deficiencies in the notice of appeal, the clerk of the Supreme
Court shall docket the appeal in accordance with Rule 12.”
Please refer to Rule 3 for an explanation of any possible deficiencies.
**Per District Court Administrative Order 2012-01, in regards to civil litigants, "...all Orders to Appear in Forma Pauperis expire one year from
the date of issuance." You must reapply for in Forma Pauperis status.
 Certification of Copy
State of Nevada
SS:
County of Clark

I, Steven D. Grierson, the Clerk of the Court of the Eighth Judicial District Court, Clark County, State of
Nevada, does hereby certify that the foregoing is a true, full and correct copy of the hereinafter stated
original document(s):
NOTICE OF APPEAL; DISTRICT COURT DOCKET ENTRIES; CIVIL
COVER SHEET; PRELIMINARY INJUNCTION; NOTICE OF ENTRY; DISTRICT COURT
MINUTES; NOTICE OF DEFICIENCY

CLARK COUNTY SCHOOL DISTRICT,

Case No: A-23-874996-C
Plaintiff(s),
Dept No: VIII
vs.

CLARK COUNTY EDUCATION

ASSOCIATION; MARIE NEISESS, in her
capacity as President of the Clark County
Education Association; JAMES FRAZEE, in his
capacity as Vice President of the Clark County
Education Association; JOHN VELLARDITA,
in his capacity as Executive Director of the Clark
County Education Association,

Defendant(s),

now on file and of record in this office.

IN WITNESS THEREOF, I have hereunto

Set my hand and Affixed the seal of the
Court at my office, Las Vegas, Nevada
This 14 day of September 2023.

Steven D. Grierson, Clerk of the Court

Cierra Borum, Deputy Clerk

 EIGHTH JUDICIAL DISTRICT COURT
CLERK OF THE COURT
REGIONAL JUSTICE CENTER
200 LEWIS AVENUE, 3rd Fl.
LAS VEGAS, NEVADA 89155-1160
(702) 671-4554

Steven D. Grierson Anntoinette Naumec-Miller

Clerk of the Court Court Division Administrator

September 14, 2023

Elizabeth A. Brown
Clerk of the Court
201 South Carson Street, Suite 201
Carson City, Nevada 89701-4702

RE: CLARK COUNTY SCHOOL DISTRICT vs. CLARK COUNTY EDUCATION ASSOCIATION;
ET AL.
D.C. CASE: A-23-874996-C

Dear Ms. Brown:

Please find enclosed a Notice of Appeal packet, filed September 13, 2023. Due to extenuating
circumstances minutes from the date(s) listed below have not been included:

September 13, 2023

We do not currently have a time frame for when these minutes will be available.

If you have any questions regarding this matter, please contact me at (702) 671-0512.

Sincerely,
STEVEN D. GRIERSON, CLERK OF THE COURT

/s/ Cierra Borum

Cierra Borum, Deputy Clerk