FILED

Electronically
CV25-01334
2025-08-13 05:04:16 PM
Alicia L. Lerud
Clerk of the Court
Transaction # 11180052 : msalazarperez

EXHIBIT I
 1 GARIN LAW GROUP
JOSEPH P. GARIN, ESQ.
2 Nevada Bar No. 6653
9900 Covington Cross Drive, Suite 210
3
Las Vegas, Nevada 89144
4 Phone: (702) 382-1500
Fax: (702) 382-1512
5 jgarin@garinlawgroup.com
6 Attorneys for Alex Velto, Devon Reese, and
Reese, Ring, Velto PLLC
7

8
IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA
9
IN AND FOR THE COUNTY OF WASHOE
10

11 MICHAEL LEONARD, an individual, Case No: CV25-01334

12 Plaintiff,
vs.
13 DECLARATION OF DEVON T.
ALEX VELTO, an individual; CONOR REESE IN SUPPORT OF SPECIAL
14 MOTION TO DISMISS PURSUANT
MCQUIVEY, an individual; RENOITES, a TO NRS 41.660
15 fictitious business entity; DEVON REESE,
an individual; REESE, RING, VELTO PLLC,
16 a Nevada Professional Limited Liability
Corporation; Does I through X, inclusive,
17
Defendants.
18

19

20 I, Devon T. Reese, declare as follows:

21 1. I am an attorney licensed to practice law in the State of Nevada for twenty-

22 five years and a named Defendant in this action. I am also a duly elected member of the

23 Reno City Council since February 2019. I submit this Declaration in support of my

24 Motion to Dismiss and Special Motion to Strike pursuant to Nevada’s anti-SLAPP

25 statute (NRS 41.635 et seq.).

26 2. I am over 18 years of age. I have personal knowledge of the matters

27 stated herein and, if called as a witness, could and would testify competently thereto.

28 3. I am competent to testify to the matters set forth in this Declaration and

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 1 will do so if called upon.

2 4. Plaintiff Michael Leonard’s First Amended Complaint contains numerous

3 falsehoods and mischaracterizations of my conduct and public statements. It seeks to

4 chill protected speech, relitigate previously resolved matters, and weaponize the legal

5 process to silence legitimate concerns expressed by me and others in the community.

6 The Belleville Wine Bar Incident – What Actually Happened

7 5. I arrived at Belleville Wine Bar at approximately 5:25 p.m. on March 14,

8 2025, to attend a private gathering related to bringing a celebrity-sponsored event to

9 Reno. Others present included my husband (Felipe Cisneros Jr.), Taylor and Phoenix

10 Adams (Taylor is the Executive Director of the Economic Development Authority of

11 Western Nevada), Reno Mayor Hillary Schieve, Dr. Whitney Hovnick, and several other
Telephone: (702) 382-1500 Facsimile: (702) 382-1512
9900 Covington Cross Drive, Suite 210, Las Vegas, Nevada 89144

12 community members.

13 6. Our group was seated at the Wine Bar at a table with a clear view of the

14 entrance. However, I was seated with my back to the door. Shortly after one of our party

15 arrived and took her seat, which faced the door, she became visibly upset, emotional,

16 scared, near tears and said something to the effect of, she believed that Mr. Leonard

17 was “the guy who has been stalking me and my daughter who just showed up; he must

18 have followed me.” When I turned around to see who she was referring to, I saw Plaintiff

19 Michael Leonard.

20 7. Mr. Leonard entered the bar around 6:23 p.m.

21 8. Another in our group reported their belief that Leonard was also stalking

22 and driving past their home multiple times a day. Based on the reactions of these two in

23 our party, and the context of previous disturbing interactions Mr. Leonard has had with

24 my former clients, my law partner Alex Velto, and his wife Sarah Velto, I was alarmed by

25 his presence and the reports of Mr. Leonard’s behavior.

26 9. To verify that it was Mr. Leonard, a person in my group took this picture of
27 him with her phone. I then sent it to Sarah Velto asking for confirmation that this was in

28 fact Mr. Leonard. Below is a true and accurate copy of the photographs from March 14,

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 1 2025 at the Belleville Wine Bar.

10

11
Telephone: (702) 382-1500 Facsimile: (702) 382-1512
9900 Covington Cross Drive, Suite 210, Las Vegas, Nevada 89144

12 10. I had previously represented Mrs. Velto in a preliminary injunction hearing

13 against Mr. Leonard, who had been harassing her. Notably, Mr. Leonard’s harassment

14 of Mrs. Velto occurred only after Mr. Velto and my law firm began representing a local

15 journalist, Conor McQuivey.

16 11. Mrs. Velto confirmed that this was Mr. Leonard in the picture. She

17 cautioned me to be careful and offered to come pick me up.

18 12. Based on my personal knowledge and prior experiences, I knew that Mr.

19 Leonard had a history of harassing behavior, including stalking other individuals known

20 to me. I was also aware that protective orders had been issued against him, a

21 preliminary injunction order had been issued against him for similar behavior, and that

22 he possessed firearms.

23 13. I was also aware that he was prevented from contacting me because of a

24 settlement agreement entered between Mrs. Velto and Mr. Leonard, which identified me

25 as an intended beneficiary, obligating Mr. Leonard to avoid contacting me.

26 14. Considering these facts and the circumstances of his sudden appearance,

27 I was alarmed and concerned for my safety and the safety of everyone in our group.

28 15. Rather than confronting Mr. Leonard, I stepped outside the bar, contacted

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 1 the Reno Police Department, and asked how our party should deal with the situation. I

2 was instructed not to engage with Leonard and that a patrol unit would be dispatched to

3 the area.

4 16. I returned inside the bar to my group and ignored Mr. Leonard, although

5 remaining alert out of concern for what he might do. Jackie Goodman and Amanda

6 Burden of our group began to leave, and we exchanged goodbyes. It was at this point

7 that Mr. Leonard approached me in a manner that startled me. Before he could speak,

8 and despite my apprehension, I calmly told him without raising my voice that he was in

9 violation of the settlement agreement that prohibited him from interacting with me or

10 anyone at my law firm. I instructed him to leave the bar before I called the police. I was

11 apprehensive but calm and polite. At no point did I raise my voice or threaten Leonard.
Telephone: (702) 382-1500 Facsimile: (702) 382-1512
9900 Covington Cross Drive, Suite 210, Las Vegas, Nevada 89144

12 17. In response, Mr. Leonard became irate, cursed at me, and said something

13 to the effect of, “I’ll fund your opponent. I will ruin you. This is my bar.” I did not engage

14 further and remained calm. I again left the bar to find out if the Reno Police had arrived.

15 Mr. Leonard left the bar at approximately 6:34 p.m.

16 18. In total, Mr. Leonard was at the Wine Bar for less than 11 minutes.

17 Leonard’s Publication of the Incident and my Facebook Post

18 19. Later that evening or early the next morning, Mr. Leonard filed a false

19 police report and began circulating misleading claims to media outlets, including Our

20 Town Reno, This Is Reno, and Picon Press. Leonard’s police report is false. Mr.

21 Leonard claims in the report “I was at the Belleville Wine Bar . . . and Devon Reese

22 walked in. . .” Mr. Leonard knows that I was at the Wine Bar long before he arrived. Mr.

23 Leonard was staring at me as he entered and stared right into my camera as I took a

24 photo of him from a seated position.

25 20. After filing the police report, Mr. Leonard began circulating the police

26 report to media outlets and the City of Reno, insisting the media outlets run the story
27 and the City of Reno place the police report (and his complaint) in public comment. The

28 next day, some media outlets ran the story.

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 1 21. On or about March 17, 2025, in response to media inquiries started by

2 Leonard, I made a post on my personal social media Facebook account to respond to

3 the claims and public attention arising from the Belleville Wine Bar incident.

4 22. The post from my Facebook page is quoted in the First Amended

5 Complaint:

6 Friends - scary incident this past weekend that I can’t go into in detail for
legal reasons but suffice to say: people I care about, clients, and friends
7 have been harassed, stalked, and victimized by Michael Leonard. Lots of
factual details in the This is Reno story today - I’m posting the pics of the
8
article for ease. Our Town Reno/Biggest Little Streets (Nico Colombant),
9 Picon Press (Candy Green), and others continually try to spin a false
narrative about me using the term “news.” This Is Reno is usually in that
10 camp, though today’s coverage is actually refreshingly fair (minus the
headline, which is in itself ugly to have the accusation in the headline and
11 the truth behind the paywall). If you want further context on who the
Telephone: (702) 382-1500 Facsimile: (702) 382-1512
9900 Covington Cross Drive, Suite 210, Las Vegas, Nevada 89144

individual is whose lies they are printing to smear me, read Conor’s post.
12
And while I very much value local and independent journalism - please
13 consider the source. What is their bias? What is the objective? Why do
they chose the headlines they choose? What is motivating them to cover
14 the stories they cover? Why do they obsess about one elected and fawn
over others? Read and consume news from lots of different sources but
15 just know that there is always more to the story. And if you have any
16 questions for me, just ask; if there is one lesson I learned the hard way
from Emily, it’s that you have to live your life out loud and in public.
17

18 23. My post serves as a carefully measured reply to Mr. Leonard’s

19 accusations to defend myself and provide context. I have approximately 4,400 people

20 that follow my Facebook page. I cannot state the total number of people who read my

21 post. There were 57 reactions and 27 comments made about my post.

22 24. At the same time, my post is a broader critique of local media's tendency

23 to prioritize clickbait and sensationalism to drive viewership, rather than engaging in

24 rigorous journalism that evaluates the credibility of sources and thoroughly analyzes the

25 facts. I also expressed concern over the media’s handling of the matter and

26 encouraged the public to critically evaluate the sources they rely on.

27 25. My Facebook post is either true, substantially true, and made without

28 knowledge of falsehood. My post was a limited reply to Mr. Leonard’s statements and

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 1 provided context based on my experience with Mr. Leonard. I stated that “people I care

2 about, clients, and friends have been harassed, stalked, and victimized by Michael

3 Leonard,” and I linked to an article from This Is Reno for further context. This statement

4 is based on my personal experience with Mr. Leonard from my representation of Mr.

5 and Mrs. Velto at the preliminary injunction hearing and that Court’s order involving Mr.

6 Leonard.

7 26. In addition, my post was made in good faith and addressed matters of

8 public concern—namely, community safety, judicial process, and media accountability. I

9 believe that everything I wrote was true or substantially true. I did not have knowledge

10 of any falsehood in my statements.

11 27. Mr. Leonard alleges that my online post constitutes “defamation per se”
Telephone: (702) 382-1500 Facsimile: (702) 382-1512
9900 Covington Cross Drive, Suite 210, Las Vegas, Nevada 89144

12 and harassment. These claims are without merit. My comments were not defamatory. I

13 provided a measured reply to Leonard’s statements based on my experience, public

14 records, and what I learned from others. Mr. Leonard’s actions publicizing the Belleville

15 Wine Bar Incident and his police report elevated the incident to a matter of public

16 concern.

17 28. To the extent my statements also include rhetorical language, opinion, or

18 hyperbole, they are constitutionally protected. Nevada courts routinely recognize that

19 commentary on public conduct, particularly by public officials, is privileged.

20 29. Mr. Leonard’s lawsuit is retaliatory and intended to silence criticism,

21 intimidate me and others, and chill protected expression. It is precisely the type of action

22 Nevada’s anti-SLAPP law is designed to deter.

23 30. I respectfully request that the Court grant the Motion to Dismiss and

24 Special Motion to Strike in its entirety, dismiss all claims against me with prejudice, and

25 award attorneys’ fees, costs, and other relief under NRS 41.670.

26 ///
27 ///

28 ///

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 1 I declare under penalty of perjury under the laws of the State of Nevada that the

2 foregoing is true and correct.

3 Dated this 13th day of August, 2025.

4
/s/ Devon T. Reese
5 ___________________________________
DEVON T. REESE
6

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Telephone: (702) 382-1500 Facsimile: (702) 382-1512
9900 Covington Cross Drive, Suite 210, Las Vegas, Nevada 89144

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