TO:

FR:
DT:
RE:

Cherie Mancini, SEIU Nevada President & Executive Board Members

Peter Nguyen, SEIU Nevada Director of Organizing & Representation
19 August 2016
Complaint against Sharon Kisling, SEIU Nevada Executive Vice President

I am hereby filing a complaint regarding the conduct of Sharon Kisling, based

upon the following facts:
Since nearly the beginning of my employment with SEIU Nevada, Ms. Kisling
has engaged in discriminatory, harassing, hostile, unprofessional, demeaning, and
otherwise inappropriate behavior towards me.
Most recently, on 17 August 2016, at approximately 3:00 pm, Ms. Kisling
demanded that I meet with her, even though she gave me no prior notice and
made no request for a meeting (though she directed Maleisa Britt to place the item
on my calendar without my knowledge or consent that very morning).
When I entered the conference room, I saw that Ms. Kisling was joined by Ms.
Britt, current Administrative Assistant, and Ms. Christina Breeden, a former parttime intern. Due to her past discriminatory and hostile behavior towards me, I
informed Ms. Kisling that I would be asking Executive Board member Amelia
Gayton to join us. When we sat down, Ms. Kisling stated that she had called the
meeting to investigate concerns regarding my performance and conduct. Upon
hearing this, I stated that I would be willing to discuss such matters with her, but
not in the presence of Ms. Britt, who was currently reporting to me, and Ms.
Breeden who was no longer working at SEIU Nevada.
Ms. Kisling stated that if I refused to have the meeting in the manner that she
insisted, my employment would be in jeopardy. Ms. Gayton interjected that she
felt Ms. Kisling was directly threatening me. I reiterated several times that I was
willing to meet with Kisling, but that it was inappropriate to do so with the
aforementioned individuals present. She began raising her voice while repeatedly
stating that I was reporting to her and that she would terminate my employment if
we did not proceed with the inappropriate meeting.
I stated several times that I was feeling threatened and that she was creating a
hostile work environment for me by raising her voice and and intimidating me. I
also made it know that Ms. Kisling was denying my due process and privacy
rights. After enduring more sustained yelling and threats, I felt the urgent need to
leave this hostile situation. As I rose and attempted to exit, Ms. Kisling told me
that I could not leave unless I wanted to be terminated. At this point, I felt that I
was being held captive in the abusive meeting against my will.
As Ms. Kislings conduct continued to escalate, I stated very calmly that I needed
to leave the conference room, because of her repeated threats. She yelled at me
that I was not able to leave because she was in charge. I stated one more time that
I was willing to meet with her in a different manner, but when she refused and
threatened me again, I exited the room. At this time, Ms. Kisling began yelling at
me and at Ms. Gayton who was trying to calm her down and suggest alternatives
to her threatening actions. This shouting was loud enough to be heard outside of

the conference room in the main public area of the Union Hall, and was beginning to attract some
attention by the staff.
After a few minutes, I returned to the room and calmly said to Ms. Britt, as your supervisor, per the
Presidents instructions, I am directing you to return to your post at the front desk and continue with
your regular duties, or words to that effect. Ms. Kisling ordered Ms. Britt to stay, which she did,
and then ordered me to leave all of my property and that of the union in the hall and to depart from
the premises immediately. I stated that I had done nothing wrong and that I had important work to
do on behalf of the members. Ms. Amelia interjected that there was no justification for her order
and that she did not have the authority to force me out of the office. Ms. Kisling again insisted
loudly that I leave immediately and that she had the authority to terminate me.
Feeling very threatened at this point, I proceeded out of the conference room, at which time Ms.
Kisling followed and confronted me in the main open area of the Union Hall. She approached me
in a very aggressive manner, pointed her finger in my face, leaned her body and face within inches
of me, and screamed at me to leave my Union Hall now, or words to that effect. Ms. Kisling
violated my personal space by leaning in very closely to me and threatened to have me removed if I
refused to leave. Her body and face were twitching and she was in an uncontrolled rage. Even
though I asked her to move away and did nothing to escalate the situation, she continued to shout
threats about my job and started to block my way, no matter what direction I moved. This was
forcing me to endure her barrage of violent words, threats, and aggressive body language. I was in
fear of being imminently struck by her, and was preparing myself to experience violence at her
hands. This caused me great mental anguish.
Ms. Kisling was yelling loudly enough so that just about all the employees in the Union Hall had
heard her, and many were now watching the confrontation and/or coming towards the main open
area. As she continued to shout threats at me, I became concerned for the well-being of my coworkers, because it was clear that everyone was becoming highly disturbed. When I looked in the
other conference room closest to my office, I could see that Organizers Randy Peters and William
Pregman were watching through the glass in bewilderment. In particular, I felt that Mr. Pregman
looked very troubled. I proceeded to enter the conference room to reassure them and dismiss them
from the Union Hall in order to protect them for Ms. Kislings hostility.
Unfortunately, she chased me and, as I tried to close the conference room door so that I could speak
with and help my staff free of harassment, Ms. Kisling violently grabbed the door, shoved it hard
against my body, yanked it back, thrust her limbs into the opening of the door while clawing at me,
and shouted that I could not walk away from her and could not close the door. She then forced her
limbs and body into the room through the door and continued her tirade. Ms. Gayton pleaded with
Ms. Kisling to stop and to calm down, but she was ignored. I looked at Mr. Peters, who asked for
everyone to please settle down, and Mr. Pregman, who was paralyzed by the incident, and told them
they were dismissed from work and should leave the Union Hall.
At this point, as I attempted to exit the conference room, Ms. Kisling stood in my way to hold me
captive to her continued shouting and abuse. Ms. Gayton asked her to back away and allow me to
leave. When I was finally able to exit, I was again dogged by Ms. Kisling all the way out to the
main Union Hall in a very aggressive manner. At this point, Ms. Gayton, out of concern that Ms.
Kisling would become physically violent, placed herself between me and the aggressor. Other staff
now approached us with looks of fear, confusion, and concern. I asked Debbie Miller to dismiss the
staff from the Union Hall so that they would not be subject to Ms. Kislings assault and some staff
began to leave. I also asked Ms. Kisling to please calm down and refrain from upsetting the staff

and our operations. She responded by shouting me down and hollared for Ms. Britt and Ms.
Breeden to call law enforcement to eject me from the building. I believe Ms. Britt carried out the
order.
It was at this time that I felt Ms. Kislings conduct was so egregious and dangerous that it needed to
be recorded, so I began to take a video of her actions with my work iPhone. At first she tried to get
me to stop the recording, but she then changed her tone when I continued to film her.
In order to protect myself from continued threats, I retreated into my office. Ms. Kisling
immediately barged in, physically confronted me, and shouted that I needed to get out. When I
stated that I had the right to be in my office and be free of verbal and physical attack at the
workplace, she screamed that it was no longer my office and added: get out of my Union Hall!
Ms. Gayton entered and asked Ms. Kisling to please leave my office and to stop attacking me, but
she refused. In response to her shouting that this was her Union Hall, Ms. Gayton and I both
reminded Ms. Kisling that this was the members Union Hall, not any individuals, to which she
scoffed and reiterated this is my Union Hall...get out! Ms. Kisling then attempted to take
possession of my personal property, including a MacBook Pro and iPhone. I told her they were my
personal items, yet she insisted that I not touch them and leave them behind. Ms. Gayton told Ms.
Kisling that it was inappropriate for her to try to control my personal property, but she insisted that I
leave those items in her possession.
As she continued to shout threats and obscenities, two leaders of the SEIU staff union, Susan Smith
and Javier Cabrera, entered my office and asked if Ms. Kisling would tone herself down, because
she was causing great disturbance and alarm among the staff who were present. Ms. Kisling
refused and blamed the commotion on my refusal to meet with her. She then stated that she had
consulted with legal counsel and had confirmed that she had the authority to fire me. She then
blamed me for the low membership at Renown and Elko and accused me of having no organizing
plan. Ms. Smith and I both responded that there was a plan and we were doing quite well overall in
terms of membership recruitment.
Ms. Smith left the room to get the accurate numbers regarding how many members we had recruited
in the last month, but, when she and I attempted to share those figures with Ms. Kisling, she
accused me of taking credit for the work of the organizers, which was a complete surprise to those
present. She continued shouting that I would be terminated, and, when I asked her to stop
threatening me, she yelled thats not a threat, its a promise!
Around this time, Ms. Clara Thomas, a SEIU Nevada Trustee and member of the Executive Board,
was on the speaker phone with all of us present in my office. Without fully understanding of
situation at hand, she sided with Ms. Kisling and told me that I needed to leave the office and
recognize Kislings authority. When Ms. Gayton and I objected based upon constitutional grounds,
Ms. Thomas then switched to counseling Ms. Kisling in preparation for the arrival of the police,
warning her to keep her voice down and not to act like you normally do, or words to that effect.
Ms. Kisling continued to occupy my office and personal space and refused multiple requests by me
and Ms. Gayton to leave. She repeatedly demanded that I leave all of my property and vacate the
premises. Feeling very uncomfortable by her constant threats, I left my own office and comforted
the staff that decided to stay. I returned to my office to find that Ms. Kisling had taken possession
of my personal laptop and iPhone. I told her not to touch my things.

Mr. Alfredo Serrano, a SEIU Nevada Trustee and member of the Executive Board, arrived and first
spoke to Ms. Kissling, then me. He attempted to convince Ms. Kisling to leave my office and call
off the police and allow me stay. She refused. Mr. Serrano asked me to avoid my own office,
because she insisted on staying there. I complied with his request.
When the police officer arrived, he first spoke with me, and then with Ms. Kisling. Because we
could not raise the President on the phone, the officer asked me to leave. When I attempted to pack
my things, Ms. Kisling again demanded that I leave behind my personal property and I refused. She
then challenged whether the laptop was mine or not, so I had to state for the record in front of the
officer that the MacBook Pro was mine. Kisling asked me where my SEIU computer was, and I
reminded her it had been stolen the previous weekend during the break-in. I was then escorted by
the officer out of the building between 5:00 and 5:30 pm.
Since the incident, Ms. Kisling has made false and defamatory statements about me to members,
staff, and leaders of SEIU.
As a result of Ms. Kislings actions, I have suffered the following actionable harm:
1.
2.
3.
4.
5.
6.
7.
8.

Assault
Battery
False Imprisonment
Trespass to Chattel
Intentional and/or Negligent Infliction of Emotional Distress
Interference with Business Relations
Invasion of Privacy
Defamation

I would like immediate action to be taken by SEIU to ensure that Ms. Kisling is never again able to
threaten, harm, or otherwise abuse me or other SEIU Nevada staff in the future.
In lieu of formal action, I would like to meet to discuss an amicable resolution to this very serious
situation.