Trustee Kevin Child Vs CCSD

1 COM
MUELLER, HINDS & ASSOCIATES, CHTD

2
Craig A. Mueller, Esq.
3 600 South Eighth Street
Las Vegas, NV 89101
4 P: (702) 940-1234 | F: (702) 940-1235
Attorney for Plaintiff, Kevin L. Child.
5
6
DISTRICT COURT
7
CLARK COUNTY, NEVADA
8
9 Kevin L. Child, individually and as a member Case No.: Number

of the Clark County School District Board of
10 Trustees, and as an individual,
11 Plaintiff, COMPLAINT
12
vs.
(Arbitration Exemption Claimed: Damages
13 in Excess of $50,000.00)
CLARK COUNTY SCHOOL DISTRICT, a
14 Political Subdivision of the State of Nevada;
WILLIAM PATRICK SKORKOWSKY, as
15
former Superintendent of the Clark County JURY TRIAL DEMANDED
16 School District; WILLIAM PATRICK
SKORKOWSKY, an individual; DEANNA
17 WRIGHT, as President of the Board of Trustees
of the Clark County School District; DEANNA
18
WRIGHT, an individual; CAROLYN
19 EDWARDS, as Vice-President of the Board of
Trustees of the Clark County School District;
20 CAROLYN EDWARDS, an individual;
CARLOS McDADE, as former General
21
Counsel of the Clark County School District;
22 CARLOS McDADE, an individual; LOLA
BROOKS, as a Trustee of the Board of Trustees
23 of the Clark County School District, and as an
individual; LINDA CAVAZOS as a Trustee of
24
the Board of Trustees of the Clark County
25 School District, and as an individual; KIM
WOODEN, as Department Superintendent and
26 as an individual, KIRSTEN SEARER, as Chief
Communications, Marketing & Strategy
27
Officer, and as an individual; CEDRIC COLE
28 as the Executive Manager of the Diversity and
1
1 Affirmative Action Program, and as an
individual; JOHN VELLARDITA, as the Clark
2
County Education Association Executive
3 Director, and as an individual; DOE
INDIVIDUAL I through XXX, inclusive; and
4 ROE BUSINESS ENTITY I through XXX,
inclusive,
5
Defendant
6
7
COMPLAINT
8
9 COMES NOW, Plaintiff, KEVIN CHILD, by and through his attorneys of record, the law
10 firm of MUELLER, HINDS AND ASSOCIATES, CHTD., prays and alleges, upon knowledge
11 as to himself and otherwise upon information and belief, against Defendants, CLARK COUNTY
12
SCHOOL DISTRICT (“CCSD”), WILLIAM PATRICK SKORKOWSKY, as former
13
Superintendent of the Clark County School District, WILLIAM PATRICK SKORKOWSKY,
14
15 an individual, DEANNA WRIGHT, as President of the CCSD Board of School Trustees,
16 DEANNA WRIGHT, an individual, CAROLYN EDWARDS, as Vice-President of the CCSD

17 Board of School Trustees, CAROLYN EDWARDS, an individual, CARLOS McDADE, as
18
former General Counsel to the CCSD, CARLOS McDADE, an individual, LOLA BROOKS, as
19
a Trustee of the Board of Trustees of the Clark County School District, and as an individual;
20
21 LINDA CAVAZOS as a Trustee of the Board of Trustees of the Clark County School District,
22 and as an individual, KIM WOODEN, as Deputy Superintendent and as an individual, KIRSTEN

23 SEARER, as Chief Communications, Marketing and Strategy Officer, and as an individual, and
24
CEDRIC COLE as the Executive Manager of the Diversity and Affirmative Action Program,
25
JOHN VELLARDITA, as the Clark County Education Association Executive Director, and as
26
27 an individual (collectively, the “Defendants”), as follows:
28
2
1 PARTIES AND JURISDICTION
2
1. Plaintiff, KEVIN CHILD, is and was, at all times mentioned herein, an individual
3
residing in Clark County, Nevada.
4
2. Defendant, CLARK COUNTY SCHOOL DISTRICT (“CCSD”), is a Political
5
6 Subdivision of the State of Nevada.
7 3. Defendant, WILLIAM PATRICK SKORKOWSKY, as former Superintendent of

8
the Clark County School District, is and was, at all times mentioned herein, the Superintendent
9
or former Superintendent of the Clark County School District and individual residing in Clark
10
County, Nevada, and a Nevada resident.
11
12 4. Defendant, WILLIAM PATRICK SKORKOWSKY, an individual, is an
13 individual residing in Clark County, Nevada, and a Nevada resident (Defendant, WILLIAM
14
PATRICK SKORKOWSKY, as former Superintendent of the Clark County School District, and
15
Defendant, WILLIAM PATRICK SKORKOWSKY, an individual, are collectively referred to
16
herein as “Skorkowsky”). As Skorkowsky acted outside of his statutorily defined role pursuant
17
18 to the allegations of this Complaint, he is being sued in his capacity as former Superintendent of
19 CCSD and in his individual capacity.

20
5. Defendant, DEANNA WRIGHT, as President of the CCSD Board of School
21
Trustees, is and was, at all times mentioned herein, the President of the CCSD Board of School
22
Trustees and or a member of the CCSD Board of School Trustees and an individual residing in
23
24 Clark County, Nevada, and a Nevada resident.
25 6. Defendant, DEANNA WRIGHT, an individual, is an individual residing in Clark

26
County, Nevada, and a Nevada resident (Defendant, DEANNA WRIGHT, as President of the
27
CCSD Board of School Trustees, and Defendant, DEANNA WRIGHT, an individual, are
28
3
1 collectively referred to herein as “Deanna Wright”). As Defendant Deanna Wright acted outside
2
of her statutorily defined role pursuant to the allegations of this Complaint, she is being sued in
3
her capacity as President of the CCSD Board of School Trustees and in her individual capacity.
4
7. Defendant, CAROLYN EDWARDS, as Vice-President of the CCSD Board of
5
6 School Trustees, is and was, at all times mentioned herein, the Vice-President of the CCSD
7 Board of School Trustees and or a member of the CCSD Board of School Trustees and an
8
individual residing in Clark County, Nevada, and a Nevada resident.
9
8. Defendant, CAROLYN EDWARDS, an individual, is an individual residing in
10
Clark County, Nevada, and a Nevada resident (Defendant, CAROLYN EDWARDS, as Vice-
11
12 President of the CCSD Board of School Trustees, and Defendant, CAROLYN EDWARDS, an
13 individual, are collectively referred to herein as “Edwards”). As Defendant Edwards acted

14
outside of her statutorily defined role pursuant to the allegation of this Complaint, she is being
15
sued in her capacity as Vice-President of the CCSD Board of School Trustees and in her
16
individual capacity.
17
18 9. Defendant, CARLOS McDADE, as former General Counsel to the CCSD, is and
19 was, at all times mentioned herein, the General Counsel to the CCSD or the former General
20
Counsel to the CCSD and an individual residing in Clark County, Nevada, and a Nevada resident.
21
10. Defendant, CARLOS McDADE, an individual, is an individual residing in Clark
22
County, Nevada, and a Nevada resident (Defendant, CARLOS McDADE, as former General
23
24 Counsel to the CCSD, and Defendant, CARLOS McDADE, an individual, are collectively
25 referred to herein as “McDADE”). As Defendant McDade acted outside of his statutorily defined
26
role pursuant to the allegations of this Complaint, he is being sued in his capacity as former
27
General Counsel to the CCSD and in his individual capacity.
28
4
1 11. Defendant, LOLA BROOKS, as a Trustee of the Board of Trustees of the Clark
2
County School District, and as an individual, is an individual residing in Clark County, Nevada,
3
and a Nevada resident (hereinafter, “Brooks”).
4
12. Defendant, LINDA CAVAZOS, as a Trustee of the Board of Trustees of the Clark
5
6 County School District, and as an individual, is an individual residing in Clark County, Nevada,
7 and a Nevada resident (hereinafter, “CAVAZOS”).

8
13. Defendant, KIM WOODEN, as Department Superintendent and as an individual,
9
is an individual residing in Clark County, Nevada, and a Nevada resident (hereinafter,
10
“WOODEN”).
11
12 14. Defendant, KIRSTEN SEARER, as the Chief Communications, Marketing and
13 Strategy Officer, and as an individual, is an individual residing in Clark County, Nevada, and a
14
Nevada resident (hereinafter “SEARER”).
15
15. Defendant, CEDRIC COLE, as the Executive Manager of the Diversity and
16
Affirmative Action Program, and as an individual, is an individual residing in Clark County,
17
18 Nevada, and a Nevada resident (hereinafter “COLE”).
19 16. Defendant, JOHN VELLARDITA, as the Clark County Education Association

20
Executive Director, and as an individual, is an individual residing in Clark County, Nevada, and
21
a Nevada resident (hereinafter “VELLARDITA”).
22
17. The true names or capacities, whether individual, corporate, associate, or
23
24 otherwise, of Defendants named herein as DOE INDIVIDUAL I through XXX, inclusive, and
25 ROE BUSINESS ENTITIES I through XXX, inclusive, and each of them, are presently unknown
26
to Plaintiff who therefore sues said Defendants by such fictitious names. Plaintiff is informed
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and believes and thereon alleges that each Defendant designated herein as a DOE INDIVIDUAL
28
5
1 and or ROE BUSINESS ENTITY is legally responsible for and liable to Plaintiff in some way
2
and or manner for the events, occurrences, and happenings which proximately caused damages
3
to Plaintiff, KEVIN CHILD, as herein alleged. A DOE INDIVIDUAL also is responsible as a
4
disseminator or second-hand disseminator of false and defamatory information as alleged in this
5
6 Complaint. A DOE INDIVIDUAL is also responsible as a conspirator and or co-conspirator of
7 Defendants. Plaintiff will seek leave of the Court to amend this Complaint to insert the true
8
names and capacities of Defendants DOE INDIVIDUAL I through X, inclusive, and ROE
9
BUSINESS ENTITIES I through X, inclusive, when the same has been ascertained by Plaintiff,
10
together with the appropriate charging allegations to join such Defendants in this action.
11
12 18. At all times relevant herein, each Defendant was and is an agent, servant, employee,
13 or joint venture of each and every other Defendant herein, and at all times mentioned herein was
14
acting within the scope and course of said agency, employment, or joint venture with knowledge
15
and permission and consent of all other Defendants.
16
19. Whenever it is alleged in this Complaint that a Defendant did any act or thing, it
17
18 is meant that such Defendant’s officers, agents, servants, employees, and or representatives did
19 such an act or thing and at the time such act or thing was done, it was done with full authorization
20
or ratification of such Defendant or was done in the normal and routine course and scope of
21
business, or with the actual, apparent, and or implied authority of such Defendant’s officers,
22
agents, servants, employees, and or representatives. Specifically, Defendants are liable for the
23
24 actions of their officer, agents, servants, employees, and representatives.
25 20. The Court has personal jurisdiction on the claims set forth pursuant to Nevada
26
Revised Statutes (“N.R.S.”) §14.065 on the grounds that such jurisdiction is consistent with the
27
Nevada Constitution and the United States Constitution.
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6
1 21. At all times material to this Complaint, the acts and omissions giving rise to this
2
action occurred in Clark County, Nevada.
3
22. Plaintiff, KEVIN L. CHILD, is a member, a Trustee of the SCHOOL BOARD OF
4
TRUSTEES.
5
6 23. He has been a member, a Trustee, for approximately three and a half (3 ½) years.
7 24. Throughout his entire career spent with the SCHOOL BOARD OF TRUSTEES
8
Mr. Child has never been found to have committed a violation of CCSD’s rules, policies, or
9
regulations.
10
25. Mr. Child filed his intent to seek reelection indicating his intent to continue serving
11
12 as a member, a Trustee, of the SCHOOL BOARD OF TRUSTEES should Mr. Child be reelected.
13 WILLIAM PATRICK SKORKOWSKY, FORMER CCSD SUPERINTENDENT

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26. Defendant Skorkowsky is a former Superintendent of Defendant CCSD, having
15
served as Superintendent of CCSD from 2013 through 2018.
16
27. While serving as Superintendent – a public officer pursuant to N.R.S.
17
18 §281A.182(b) – Defendant Skorkowsky was obligated to conform his conduct to N.R.S. §281A
19 et seq.
20
28. While serving as Superintendent of Defendant CCSD, Skorkowsky outlined a
21
“District Scorecard,” which was meant to measure the school district’s progress on certain goals
22
Skorkowsky deemed to be most important.
23
24 29. One of the goals outlined on Skorkowsky’s “District Scorecard” was “ensuring
25 student safety and happiness.”

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30. Defendant Skorkowsky, as detailed herein, prevented an arbitration award from
27
being appealed in 2017, costing CCSD approximately Nineteen Million Dollars
28
7
1 ($19,000,000.00).
2
31. Defendant Skorkowsky failed to declare an “impasse” when negotiating with the
3
Clark County Education Association (“CCEA Union”) teacher’s union, thereby costing the
4
CCSD at least Thirteen Million ($13,000,000.00) in the next year and potentially almost Forty
5
6 Million ($40,000,000.00) or more for 2018 – 2019. His failure to declare an “impasse” was due
7 to an improper relationship and improper discussions that Defendant Skorkowsky would have
8
with John Vellardita, the highest-ranking and Executive Director of the CCEA Union, and a
9
conspiracy between and among John Vellardita, Pat Skorkowsy, Carolyn Edwards, and Deanna
10
Wright to defraud CCSD.
11
12 32. Defendant Skorkowsky is a close confidant of Defendant Deanna Wright,
13 Defendant Edwards, and Defendant McDade.

14
33. Defendants Edwards, Deanna Wright, and Skorkowsky conspired and continue to
15
conspire to defame Trustee Kevin L. Child for Trustee Child’s actions in dealing with financial
16
malfeasance of the Defendants.
17
18 34. Together, Defendants Edwards, Deanna Wright, and Skorkowsky conspired and
19 continue to conspire to embarrass, defame, and injure Trustee Child.

20
35. Together, Defendants McDade, Edwards, Deanna Wright, and Skorkowsky
21
conspired and continue to conspire to conceal facts regarding Jason Wright, which were brought
22
to Defendant Skorkowsky’s attention by Dr. Goldman and others (and are the subject of several
23
24 Las Vegas Review-Journal Articles).
25 36. Defendant Skorkowsky has taken retaliatory actions as defined pursuant to N.R.S.
26
§281.611(5) against Kevin L. Child.
27
CAROLYN EDWARDS, VICE-PRESIDENT, CCSD BOARD OF SCHOOL TRUSTEES
28
8
1 37. Defendant Edwards is the Trustee from District “F” on the CCSD Board of School
2
Trustees. She was and has been on the CCSD Board of School Trustees since approximately
3
2007.
4
38. Defendant Edwards currently is the Vice-President of the CCSD Board of School
5
6 Trustees.
7 39. She has also served as President in 2011 and 2013, as vice president in 2009 and
8
2010, and as Clerk in 2008.
9
40. As an elected officer of the CCSD Board of Trustees as defined pursuant to N.R.S.
10
§281A.160, Defendant Edwards is obligated to conform her conduct to N.R.S. §281A et seq. As
11
12 an elected officer, she has three (3) roles: 1) hire or fire the CCSD Superintendent; 2) submit a
13 balanced budget to the State of Nevada; and 3) make policy. Defendant Edwards does not have
14
the statutory authority to interfere with or direct enforcement against any tenured employee.
15
41. Defendant Edwards has admitted to violating state law by misusing taxpayer
16
money.
17
18 42. Following a formal complaint with the Nevada Commission on Ethics and a Third-
19 Party Request for Opinion, Defendant Edwards entered into a Stipulated Agreement with the
20
Commission and admitted to violating N.R.S. §281A.520(1)(a).
21
43. In entering into this Stipulated Agreement with the Nevada Commission on Ethics,
22
Defendant Edwards acknowledged her “duty as a public officer to commit herself to protect the
23
24 public trust.”
25 44. However, as detailed in this Complaint, Defendant Edwards has failed to live up
26
to her obligations to either the CCSD or the students of Nevada.
27
45. Defendant Edwards also significantly gained when Defendant Skorkowsky
28
9
1 prevented an arbitration award from being appealed in 2017.
2
46. Defendant Edwards is a close confidant of Defendant Deanna Wright and
3
Defendant Skorkowsky.
4
47. Defendants Edwards, Deanna Wright, and Skorkowsky conspired and continue to
5
6 conspire to defame Trustee Child because Trustee Child demanded and continues to demand
7 financial transparency from Defendants.

8
48. Together, Defendants Edwards, Deanna Wright, and Skorkowsky conspired and
9
continue to conspire to embarrass, defame, and injure Trustee Child.
10
49. Defendant Edwards has taken retaliatory actions as defined pursuant to N.R.S.
11
12 §281.611(5) against Trustee Child.
13 CARLOS McDADE, ESQ. – FORMER GENERAL COUNSEL

14
50. Defendant McDade previously worked for Defendant CCSD as its General
15
Counsel.
16
51. Jon Okazaki, Esq. is the current acting General Counsel.
17
18 52. While serving as Defendant CCSD’s General Counsel, Defendant McDade was
19 investigated by the Nevada State Bar for professional misconduct based upon several CCSD
20
Board of School Trustees admitting to breaking Nevada state law while acting under his legal
21
advice (including but not limited to Defendant Deanna Wright and Defendant Edwards).
22
53. Defendant McDade’s unlawful behavior included but was not limited to his
23
24 dealing with and regarding Defendant Deanna Wright and Defendant Edwards.
25 54. Defendant McDade is a close confidant of Defendant Skorkowsky.

26
55. Instead of Defendant McDade ensuring that proper investigations were done, as
27
favors to his co-conspirators, Defendant McDade, and others, worked in concert to conceal
28
10
1 certain misconduct of employees of CCSD.
2
56. Defendant McDade gave preferential treatment to his friends, allies, and
3
confidants, including but not limited to, preventing investigations into complained about
4
misconduct of Defendants.
5
6 57. Together, Defendants Edwards, McDade, Deanna Wright, and Skorkowsky
7 conspired and continue to conspire to embarrass, defame, and injure Trustee Child.
8
58. Defendant McDade has taken retaliatory actions as defined pursuant to N.R.S.
9
§281.611(5) against Kevin Child.
10
DEANNA WRIGHT, PRESIDENT, CCSD BOARD OF SCHOOL TRUSTEES
11
12 59. Defendant Deanna Wright is currently the President of the CCSD Board of School
13 Trustees, and she has served on the CCSD Board of School Trustees since 2009.
14
60. Following a formal complaint with the Nevada Commission on Ethics and a Third-
15
Party Request for Opinion, Defendant Deanna Wright entered into a Stipulated Agreement with
16
the Commission and admitted to violating N.R.S. §281A.520(1)(a) “for causing a government
17
18 entity, the CCSD, to incur an expense or make an expenditure in support of a ballot question.”
19 Nevada Commission on Ethics, Opinion No. 13-83C.

20
61. In Defendant Deanna Wright entering into this Stipulated Agreement with the
21
Nevada Commission on Ethics, she acknowledged her “duty as a public officer to commit herself
22
to protect the public trust” and has admitted to violating state law by using taxpayer money.
23
24 62. However, as detailed in this Complaint, Defendant Deanna Wright has failed to
25 live up to her obligations to the CCSD and the students of Nevada.

26
63. As an elected officer of the CCSD Board of Trustees as defined pursuant to N.R.S.
27
§281A.160, Defendant Deanna Wright is obligated to conform her conduct to N.R.S. §281A et
28
11
1 seq. As an elected officer, she has three (3) roles: 1) hire or fire the CCSD Superintendent; 2)
2
submit a balanced budget to the State of Nevada; and 3) make policy. Defendant Deana Wright
3
does not have the statutory authority to interfere with or direct enforcement against a tenured
4
employee.
5
6 64. Defendant Deanna Wright also does not have the statutory authority to conceal
7 allegations of a teacher assaulting and battering students.

8
65. Defendant Deanna Wright’s biography from the CCSD Board of School Trustees
9
website, provides that “she constantly works to secure more dollars for education, while also
10
shaping policy to ensure meaningful and discerning changes for the District.”
11
12 66. However, Defendant Deanna Wright’s actions as President of the CCSD Board of
13 School Trustees indicate that she is willing to forego “work[ing] to secure more dollars for
14
education” when it personally benefits her, her husband, and or Defendant Skorkowsky or
15
Defendant Edwards.
16
67. Defendant Deanna Wright is married to Jason Wright.
17
18 68. Jason Wright is also an employee of CCSD. He has been given preferential
19 treatment from the CCSD Board of School Trustees at the behest of his President wife.
20
Additionally, Defendant Deanna Wright has ensured that her husband remains employed by
21
Defendant CCSD despite being unqualified and the existence of allegations that he assaulted and
22
battered at least one (1) school child.
23
24 69. Defendant Deanna Wright uses her power and influence as President of the CCSD
25 Board of School Trustees for personal benefit as well as for the benefit of her husband, Jason
26
Wright.
27
70. Defendant Deanna Wright has put her own personal gain, and the gain of
28
12
1 Defendants Edwards and Skorkowsky, above the safety of students of CCSD.
2
71. Defendant Deanna Wright is a close confidant of both Defendant Edwards and
3
Defendant Skorkowsky.
4
72. Defendant Edwards, Deanna Wright, and Skorkowsky conspired and continue to
5
6 conspire to defame Trustee Child because Trustee Child demands financial transparency from
7 Defendants.
8
73. Defendant Deanna Wright is engaging in such behavior because of her conceived
9
animus against Trustee Child, as she believes Trustee Child has engaged in behavior that runs
10
counter to Defendant Deanna Wright’s and Jason Wright’s best interests.
11
12 74. Instead, together, Defendants McDade, Edwards, Deanna Wright, and
13 Skorkowsky conspired and continue to conspire to conceal facts regarding Jason Wright.
14
75. Together, Defendants Deanna Wright, Edwards, and Skorkowsky conspired to
15
embarrass, defame, and injure Trustee Child.
16
76. Further, together, Defendants Edwards, McDade, Deanna Wright, and
17
18 Skorkowsky conspired and continue to conspire to embarrass, defame, and injure Trustee Child.
19 JASON WRIGHT, HUSBAND OF CCSD BOARD OF SCHOOL TRUSTEES

PRESIDENT, DEFENDANT DEANNA WRIGHT
20
21
77. As stated, Mr. Wright is the husband of Defendant, Deanna Wright, the CCSD
22
Board of School Trustees President.
23
24 78. Defendant Deanna Wright and Mr. Wright have been married since 1991.
25 79. Mr. Wright was previously employed by Defendant CCSD as a support staff clerk
26
in a high school.
27
80. While working in his job as a support staff clerk, Mr. Wright had several serious
28
13
1 violations of CCSD policies and regulations.
2
81. These violations of CCSD policies and regulations should have resulted in Mr.
3
Wright being discharged from his job with Defendant CCSD.
4
82. Previous evaluations of Mr. Wright stated that “he needed improvement in some
5
6 areas” and that he received a written reprimand in 2007.
7 83. However, Deanna Wright used her power and influence as President of the CCSD
8
Board of School Trustees for Mr. Wright to be transferred to a different school as opposed to
9
being discharged.
10
84. Subsequently, Mr. Wright applied for a program offered by Defendant CCSD
11
12 called Alternative Routes to Licensure (“ARL”). The ARL program is designed for professionals
13 such as physicians, attorneys, judges, accountants, and other professionals who do not have a
14
teaching license but who have substantial education (usually a professional degree) and
15
knowledge from practicing their respective professions for a significant amount of time. The
16
ARL program combines classwork with on-the-job training so that a professional can become a
17
18 teacher without first obtaining a teaching license.
19 85. Jason Wright’s initial application for the ARL program was rejected by CCSD’s
20
human resources department.
21
86. However, at the request of Defendant Deanna Wright, Defendant Skorkowsky
22
intervened and ordered that Mr. Wright be admitted into the ARL program.
23
24 87. Mr. Wright was then admitted into the ARL program.
25 88. Defendant Skorkowsky has acknowledged the personal favor he did to Defendant
26
Deanna Wright in directing CCSD’S Human Resources department to “give Mr. Wright an
27
opportunity to participate in the [ARL] program, a clear confirmation of personal benefits.
28
14
1 89. Based upon information and belief, the instance of Defendant Skorkowsky
2
ordering that the ARL program accept Mr. Wright is the only time when a Superintendent has
3
intervened with the ARL program and ordered a rejected application to be admitted.
4
90. While in the ARL program, Mr. Wright was a candidate for a secondary education
5
6 license, which license applies to teaching the 6th grade through the 12th grade.
7 91. However, based upon information and belief, Mr. Wright failed to pass the
8
mathematics tests necessary for a secondary education license.
9
92. Mr. Wright then switched from seeking the secondary education license to an
10
elementary program, which applies to teaching kindergarten through the 8th grade.
11
12 93. Mr. Wright was then hired by Defendant CCSD and later placed at the George E.
13 Harris Elementary School.

14
94. While working at the George E. Harris Elementary School, Mr. Wright has been
15
the subject of several complaints and allegations from students of CCSD.
16
95. One such incident occurred on March 7, 2018, when a 5th grade elementary school
17
18 student at the George E. Harris Elementary School was assaulted and battered by Mr. Wright.
19 96. The student spoke with Victor Joecks, a reporter for the Las Vegas Review-Journal.
20
Mr. Joecks’ article quotes statements made by the student and details the allegations against Mr.
21
Wright.
22
97. The student alleges that his class was in a group outside when he picked up a
23
24 caterpillar. Mr. Wright then “kicked [the student’s] hand,” contacting the student’s hand and
25 finger. When he kicked the student’s hand, Mr. Wright told the student to ‘get in line, go back
26
to the class.”
27
98. Mr. Wright then grabbed the student by the collar and started pulling the student
28
15
1 around by his shirt, jerking the student around to “get [him] in line.”
2
99. The day following this March 7, 2018 incident, CCSD police conducted a criminal
3
investigation “in reference to a report of a teacher committing a battery upon a student.”
4
100. Mr. Wright’s kick left the student’s pinkie finger “swollen and bruised” according
5
6 to the police report cited in Mr. Joecks’ May 2, 2018 article.
7 101. Mr. Joecks’ article indicates that “other students completed statements that
8
corroborated [the student-victim’s] story.”
9
102. Child Protective Services investigated the alleged assault and battery.
10
103. The CCSD police also investigated further but declined to press charges after Mr.
11
12 Wright refused to talk to the investigating detective.
13 104. Instead of Mr. Wright cooperating with the CCSD police, eight (8) days after the
14
incident, Mr. Wright provided a written statement that he used his “left foot to move [the student-
15
victim’s] hand out of the way to protect him from being stung by a bee.”
16
105. The student-victim’s grandmother told Mr. Joecks that Jason Wright was moved
17
18 by Defendant CCSD to another school just days after this March 7, 2018 battery incident.
19 106. Defendant CCSD communications chief, Kirsten Searer, confirmed that Mr.
20
Wright was transferred to a different school within the district by CCSD, stating that the move
21
“was in the best interest of all parties.”
22
107. Mr. Wright was then transferred to the Johnston Middle School. He has since
23
24 transferred to Nate Mack Elementary School, where he is still permitted to teach Nevada’s
25 schoolchildren.
26
108. Based upon information and belief, the principal of Nate Mack Elementary School
27
has already received complaints from concerned parents regarding Mr. Wright.
28
16
1 109. Mr. Wright did not receive any disciplinary actions resulting from the March 7,
2
2018 battery. This is despite Mr. Wright confirming that he battered a 10-year-old 5th grade
3
student.
4
110. The lack of disciplinary action against Mr. Wright and his being allowed to remain
5
6 employed by CCSD is preferential treatment from Defendants CCSD, Skorkowsky, Deanna
7 Wright, and Edwards, that comes at the detriment, disadvantage, and a risk to the safety of
8
Nevada’s schoolchildren.
9
111. Mr. Wright is now a third-year probationary teacher.
10
112. Defendants CCSD, Skorkowsky, Deanna Wright, and Edwards conspired so that
11
12 Mr. Wright could keep a job with CCSD even though he was unqualified and despite allegations
13 that he assaulted and battered at least one (1) school child, all for the monetary benefit of
14
Defendant Deanna Wright and her husband.
15
113. Regarding the assault and battery allegations made against Jason Wright,
16
Defendant Deanna Wright, along with Defendant Skorkowsky and or Defendant Edwards,
17
18 conspired to “sweep these allegations under the rug” and cover-up the possible assault and
19 battery by transferring Mr. Wright to a different school.

20
114. The actions of Mr. Wright and Defendant Deanna Wright, along with Defendant
21
Skorkowsky and or Defendant Edwards, attempted to conceal allegations against Mr. Wright.
22
115. Mr. Wright was simply transferred to another school, which violated the
23
24 customary norms and procedures for dealing with employee misconduct.
25
26
CCSD BOARD OF SCHOOL TRUSTEE’S FAILURE TO DECLARE AN “IMPASSE”
27 AS UNANIMOUSLY VOTED RESULTS IN CCSD LOSING $13 MILLION
28
17
1 116. Pursuant to N.R.S. §288 et seq., Defendant CCSD and the Clark County Education
2
Association (“CCEA Union”) began meeting in February 2017 to negotiate a budget for the 2018
3
– 2019 school year.
4
117. Negotiation sessions for the budget were held on the following dates: 1) February
5
6 6, 2017; 2) March 21, 2017; 3) March 27, 2017; 4) April 3, 2017; 5) April 20, 2017 (April 17,
7 2017 session was cancelled); 6) April 24, 2017; 7) May 1, 2017; 8) May 4, 2017; and 9) May
8
15, 2017 (May 8, 2017 session was cancelled).
9
118. Dr. Goldman was the Chief Negotiator on behalf of CCSD for these negotiations.
10
119. Pursuant to N.R.S. §288.217(3), “If the parties to a negotiation pursuant to this
11
12 section have failed to reach an agreement after at least eight sessions of negotiation, either party
13 may declare the negotiations to be at an impasse and, after 5 days written notice is given to the
14
other party, submit the issues remaining in dispute to the arbitrator selected pursuant to
15
subsection 2.
16
120. The eighth session of negotiation occurred on May 4, 2017 and at the conclusion,
17
18 the CCEA Union had not made a financial proposal.
19 121. At that time, as eight negotiation sessions had concluded without an agreement
20
reached, the District was within its rights to declare an “impasse” pursuant to N.R.S. §288.217,
21
which then would have moved the budget matter to arbitration for an arbitrator to consider the
22
issues remaining in dispute.
23
24 122. Importantly, since the CCEA Union had never made a financial proposal to CCSD,
25 that issue would not have been considered by the arbitrator if CCSD declared an impasse
26
following the eighth negotiation session.
27
123. On May 11, 2017, the CCSD Board of School Trustees was advised that CCEA
28
18
1 Union had not made any financial proposal following eight negotiations and that if an impasse
2
were declared prior to a ninth negotiation session, then no financial could be arbitrated,
3
guaranteeing that CCSD would not have to arbitrate several millions of dollars.
4
124. That same date, the CCSD Board of School Trustees voted unanimously to
5
6 immediately declare an impasse, and the Board instructed the negotiations team to declare an
7 impasse prior to a ninth negotiation session.

8
125. The District, in keeping with the direction of the CCSD Board of School Trustees,
9
planned to hand-deliver a Declaration of Impasse to the CCEA Union.
10
126. However, on the next day, May 12, 2017, Defendant Skorkowsky personally
11
12 called the District’s Chief Negotiator, Dr. Goldman, and contrary to the CCSD Board of School
13 Trustees’ directive, Defendant Skorkowsky instructed Dr. Goldman to not declare an impasse.
14
127. When Dr. Goldman asked Defendant Skorkowsky why no impasse would be
15
declared, Defendant Skorkowsky replied that it was “Teacher’s Appreciation Week.”
16
128. At that time, Dr. Goldman informed Defendant Skorkowsky that not declaring an
17
18 impasse immediately on behalf of the CCSD Board of School Trustees is contrary to the Board’s
19 explicit directive and unanimous vote and could be financially devastating to the district.
20
129. Shortly after Dr. Goldman and Defendant Skorkowsky’s May 12, 2017 telephone
21
conversation, Defendant McDade then telephoned Dr. Goldman.
22
130. Dr. Goldman informed Defendant McDade that Defendant Deanna Wright had no
23
24 authority to decide on her own accord to cancel a negotiation session.
25 131. As Defendant Deanna Wright had no authority to cancel a negotiation session, the
26
ninth session went forward as scheduled for May 15, 2017.
27
132. The attempted cancellation of the May 15, 2017 negotiation session was contrived
28
19
1 by the conspirator Defendants to give the CCEA Union additional time to prepare for the ninth
2
negotiation session and add a financial demand.
3
133. Even though the CCSD Board of School Trustees voted unanimously in favor of
4
declaring an impasse, no Declaration of Impasse occurred prior to the next scheduled negotiation
5
6 session.
7 134. On May 15, 2017 the ninth negotiation session occurred, and Defendant McDade
8
took over Dr.Goldman’s role of CCSD’s Chief Negotiator.
9
135. Interestingly, as if the CCEA Union had been warned of an impasse being declared
10
by CCSD, the first order of business from the CCEA Union at the ninth negotiation was to
11
12 propose a financial proposal which the CCEA Union calculated would cost CCSD about Eighty
13 Million Dollars ($80,000,000.00) for the next fiscal school year.

14
136. Based upon information and belief, Defendant Skorkowsky told the CCEA Union
15
that they failed to make a financial proposal in the first eight negotiation sessions and the
16
implications if CCSD declared an impasse without a financial proposal from the CCEA Union.
17
18 137. Then, right on cue, immediately after the CCEA Union’s financial proposal was
19 made, Defendant McDade then declared an impasse on behalf of CCSD, allowing negotiations
20
to proceed to an arbitrator – including the “23rd hour” CCEA Union financial proposal.
21
138. Subsequently, at the arbitration, the CCEA Union got a favorable arbitration award,
22
resulting in a loss of approximately Thirteen Million Dollars ($13,000,000.00) to CCSD for the
23
24 2017 – 2018 school year, and a minimum Thirty-four Million ($34,000,000.00) loss for the 2018
25 – 2019 school year.

26
139. As such, the failure to declare an impasse prior to the ninth session resulted in a
27
loss of approximately Thirteen Million Dollars ($13,000,000.00) to CCSD for the 2017 – 2018
28
20
1 school year, and a minimum Thirty-Four Million ($34,000,000.00) dollars loss for the 2018 –
2
2019 school year. This vast monetary loss would have been avoided if the Board’s unanimous
3
decision was followed and more importantly, if Defendants Skorkowsky, McDade, and Deanna
4
Wright had not (beyond their statutory authority) interjected themselves, conspired, and
5
6 cancelled a negotiation session and instructed that the CCSD not declare an impasse.
7 140. Moreover, this immense loss of money only occurred because Defendant
8
Skorkowsky (contrary to the District) informed the CCEA Union that they needed to make a
9
financial proposal to CCSD prior to a Declaration of Impasse.
10
141. Additionally, CCEA Union’s proposal awarded by the arbitrator assumes a
11
12 carryover of over Thirty-Eight Million ($38,000,000.00) dollars in insurance costs onto the 2018
13 – 2019 school year, coupling those damages with the continuation of increase in salary or
14
additional costs to CCSD (and the Nevada taxpayers) if the CCEA Union seeks additional money
15
for the 2018 – 2019 school year.
16
142. The District is currently projecting a budget deficit of approximately Sixty-Eight
17
18 Million ($68,000,000.00) dollars, which will result in budget cuts that directly affect the delivery
19 and quality of education services for Nevada’s schoolchildren.

20
143. CCSD is required by law to submit a balanced budget to the State of Nevada. The
21
State (and its taxpayers) are now being asked to fund the District’s budget shortfall, which
22
includes the over Thirty-Eight Million ($38,000,000.00) dollars in increased costs resulting from
23
24 the arbitration award to the CCEA Union.
25 144. On May 19, 2017 the first meeting of the CCSD Board of School Trustees occurred
26
following the failure to declare an impasse.
27
145. At this meeting, the CCSD Board of School Trustees was advised that there was
28
21
1 no Declaration of Impasse by the Board prior to the ninth negotiation session, with Defendant
2
McDade stating that it was his fault that the impasse was not declared.
3
146. Defendant McDade was accused by the CCSD Board of School Trustees of
4
insubordination for his error.
5
6 147. Defendant McDade’s crony, Defendant Skorkowsky, then told the CCSD Board
7 of School Trustees that the failure to declare an impasse, which resulted in a multi-million-dollar
8
error, had already been addressed.
9
148. Defendant McDade was never disciplined for the multi-million-dollar “error.”
10
149. As a direct result of the failure to declare an impasse prior to the ninth negotiation
11
12 session, CCSD will lose tens-of-millions of dollars, countless jobs will be lost, and the State of
13 Nevada’s taxpayers will be tasked with funding these losses, all of which could have been
14
avoided.
15
150. The conspiracy and collusion of Defendants Skorkowsky, McDade, and Deanna
16
Wright cost Nevada’s taxpayers tens-of-millions of dollars, which is directly at the expense of
17
18 Nevada’s schoolchildren.
19 151. The actions and inactions of Defendants Skorkowsky, McDade, Deanna Wright,
20
Carolyn Edwards, Lola Brooks, and Linda Cavazos costing Nevada’s taxpayers tens-of-millions
21
of dollars constitutes violations of N.R.S. §357.040(f) and (g).
22
152. On June 12, 2018, Dr. Goldman filed a formal complaint with Nevada Attorney
23
24 General Adam Laxalt regarding the actions/inactions of Defendants Skorkowsky, McDade, and
25 Deanna Wright damaging Nevada’s citizens and schoolchildren. That same date, Defendant
26
McDade was notified that this formal complaint against Defendants Skorkowsky, McDade, and
27
Deanna wright was filed and that there are prohibitions against retaliation for disclosing
28
22
1 improper District actions both pursuant to Nevada law and the District’s Regulations.
2
153. Defendants have conspired and continue to conspire to retaliate against Dr.
3
Goldman for his filing this June 12, 2018 complaint with the Nevada Attorney General regarding
4
Defendants Skorkowsky, McDade, and Deanna Wright.
5
6 154. When Dr. Goldman raised complaints regarding the failure to declare an “impasse”
7 with Defendant Skorkowsky and the CCSD Board of School Trustees, he was defamed and
8
retaliated against by Defendants.
9
155. Further, Defendants Skorkowsky, McDade, and Deanna Wright have taken
10
retaliatory actions as defined pursuant to N.R.S. §281.611(5) against Dr. Goldman for Dr.
11
12 Goldman’s June 12, 2018 complaint.
13
14
DEFENDANTS CONSPIRED TO POSTPONE DEFENDANT SKORSKOWSKY’S
15 RETIREMENT UNTIL JUNE 30, 2018, COSTING CCSD SIGNIFICANT AMOUNTS
OF ADDITIONAL MONEY THAT GOES DIRECTLY TO DEFENDANT
16 SKORKOWSKY
17
18 156. Defendant Skorkowsky’s term as CCSD Superintendent concluded on June 19,
19 2018 with Dr. Jesus Jara’s Superintendent term officially beginning on that date.
20
157. If Defendant Skorkowsky retired when Dr. Jara’s term began on June 19, 2018 as
21
this was prior to June 30, 2018 Defendant Skorkowsky would not have reached 30 years working
22
for Defendant CCSD. This 30-year mark is important as it correlates to one’s pension in
23
24 retirement.
25 158. More specifically, when one reaches 30 years of work for Defendant CCSD, that
26
person is eligible for a full pension with no penalty. However, for each year less than 30 worked
27
that person is penalized according to their age. For each year under 60 years old, that person is
28
23
1 penalized 4% of their pension.
2
159. On June 19, 2018 Defendant Skorkowsky was 55 years old and had worked for
3
CCSD for 29 years.
4
160. As such, Defendant Skorkowsky, would have received a 20% penalty from his
5
6 pension if he retired on that date, which is prior to June 30, 2018 the date when the Defendant
7 Skorkowsky reached 30 years working for CCSD.

8
161. However, to ensure that Defendant Skorkowsky reached 30 years of work for
9
CCSD (and more importantly, a full pension), certain members of the CCSD Board of School
10
Trustees conspired with Defendant Skorkowsky to allow him to work in a “transitional” role
11
12 through June 30, 2018.
13 162. Since Defendant Skorkowsky retired after 30 years, he received a full pension,
14
without the 20% penalty he was due if he retired upon the commencement of Dr. Jara’s term as
15
Superintendent.
16
163. Over the entire course of Defendant Skorkowsky’s retirement, the 20% penalty
17
18 would amount to possibly hundreds-of-thousands or millions of dollars.
19 164. Due to Defendants conspiracy and the special benefit conferred upon Defendant
20
Skorkowsky, PERS will be forced to pay for the 20% extra in pension that Defendant
21
Skorkowsky will receive every year.
22
165. Defendant Skorkowsky conspired with other co-conpsirator Defendants to ensure
23
24 he would be able to work through June 30, 2018 when his term as Superintendent concluded and
25 Dr. Jara’s began on June 19, 2018 receiving an improper benefit at the expense of Nevada’s
26
taxpayers and schoolchildren.
27
MEMBERS OF THE CCSD BOARD OF SCHOOL TRUSTEES HOLD A SECRET,
28 CLOSE-DOOR, MEETING REGARDING DEFENDANT SKORKOWSKY
24
1
2
166. Pursuant to N.R.S. §241.020, meetings of the CCSD Board of School Trustees are
3
to be “open and public.”
4
167. However, on September 22, 2017 a secret, closed-door, meeting of the CCSD
5
6 Board of School Trustees was held, in violation of Nevada’s open meeting law.
7 168. Prior to this secret meeting, the CCSD Board of School Trustees made a directive
8
requiring a minimum of 300 Professional Growth Units (“PGUs”) for advancement on the salary
9
schedule of CCSD.
10
169. Instead of following the CCSD Board of School Trustees’ directive, Defendant
11
12 Skorkowsky – beyond his authority as Superintendent – took it upon himself to violate terms of
13 a negotiated agreement pertaining to attainment of PGUs, and instead of requiring 300 PGUs for
14
advancement, Defendant Skorkowsky made it so only 225 PGUs were required for advancement
15
on the salary schedule.
16
170. In other words, Defendant Skorkowsky on his own accord and contrary to an
17
18 express directive of the CCSD Board of School Trustees, made the PGU salary advancement
19 requirement only 225 PGUs instead of the minimum of 300 PGUs directed by the CCSD Board
20
of School Trustees.
21
171. The salary requirement of 225 PGUs versus a requirement of 300 PGUs makes it
22
substantially easier for a CCSD employee to advance up the salary schedule, costing Nevada’s
23
24 taxpayers millions of dollars.
25 172. After Dr. Goldman complained to the CCSD Board of School Trustees regarding
26
Defendant Skorkowsky’s actions regarding the PGU salary advancement threshold, Defendant
27
Edwards insisted that Defendant Skorkowsky be allowed to defend himself in a closed session
28
25
1 of the CCSD Board of School Trustees called for the purposes of “negotiations.”
2
173. However, since Defendant Edwards called this secret, closed, session without
3
providing notice to the public, no negotiators were present and no “negotiations” took place at
4
this meeting on September 22, 2017.
5
6 174. As a result of Trustees Child and Chris Garvey indicating that this secret, closed,
7 meeting session violates N.R.S. §241.020 and the requirement that CCSD Board of School
8
Trustees meetings are to be “open and public,” CCSD Board counsel Mary Ann Miller shut this
9
September 22, 2017 meeting down.
10
175. This closed-door secret meeting initiated by Defendant Edwards violates N.R.S.
11
12 §241.020, Nevada’s law requiring meetings to be open and public, and Trustees Child and Chris
13 Garvey can testify to this effect.

14
15
MEMBERS OF THE CCSD BOARD OF SCHOOL TRUSTEES AGAIN VIOLATE
16 NEVADA’S OPEN MEETING LAW
17
18 176. On a second occasion, Defendant Deanna Wright and Defendant Carolyn Edwards
19 again attempted to hold a closed-door meeting with other members of the CCSD Board of School
20
Trustees.
21
177. The subject of the attempted closed-door meeting was Dr. Goldman and the
22
allegations contained in Defendant Harris’ April 10, 2018 correspondence.
23
24 178. Defendant Deanna Wright and Defendant Carolyn Edwards sought to hold this
25 closed-door meeting without notifying Dr. Goldman, and accordingly, he was intentionally not
26
notified.
27
179. Dr. Goldman therefore was not present for this closed-door meeting.
28
26
1 180. Based upon information and belief, two (2) other Trustees – Trustees Child and
2
Chris Garvey – indicated that this attempted closed-door meeting was inappropriate and against
3
Nevada law.
4
181. This closed-door meeting set up by Defendants Skorkowsky, Deanna Wright, and
5
6 Edwards violates N.R.S. §241.020, which is Nevada’s law requiring meetings to be open and
7 public.
8
9
DEFENDANTS VIOLATE NEVADA LAWS AND CCSD DISTRICT REGULATIONS
10
11
12 182. In addition to violating Nevada’s open meeting law, Defendants also violated
13 certain Nevada laws and numerous CCSD Policies or Regulations.

14
183. The following, and potentially other, Nevada laws were violated by Defendants:
15
i. N.R.S. §613.340(1) regarding discrimination;
16
ii. N.R.S. §281.641 regarding retaliation against a public employee for
17
18 reporting improper conduct in government;
19 iii. N.R.S. §281.651 regarding harassment; and

20
iv. N.A.C. §281.305 and N.A.C. §281.315 regarding when an employee
21
claims retaliatory action was taken against them.
22
184. The following, and potentially other, District Regulations were violated by
23
24 Defendants.
25 i. Clark County School District Policy P-4390 regarding Disclosure of

26
Improper District Action;
27
ii. Clark County District Regulation 1212 regarding confidential information
28
27
1 concerning all District personnel being safeguarded; and
2
iii. Clark County District Regulation 4313 regarding the appeal procedure for
3
decisions made by an administrator.
4
6 CEDRIC COLE CONSPIRED WITH KIM WOODEN TO CLAIM HARASSMENT
7
185. Defendants, CEDRIC COLE, KIM WOODEN, DEANNA EDWARDS, LOLA
8
9 CAVAZOS, KIRSTEN SEARER, and PAT SKORKOWSKY conspired with one another to
10 claim Trustee Child harassed her.

11
186. In an attempt to have a reason to preclude Trustee Child from entering various
12
public schools Defendants CEDRIC COLE and KIM WOODEN worked together to concoct a
13
pretense that would seemingly justify barring Trustee Child from various premises.
14
15 187. Defendant Wooden’s false claim resulted in a settlement between Defendant
16 Wooden and CCSD.

17
188. This settlement, predicated upon a false claim, unnecessarily cost CCSD an as of
18
yet undisclosed sum of money.
19
20
21 GENERAL ALLEGATIONS
22
23
189. In October 2016, Trustee Kevin Child began gathering information to investigate
24
potential financial fraud and budgetary waste occurring in the Clark County School District.
25
190. On or about November 30, 2016, Defendant Skorkowsky, acting on behalf of
26
27 Defendant School District (collectively, “Defendants”) sent Trustee Child a letter restricting his
28 ability to visit public schools within the Clark County School District, to wit:
28
1 i. “You are not to enter the administrative offices of the District without a
2
specific written invitation, and prior to following that invitation, you must check in with the front
3
desk of the administrative office to confirm that you have an invitation.”
4
ii. “If you wish to meet with a staff member of the District on official business,
5
6 you are to schedule that meeting to occur at the offices of the Board of School Trustees.”
7 iii. “You are not to appear at any of the District schools unless it is to attend a
8
function which is open to the public or upon the specific written request of the Superintendent
9
or the administrator with authority over that school. In the event that you receive such an
10
invitation from an administrator, you are to forward a copy of that invitation to the
11
12 Superintendent in a timely manner.”
13 iv. “If you fail to comply with these directives, you will be trespassed of the
14
premises.”
15
v. “The District retains its rights to take formal legal action against you as
16
necessary to protect the employees of the District from a hostile work environment.”
17
18 191. On December 5, 2016, Defendant distributed an Interoffice Memorandum that
19 requires the Superintendent be notified of any invitations given to Trustee Child to attend events,
20
meetings and school functions: “The Superintendent must be notified via e-mail or by telephone
21
of all invitations prior to the meeting.”
22
192. On April 24, 2017 Defendant sent a letter to Trustee Child stating, inter alia, that
23
24 he may be criminally cited for trespass if he refuses to abide by the Defendant’s restrictions: “In
25 addition to the restrictions in the communications referenced above, access to the administrative
26
offices of District staff, with the exception of the offices of the Board of School Trustees and
27
Board Office staff, will be restricted to district staff. If you have an appointment with the staff
28
29
1 in the building, upon verification with the Board Office, an escort will take you directly to meet
2
with the employee(s). Signs indicating the restricted area shall be posted and access to these
3
restricted areas will be controlled. If you access the restricted staff area without escort, you will
4
be violated the trespass restrictions and may be cited criminally. The District reserves the right
5
6 to take any other legal actions available to it.”
7 193. On May 31, 2017 Defendant sent a letter to Trustee Child reaffirming the above
8
procedures, giving specific instructions on what rooms may be accessed without permission
9
(even including what restrooms), requiring an escort to access his own office, and admitting that
10
no reasons need be provided if Plaintiff is refused access in the course of his official duties, to
11
12 wit:
13 i. “With regard to school facilities, the current procedure remains in place

14
with the following additions:
15
a. The principal must invite you to events only through the Office of
16
the Superintendent and or Office of the Board of School trustees.
17
18 b. All events must be approved by the Superintendent prior to your
19 acceptance to attend the event. You may then attend that event, but shall not loiter on the facility
20
after the event is complete.
21
c. If approval to an event is denied, there will be no explanation
22
offered.”
23
24 ii. “You may access portions of the Edward A. Greer Education Center
25 building without prior permission, as follows: You may enter in the east side entrance directly
26
into the Board Conference Room. You may go into the Superintendent’s Conference Room, the
27
lobby, the lobby restroom, and the Board Room itself. You may not go into the office of Human
28
30
1 Resources unless permission is given by the Superintendent.”
2
iii. “You may not call or text any CCSD employees directly, with the
3
following exceptions: Superintendent, Depute Chief of Staff/Liaison to the Board of School
4
Trustees, employees assigned to the Office of the Board of School Trustees and Office of the
5
6 Superintendent employees. These individuals will obtain for you information and documents
7 that you request to perform your duties as a Trustees. You must have written permission of the
8
Superintendent each time prior to contacting any employee who is not mentioned above.”
9
194. On October 23, 2017 Defendant sent Plaintiff a letter which stated in bold: “You
10
must immediately cease seeking information from District personnel other than through the
11
12 established Board governance process.”
13 195. In the letter dated October 23, 2017 Defendant affirmatively trespassed Trustee
14
Child from all District property unless there is a prior invitation approved by Defendant
15
Skorkowsky and excluding the Edward A. Greer Building and Administrative Center with the
16
restrictions as noted above. The letter also limited Plaintiff’s interaction with parents, stating
17
18 “You will be assisted by the Board Office staff with scheduling one parent meeting per month.
19 Staff will determine a suitable location and provide support.” The letter stated that if Plaintiff
20
fails to abide by the restrictions, “you may be immediately referred to the appropriate law
21
enforcement agency for prosecution under N.R.S 207.200.”
22
196. On October 24, 2017 Defendant distributed an Interoffice Memorandum to “All
23
24 Administrators” that contained the following: “Starting today, Trustee Child is not allowed to
25 contact any CCSD Employee directly, with the exception of the Superintendent, the
26
Superintendent’s Liaison to the Board of Trustees, and the Executive Assistant to the Board. If
27
you are contacted by Trustee Child by any means, you are not to answer or respond … If Trustee
28
31
1 Child appears at any CCSD building or any CCSD school, including any athletic or sporting
2
event being held before, during or after school hours, you are to ask him to leave the properly
3
and you must call your supervisor immediately.”
4
197. On November 2, 2017 Defendant distributed an Interoffice Memorandum
5
6 confirming that “I made a decision to trespass Trustee Child from district property.”
7 198. Defendant issued the above restrictions under the guise that Trustee Child’s
8
“interactions with District employees made them feel uncomfortable” but upon Plaintiff’s
9
request, failed to provide any specific examples of such complaints.
10
199. Trustee Child received no notice of formal complaints being made until one was
11
12 filed over a year after the above restrictions were entered; this formal complaint remains highly
13 disputed.
14
200. Defendant later stated the above restrictions were a result of Trustee Child’s
15
“disruptive behavior,” but then refers only to classroom discussions (supervised by teachers)
16
with students about bullying, suicide, and other difficult but pervasive topics among students.
17
18 201. Numerous instances in Defendant’s restrictions include inhibitions on gathering
19 information from Human Resource staff, and to Plaintiff’s belief was intended to target and stop
20
Trustee Child’s investigation in monetary waste and potential fraud in the Clark County School
21
District, including misappropriation of funds to consultants and contractors.
22
202. Numerous instances in Defendant’s restrictions include threatening Trustee Child
23
24 with criminal sanctions in the event he visits public schools within his constituency, which again
25 to Trustee Child’s belief was intended to target and stop Trustee Child’s investigation in
26
monetary waste and potential fraud in the Clark County School District, including
27
misappropriation of funds to consultants and contractors.
28
32
1 203. To Trustee Child’s belief, Defendant’s restrictions constitute an ongoing personal
2
vendetta by Defendants and representatives of Defendant District against Trustee Child for
3
effectuating the duties to which he was duly elected and potentially exposing significant
4
budgetary issues within the Clark County School District.
5
6 204. Defendant’s restrictions have and are continuing to inhibit Trustee Child’s lawful
7 duties as a Clark County School District Trustee.

8
9
FIRST CAUSE OF ACTION
10 (Interference with Public Officer – All Defendants)
11
12 205. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
13 through 204 of this Complaint and incorporates each as though fully set forth herein.
14
206. Plaintiff qualifies as a “Public Officer” within the statutory definition of N.R.S.
15
§281A.160.
16
207. That Plaintiff has several duties and obligations which arise from his status as a
17
18 Public Officer, including but not limited to those set forth in N.R.S. Chapters 385, 386, 388 and
19 393.
20
208. That Plaintiff is empowered per N.R.S. §386.350 with “such reasonable and
21
necessary powers, not conflicting with the Constitution and the laws of the State of Nevada, as
22
may be requisite to attain the ends for which the public schools, excluding charter schools and
23
24 university schools for profoundly gifted pupils, are established and to promote the welfare of
25 school children, including the establishment and operation of schools and classes deemed
26
necessary and desirable.”
27
209. That Plaintiff requires access to information or facilities within his constituency
28
33
1 Clark County School District in order to properly perform the duties of his position as a Public
2
Officer, duties which include, but are not limited to discovering corruption, malfeasance, and
3
protection of the public interest insofar as the public interest aligns with the School Board’s
4
interests.
5
6 210. That Defendants, individually and collectively, are continuing to interfere with
7 Plaintiff’s performance of his lawful duties by restricting his access to property and information
8
as detailed above.
9
211. That Defendants, individually and collectively, are continuing to interfere with
10
Plaintiff’s performance of his lawful duties by instructing other personnel not to speak or
11
12 cooperate with Plaintiff as detailed above.
13 212. That Defendants’ actions constitute Interference with a Public Officer, ordinarily
14
a criminal gross misdemeanor, as defined under N.R.S. 197.090.
15
213. That Defendants’ are effectuating said interference by trespassing Plaintiff from
16
facilities within his constituency Clark County School District.
17
18 214. That Defendants are effectuating said interference by threatening Plaintiff with
19 criminal sanction and other liability if he should attempt to properly perform the duties of his
20
position as a Public Officer in violation of their restrictions.
21
215. That Defendants are acting without lawful authority in preventing Plaintiff from
22
accessing facilities and information within his constituency Clark County School District.
23
24 216. That Defendants are acting without lawful authority in interfering with Plaintiff’s
25 proper performance of his duties as a Public Officer.

26
217. That Plaintiff has no adequate remedy at law to prevent the Defendants’ collective
27
interference with the proper performance of his duties as a Public Officer.
28
34
1 218. That Defendants’ unlawful interference cannot be remedied by an award of
2
monetary damages, and requires injunctive relief under this Court’s equitable powers.
3
SECOND CAUSE OF ACTION
4 (Whistleblowing Under Nevada False Claims Act N.R.S. §357 et seq. – All Defendants)
5
8
220. Trustee Child voluntarily disclosed information and took action that acted in
9
furtherance of a False Claims Act action against Defendant employer CCSD and Defendants.
10
221. Defendant CCSD and more specifically, Defendants retaliated against Trustee
11
12 Child because of such actions.
13 222. As a direct and proximate result of Trustee Child’s whistleblowing and the
14
subsequent retaliation by Defendants of Trustee Child for his whistleblower disclosure, he has
15
been damaged in an amount greater than $15,000.00.
16
223. The conduct of Defendants, and each of them, individually and in concert with one
17
18 another as herein alleged, was grossly negligent, reckless, willful, intentional, oppressive,
19 fraudulent, malicious, and done in reckless disregard of the safety and rights of Trustee Child
20
thereby warranting the imposition of punitive damages in excess of $15,000,00.
21
224. That is has been necessary for Trustee Child to retain the services of legal counsel
22
to prosecute this action, and Trustee Child is, therefore, entitled to reasonable attorney’s fees and
23
24 costs associated therewith.
25 225. Moreover, as Defendants have taken retaliatory actions against Trustee Child, he
26
is entitled to reasonable attorney’s fees and costs pursuant to N.R.S. §357.180 and N.R.S.
27
§357.250.
28
35
1 THIRD CAUSE OF ACTION
(Defamation – All Defendants)
2
3
226. Plaintiff repeats and realleges each and every allegation contained in paragraphs 1
4
through 225 of this Complaint and incorporates each as though fully set forth herein.
5
6 227. Defendants made false and defamatory statements concerning Trustee Child.
7 228. Defendants released and disseminated false and defamatory statements concerning
8
Trustee Child to members of the Media as well as newspapers, including but not limited to the
9
Las Vegas Review-Journal, causing unprivileged publications of the false and defamatory
10
statements to third persons.
11
12 229. Defendants were at least negligent in making the false and defamatory statements
13 concerning Trustee Child.

14
230. Trustee sustained actual or presumed damages as a result of the false and
15
defamatory statements concerning him.
16
231. As a direct and proximate result of Defendants’ defamation of Trustee Child, he
17
18 has been damaged in an amount greater than $15,000.00.
19 232. The conduct of Defendants, and each of them, individually and in concert with one
20
another as herein alleged, was grossly negligent, reckless, willful, intentional, oppressive,
21
fraudulent, malicious, and done in reckless disregard of the safety and rights of Trustee Child
22
thereby warranting the imposition of punitive damages in excess of $15,000.00
23
24 233. That is has been necessary for Trustee Child to retain the services of legal counsel
25 to prosecute this action, and Trustee Child is, therefore, entitled to reasonable attorney’s fees and
26
costs associated therewith.
27
234. Moreover, as Defendants have taken retaliatory actions against Trustee Child, he
28
36
1 is entitled to reasonable attorney’s fees and costs pursuant to N.R.S. §357.180 and N.R.S.
2
§357.250.
3
6 FOURTH CAUSE OF ACTION

(Invasion of Privacy – False Light – All Defendants)
7
8
9
10
236. Defendants gave publicity to a matter concerning Trustee Child that placed Trustee
11
12 Child before the public in a false light.
13 237. Defendants released and disseminated false and defamatory statements concerning
14
Trustee Child to members of the Media as well as newspapers, including but not limited to the
15
Las Vegas Review-Journal.
16
238. The false light under which Trustee Child was placed would be highly offensive
17
18 to a reasonable person.
19 239. Defendants had knowledge of or acted in reckless disregard as to the falsity of the
20
publicized matter and the false light in which Trustee was placed.
21
240. Trustee Child sustained actual or presumed damages as a result of the being placed
22
before the public in a false light.
23
24 241. As a direct and proximate result of Defendants’ invasion of privacy – false light
25 portrayal of Trustee Child, he has been damaged in an amount greater than $15,000.00
26
27
another as herein alleged, was grossly negligent, reckless, willful, intentional, oppressive,
28
37
2
thereby warranting the imposition of punitive damages in excess of $15,000.00.
3
4
to prosecute this action, and Trustee Child is, therefore, entitled to a reasonable attorney’s fees
5
6 and costs associated therewith.
8
9
§357.250.
10
11
12 FIFTH CAUSE OF ACTION

(Intentional Infliction of Emotional Distress – All Defendants)
13
14
15
16
246. Defendants’ conduct was extreme or outrageous with either the intention of, or
17
18 reckless disregard for causing emotion distress to Trustee Child.
19 247. Trustee Child suffered severe or extreme emotional distress as the actual or
20
proximate result of Defendants’ conduct.
21
248. As a direct and proximate result of Defendants’ intentional infliction of emotional
22
distress upon Trustee Child, he has been damaged in an amount greater than $15,000.00.
23
24 249. The conduct of Defendants, and each of them, individually and in concert with one
26
fraudulent, malicious, and done in reckless disregard of the safety and rights of Trustee Child
27
28
38
1 250. That it has been necessary for Trustee Child to retain the services of legal counsel
2
3
costs associated therewith.
4
SIXTH CAUSE OF ACTION
5
(Negligent Infliction of Emotional Distress – All Defendants)
6
8
9
252. Defendants’ conduct was extreme or outrageous with either the intention of, or
10
reckless disregard for causing emotion distress to Trustee Child.
11
12 253. Trustee Child suffered severe or extreme emotional distress as the actual or
13 proximate result of Defendants’ conduct.

14
254. As a direct and proximate result of Defendants’ intentional infliction of emotional
15
distress upon Trustee Child, he has been damaged in an amount greater than $15,000.00.
16
17
20
21
256. That it has been necessary for Trustee Child to retain the services of legal counsel
22
23
25 SEVENTH CAUSE OF ACTION

(Civil Conspiracy – All Defendants)
26
27
28
39
2
258. Defendants, by acting in concert, intended to accomplish an unlawful objective for
3
the purpose of harming, embarrassing, harassing, injuring, and/or defaming Trustee Child, and
4
in the case of John Vellardita, Pat Skorkowsky, Carolyn Edwards, and Deanna Wright
5
6 defrauding CCSD
7 259. Trustee Child sustained damages resulting from Defendants’ acts.

8
260. As a direct and proximate result of Defendants’ civil conspiracy against Trustee
9
Child, he has been damaged in an amount greater than $15,000.00.
10
11
14
15
16
to prosecute this action, and Trustee Child, therefore, is entitled to reasonable attorney’s fees and
17
20
21
357.250.
22
PRAYER FOR RELIEF
23
24 WHEREFORE, Plaintiff, KEVIN CHILD, prays for judgment against Defendants, and
25 each of them, as follows:

26
1. For compensatory damages in excess of $15,000.00
27
2. For statutory damages against Defendants Skorkowsky, Deanna Wright, Edwards,
28
40
1 McDade, Kim Wooden, Linda Cavazos, Cedric Cole, Kirsten Searer, and Lola Brooks for actions
2
and inactions done in their official capacities with Defendant CCSD in an amount up to the
3
maximum allowable under Nevada law;
4
3. For additional damages in an uncapped amount against Defendants Skorkowsky,
5
6 Deanna Wright, Edwards, McDade, Kim Wooden, Linda Cavazos, Cedric Cole, Kirsten Searer,
7 and Lola Brooks for actions and inactions done beyond the authority prescribed in N.R.S. §281A
8
et seq. in an amount to be determined by the jury;
9
4. For additional damages in an uncapped amount against Defendant Harris in an
10
amount to be determined by the jury;
11
12 5. For punitive damages in an amount to be determined by the jury;
13 6. For reasonable attorney’s fees and costs of suit incurred herein;

14
7. For reasonable attorney’s fees and costs of suit pursuant to N.R.S. §357 et seq.;
15
8. For pre-judgment and post-judgment interest, as allowed by law; and
16
9. For such other and further relief as this Court may deem just and proper.
17
18
19 Dated this 31st day of August, 2018.

20
21
MUELLER, HINDS & ASSOCIATES, CHTD
22 Craig A. Mueller, Esq.
600 South Eighth Street
23 Las Vegas, NV 89101
P: (702) 940-1234 | F: (702) 940-1235
24 Attorney for ________
25
26
27
28
41

Trustee Kevin Child Vs CCSD

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Trustee Kevin Child Vs CCSD

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1 COM

MUELLER, HINDS & ASSOCIATES, CHTD

9 Kevin L. Child, individually and as a member Case No.: Number

15 an individual, DEANNA WRIGHT, as President of the CCSD Board of School Trustees,

16 DEANNA WRIGHT, an individual, CAROLYN EDWARDS, as Vice-President of the CCSD

22 and as an individual, KIM WOODEN, as Deputy Superintendent and as an individual, KIRSTEN

27 an individual (collectively, the “Defendants”), as follows:

6 Subdivision of the State of Nevada.

7 3. Defendant, WILLIAM PATRICK SKORKOWSKY, as former Superintendent of

12 4. Defendant, WILLIAM PATRICK SKORKOWSKY, an individual, is an

19 CCSD and in his individual capacity.

24 Clark County, Nevada, and a Nevada resident.

25 6. Defendant, DEANNA WRIGHT, an individual, is an individual residing in Clark

13 individual, are collectively referred to herein as “Edwards”). As Defendant Edwards acted

18 9. Defendant, CARLOS McDADE, as former General Counsel to the CCSD, is and

7 and a Nevada resident (hereinafter, “CAVAZOS”).

12 14. Defendant, KIRSTEN SEARER, as the Chief Communications, Marketing and

18 Nevada, and a Nevada resident (hereinafter “COLE”).

19 16. Defendant, JOHN VELLARDITA, as the Clark County Education Association

6 Complaint. A DOE INDIVIDUAL is also responsible as a conspirator and or co-conspirator of

24 actions of their officer, agents, servants, employees, and representatives.

13 WILLIAM PATRICK SKORKOWSKY, FORMER CCSD SUPERINTENDENT

25 student safety and happiness.”

12 32. Defendant Skorkowsky is a close confidant of Defendant Deanna Wright,

13 Defendant Edwards, and Defendant McDade.

19 continue to conspire to embarrass, defame, and injure Trustee Child.

24 Las Vegas Review-Journal Articles).

7 financial transparency from Defendants.

12 §281.611(5) against Trustee Child.

13 CARLOS McDADE, ESQ. – FORMER GENERAL COUNSEL

25 54. Defendant McDade is a close confidant of Defendant Skorkowsky.

6 57. Together, Defendants Edwards, McDade, Deanna Wright, and Skorkowsky

19 Nevada Commission on Ethics, Opinion No. 13-83C.

25 live up to her obligations to the CCSD and the students of Nevada.

7 allegations of a teacher assaulting and battering students.

12 74. Instead, together, Defendants McDade, Edwards, Deanna Wright, and

19 JASON WRIGHT, HUSBAND OF CCSD BOARD OF SCHOOL TRUSTEES

6 areas” and that he received a written reprimand in 2007.

18 teacher without first obtaining a teaching license.

13 Harris Elementary School.

6 to the police report cited in Mr. Joecks’ May 2, 2018 article.

12 Wright refused to talk to the investigating detective.

6 employed by CCSD is preferential treatment from Defendants CCSD, Skorkowsky, Deanna

19 battery by transferring Mr. Wright to a different school.

24 customary norms and procedures for dealing with employee misconduct.

18 the CCEA Union had not made a financial proposal.

7 impasse prior to a ninth negotiation session.

24 authority to decide on her own accord to cancel a negotiation session.

13 Million Dollars ($80,000,000.00) for the next fiscal school year.

25 – 2019 school year.

19 and quality of education services for Nevada’s schoolchildren.

24 the arbitration award to the CCEA Union.

12 Goldman’s June 12, 2018 complaint.

18 156. Defendant Skorkowsky’s term as CCSD Superintendent concluded on June 19,

7 Skorkowsky reached 30 years working for CCSD.

12 through June 30, 2018.

18 would amount to possibly hundreds-of-thousands or millions of dollars.

24 taxpayers millions of dollars.

13 Garvey can testify to this effect.

13 certain Nevada laws and numerous CCSD Policies or Regulations.

18 reporting improper conduct in government;

19 iii. N.R.S. §281.651 regarding harassment; and

25 i. Clark County School District Policy P-4390 regarding Disclosure of