Temporary Restraining Order

Electronically Filed
08/05/2020 11:11 AM
1 TRO
JEFFREY F. BARR, ESQ.
2 Nevada Bar No. 7269
TIFFANY A. KAHLER, ESQ.
ARMSTRONG TEASDALE LLP
4 3770 Howard Hughes Parkway, Suite 200
Las Vegas, NV 89169
5 Telephone: 702-678-5070
Facsimile: 702-878-9995
6 [email protected]
[email protected]
7
Attorneys for Plaintiff Alfonso Noyola
8
RICHARD C. GORDON, ESQ
BRADELY T. AUSTIN, ESQ.
SNELL & WILMER L.L.P.
Las Vegas, Nevada 89169
12 Telephone: 702.784.5200
Facsimile: 702.784.5252
13 [email protected]
[email protected]
14
Attorneys for Plaintiff Steven L. Morris
15
16
17 DISTRICT COURT
18 CLARK COUNTY, NEVADA
19
Case No.: A-20-818973-C
20 ALFONSO NOYOLA, an individual, and
STEVEN L. MORRIS, an individual Dept. No.: 24
21
Plaintiffs,
22 TEMPORARY RESTRAINING
vs. ORDER
23
THE CITY OF BOULDER CITY, a political
24 subdivision of the State of Nevada,
25 Defendant.
26
Alfonso Noyola (“Mr. Noyola”) and Steven L. Morris (“Mr. Morris”) (collectively,
27
“Plaintiffs”), by and through their respective attorneys of record, filed their Ex Parte Application for
28
Temporary Restraining Order (the “Application for TRO”) against Defendant The City of Boulder
1
1 City (“The City”) on August 4, 2020.
2 The Court, having reviewed and considered the Application for TRO, and good cause
3 appearing therefore, THE COURT HEREBY FINDS THAT:
4 1. Plaintiffs met their burden under NRCP 65(b) for issuance of an Ex Parte Temporary
5 Restraining Order against The City, pending a hearing on the preliminary injunction, as
6 the facts set forth in the Application for TRO support a finding that:
7 a. Plaintiffs will suffer immediate and irreparable harm, should The City be
8 permitted to proceed with hearing Items 1-4 on the August 6, 2020 Special
9 Meeting Agenda – which Special Meeting and Special Meeting Agenda violate
10 Nevada’s Open Meeting Law, NRS ch. 241; and
11 b. The Ex Parte Temporary Restraining Order is necessary to preserve the status quo
12 and prevent said irreparable harm; and
13 There is insufficient time for The City to be heard regarding the Temporary Restraining Order
14 prior to the August 6, 2020 Special Meeting. THEREFORE, IT IS HEREBY ORDERED THAT:
15 A. Plaintiffs’ Application for TRO is GRANTED;
16 B. The Court further orders that The City, City Council, its agents, servants and employees,
17 and those persons acting in convert or participation with them, are prohibited and enjoined
18 from hearing Items 1-4 of the August 6, 2020 Special Meeting Agenda until the
19 conclusion of the preliminary injunction hearing;
20 C. The Court further orders the hearing on Plaintiffs’ Motion for Preliminary Injunction is
21 20th of ___________,
scheduled for the ____ August 2020, at the hour of _____
9:00 o’clock ____.m.
a in
24
22 Department ______of the Eighth Judicial District Court. The hearing will not be an
23 evidentiary hearing;
24 D. The Court further orders that Plaintiffs shall serve The City with the Application for
25 Temporary Restraining Order and Preliminary Injunction, and the executed Temporary
26 August 7
Restraining Order by _______________, 2020;
27 E. This Temporary Restraining Order shall expire at the conclusion of the preliminary
28 August 20, 2020 unless otherwise ordered by the Court;
injunction hearing on _______________,
2
1 F. The City’s Opposition brief shall be filed and electronically served on Plaintiffs and the
2 August 11 at _____.m;
Court by ___________ 4:00 p
3 G. The Plaintiffs’ Reply brief shall be filed and electronically served on The City by
4 August 14 ______.m;
__________at 9:00
5 500.00
H. The Court further order that Plaintiffs shall post a bond in the amount of $_________.
6 This security shall be deposited with the Clerk of the Court.
7 IT IS SO ORDERED.
8 DATE:____________________HOUR:_________________
9
10 DISTRICT COURT JUDGE

11
Respectfully submitted:
12 ARMSTRONG TEASDALE LLP
13
By: /s/Tiffany A. Kahler
14 JEFFREY F. BARR, ESQ.
TIFFANY A. KAHLER, ESQ.
3770 Howard Hughes Parkway, Suite 200
17 Las Vegas, Nevada 89169
18 Attorneys for Plaintiff Alfonso Noyola
19
20 SNELL & WILMER L.L.P.
21 By: /s/Richard C. Gordon

RICHARD C. GORDON, ESQ
23 BRADELY T. AUSTIN, ESQ.
Nevada Bar No. 13064
Las Vegas, Nevada 89169
25
Attorneys for Plaintiff Steven L. Morris
26
4831-8414-1766
27
28
3
Sheila Darling
From: Gordon, Richard <[email protected]>

Sent: Tuesday, August 04, 2020 10:21 AM
To: Tiffany A. Kahler; Austin, Bradley
Cc: Jeffrey F. Barr
Subject: Noyola/Morris v. Boulder City (Case No. A-20-818973-C) - Authorization to E-Sign
EXTERNAL
CAUTION:
EMAIL
Tiffany,
Since you will be submitting the TRO Application and Order to chambers, you have
authorization to e-sign any documents for me on behalf Mr. Steven Morris. Thanks in advance for
your assistance.
Best,
Rick
Richard C. Gordon, Esq.

Snell & Wilmer
______L.L.P.______
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, NV 89169
(702) 784-5210 (direct)
(702) 784-5200 (main)
(702) 784-5252 (facsimile)
[email protected]
"The information contained in this electronic mail message is confidential information intended only for the use of the individual or entity named above, and may be
privileged. If the reader of this message is not the intended recipient or the employee or agent responsible to deliver it to the intended recipient, you are hereby
notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please
immediately notify us by telephone (702-784-5200), and delete the original message. Thank you."
1
1
CSERV
2
DISTRICT COURT
3 CLARK COUNTY, NEVADA
4
6 Alfonso Noyola, Plaintiff(s) CASE NO: A-20-818973-C
7 vs. DEPT. NO. Department 24
8 The City of Boulder City,

Defendant(s)
9
10
11 AUTOMATED CERTIFICATE OF SERVICE
12 This automated certificate of service was generated by the Eighth Judicial District
Court. The foregoing Temporary Restraining Order was served via the court’s electronic
13 eFile system to all recipients registered for e-Service on the above entitled case as listed
below:
14
15 Service Date: 8/5/2020
16 Jessica Myrold [email protected]
17 Sheila Darling [email protected]

18
Jeffrey Barr [email protected]
19
LV Docketing [email protected]
20
Richard Gordon [email protected]
21
Bradley Austin [email protected]
22
23 Tiffany Kahler [email protected]
24
25
26
27
28

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Electronically Filed

10 DISTRICT COURT JUDGE

20 SNELL & WILMER L.L.P.

21 By: /s/Richard C. Gordon

From: Gordon, Richard <[email protected]>

Richard C. Gordon, Esq.

6 Alfonso Noyola, Plaintiff(s) CASE NO: A-20-818973-C

7 vs. DEPT. NO. Department 24

8 The City of Boulder City,

11 AUTOMATED CERTIFICATE OF SERVICE

15 Service Date: 8/5/2020

16 Jessica Myrold [email protected]

17 Sheila Darling [email protected]

23 Tiffany Kahler [email protected]

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