1 CODE: $1425

HAWAH S. AHMAD, ESQ.

2 Nevada State Bar No. 16374
3 AHMADLAW
300 S. Arlington Avenue, Ste B
4 Reno, Nevada 85901
Telephone: (775) 742-4927
5 [email protected]
Attorney for Michael Leonard
6

7 IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA

8 IN AND FOR THE COUNTY OF WASHOE

10
MICHAEL LEONARD,
11 an individual, Case No.
Plaintiff,
12 Dept No.
300 S. Arlington Avenue, Ste B

vs.
13
Reno, Nevada 85901
AHMADLAW

SARAH SMITH, an individual,

(775) 234-8760

14
ALEX VELTO, an individual, COMPLAINT
15 CONOR MCQUIVEY, an individual, JURY TRIAL DEMAND
RENOITES, a fictitious business entity, EXEMPT FROM ARBITRATION
16 DEVON REESE, an individual,
REESE, RING, VELTO PLLC, A Nevada
17 Domestic Professional Limited Liability
Corporation, Does I through X, inclusive,
18
Defendants.
19

20 Plaintiff, MICHAEL LEONARD, an individual, by and through his attorney of record,

21 HAWAH S. AHMAD, ESQ. of AHMADLAW, hereby files this Complaint against SARAH SMITH,
22
ALEX VELTO, CONOR MCQUIVEY, RENOITES, DEVON REESE, REESE, RING, VELTO,
23
PLLC, and Does I through X, and alleges as follows:
24
PARTIES
25

26 1. Plaintiff, MICHAEL LEONARD, is an individual who resides in Washoe County,

27 Nevada.

28

1
 1 2. Upon information and belief, Defendant, SARAH SMITH, is an individual who
2 resides at 2655 Powder Drive, Reno, Washoe County, Nevada, 89503.
3
3. Upon information and belief, Defendant, ALEX VELTO, is an individual and attorney
4
(NV Bar No. 14961) who resides at 2655 Powder Drive, Reno, Washoe County, Nevada, 89503. He
5
was, at all times relevant hereto, an agent, who owned and/or controlled REESE RING VELTO,
6

7 PLLC, DBA REESE RING VELTO.

8 4. Upon information and belief, Defendant, CONOR MCQUIVEY, is an individual who

9 resides at 1310 El Camino Circle, Reno, Washoe County, Nevada, 89509. He was, at all times
10
relevant hereto, an agent, owned and/or controlled RENOITES.
11
5. Upon information and belief, Defendant, RENOITES, a fictitious business entity that
12
300 S. Arlington Avenue, Ste B

is doing business in the State of Nevada, City of Reno. RENOITES’ podcast’s City of Reno business
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license is registered at 25 Keystone Avenue, 9, Reno, Nevada 89503.

(775) 234-8760

14

15 6. Upon information and belief, Defendant, DEVON REESE, is an individual attorney

16 (NV Bar No. 7496), and Reno City Council Member for Ward 5, who resides at 8865 Golfwood
17 Court, Reno, Washoe County, Nevada, 89523. He was, at all times relevant hereto, an agent, who
18
owned and/or controlled REESE RING VELTO, PLLC, DBA REESE RING VELTO.
19
7. Upon information and belief, Defendant, REESE RING VELTO, PLLC, DBA REESE
20
RING VELTO, is a Domestic Professional Limited Liability Company, organized and existing under,
21

22 and by virtue, of the laws of the State of Nevada, and registered and licensed to do business within

23 the State of Nevada and is registered at 200 South Virginia, Ste. 655, Reno, Washoe County, Nevada,

24 89501.
25 8. Plaintiff does not know the true names and capacities, whether a business entity,
26
governmental, or individual, of those Defendants sued herein as Does I-X, inclusive. Plaintiff prays
27
leave that when the true names and capacities of said Defendants are ascertained, he may be permitted
28

2
 1 to insert the same herein with appropriate allegations; but upon information and belief, Plaintiff
2 alleges that each of said Defendants is legally responsible for the events and happenings referred to
3
herein and proximately caused damages to Plaintiff, as alleged herein.
4
JURISDICTION AND VENUE
5
9. Jurisdiction and venue are properly in the Second Judicial District Court of the State
6

7 of Nevada, because all events set forth herein arose in Washoe County, Nevada.

8 FACTS

9 10. Plaintiff, MICHAEL LEONARD (hereinafter “Plaintiff”), brings this action to remedy
10
acts of civil tort perpetrated against him by REESE RING VELTO, PLLC (“hereinafter “Reese Ring
11
Velto”); Alex Velto, Owner of Reese Ring Velto (hereinafter “Mr. Velto”); and Devon Reese
12
300 S. Arlington Avenue, Ste B

(hereinafter “Mr. Reese”), Owner of Reese Ring Velto; Sarah Smith (hereinafter “Mrs. Smith”);
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Conor McQuivey (hereinafter “Mr. McQuivey”), and an individual and in his capacity as owner of
(775) 234-8760

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15 Renoites Podcast; and Renoites Podcast. Plaintiff contends that Mr. Velto and Mr. Reese in their

16 capacity as agents of Reese Ring Velto colluded with Mrs. Smith, Mr. McQuivey and Renoites
17 podcast and engaged in a series of unlawful actions and inappropriate communications that caused
18
Plaintiff to be threatened, harassed, humiliated, and fear for his safety. Defendants’ persistent actions,
19
including but not limited to defaming social media posts inciting others to act against Plaintiff and
20
harm his reputation have negatively impacted Plaintiff’s health, wellbeing and security. Even after
21

22 receiving an email to cease on desist from Plaintiff on March 14, 2025 and a follow-up “RE:

23 RESPONSE TO COMMUNICATION FROM ALEX VELTO, ESQ. ON MARCH 15, 2025, AND

24 CEASE AND DEMAND FOR DAMAGES AGAINST DEVON REESE, ALEX VELTO AND
25 CONOR MCQUIVEY” on March 21, 2025, Defendants continued to defame and harass Plaintiff on
26
social media and in person following the misrepresentation that the parties’ prior settlement
27
agreements were violated. Defendants did not appear to take any affirmative good faith efforts when
28

3
 1 entering the settlement agreements. Nor did Defendants make any good faith efforts to comply with
2 the demand to cease and desist their behavior. Further, Defendants have failed to follow the terms of
3
the settlement agreements, or to mitigate ongoing harassment and defamation of Plaintiff.
4
11. Unfortunately, even after entering into unenforceable stipulated settlement agreements
5
at Defendant, ALEX VELTO’s urging and paying out payments demanded by Defendants, SARAH
6

7 SMITH, ALEX VELTO, and CONOR MCQUIVEY, Defendants have not let Plaintiff live in peace.

8 Instead, Defendant, DEVON REESE, in his capacity as an agent of REESE RING VELTO personally

9 humiliated, harassed and threatened Plaintiff with a stay away order that does not exist, then took to
10
social media in his capacity as a Reno City Councilmember and Managing Member of REESE RING
11
VELTO PLLC to defame Plaintiff, incite other businesses and individuals to refuse Plaintiff service
12
300 S. Arlington Avenue, Ste B

and/or harass Plaintiff and any people who voiced their support for Plaintiff. There is no other purpose
13
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for these communications other than to defame and continue to harass Plaintiff to interfere with his
(775) 234-8760

14

15 retirement and quality of life.

16 12. Mr. Reese then enlisted Mr. McQuivey, Mr. Velto, and various other influential people
17 in Northern Nevada, now known as Does I through X, inclusive, to further defame and harass Plaintiff
18
online and in the Reno Gazette Journal.
19
GENERAL ALLEGATIONS
20
13. Plaintiff, MICHAEL LEONARD (hereinafter “Plaintiff”), is a resident of Washoe
21

22 County.

23 14. On or about November 20, 2023, Defendant, CONOR MCQUIVEY filed a police

24 report with Reno Police Department (OCA # 23-1111834), for what he deemed stalking and
25 harassment. Defendant, CONOR MCQUIVEY specifically named private investigator, Tom Green,
26
as the alleged perpetrator.
27

28

4
 1 15. Sometime after the filing of the police report, Defendant, CONOR MCQUIVEY
2 reached out to former bar owner, Matt Polley, to elucidate information regarding Plaintiff’s financial
3
status.
4
16. Shortly after speaking to Matt Polley, Defendant, CONOR MCQUIVEY met with and
5
or retained Defendants, ALEX VELTO and DEVON REESE and their law firm, REESE RING
6

7 VELTO, PLLC, and colluded with the parties to interview Matt Polley regarding Plaintiff.

8 17. On or about January 24, 2024, Defendant, CONOR MCQUIVEY, filed an Application

9 for Protective Order against Plaintiff in the Reno Justice Court (Case Number RCP2024-000067). An
10
Order Granting Protection Against Stalking was issued on January 30, 2024, and a Hearing was set
11
for March 18, 2024. The hearing was vacated as Defendant, CONOR MCQUIVEY failed to attend.
12
300 S. Arlington Avenue, Ste B

18. Defendant, CONOR MCQUIVEY then took to social media and his podcast,
13
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RENOITES, to disparage his alleged stalker, Reno Police Department for not pursuing charges, and
(775) 234-8760

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15 the Nevada Court System.

16 19. On or about February 22, 2024, Matt Polley informed Plaintiff of his conversations
17 with Defendants, CONOR MCQUIVEY and ALEX VELTO after Defendants learned of an incident
18
between Plaintiff and an employee of Whispering Vine.
19
20. On or about February 23, 2024, Plaintiff emailed Defendant, ALEX VELTO regarding
20
Defendants, CONOR MCQUIVEY and ALEX VELTO recent conversation with Matt Polley, and
21

22 the parties’ false allegations against Plaintiff. Plaintiff’s email effectively served as a cease-and-desist

23 letter.

24 21. Defendant, ALEX VELTO did not immediately respond to Plaintiff’s cease-and-desist
25 letter.
26
22. In or about March 2024, Defendant, ALEX VELTO reached out to Plaintiff’s friend,
27
Michael Creedy, an unrelated party found off of Plaintiff’s Facebook and left the following voicemail:
28

5
 1 Hi Mike. My name is Alex Velto. I'm an attorney at Reese Ring Velto.
I'm calling because of a case I have with Michael Leonard. Michael's
2 taking actions that are going to end up with him potentially facing
3 criminal penalties and in a lot of liability civilly, I'm hoping to have a
conversation with someone that can have a reasonable conversation
4 with him, because I fear the steps he is taking are going to cause him
serious harm. Give me a call when you have a chance. [Defendant
5 ALEX VELTO’S personal cell phone number] Thank you. Bye. Bye.
6

7 23. In or about March 2024 Defendant, ALEX VELTO reached out to Plaintiff’s brother,

8 Marc Leonard, an unrelated party found from Plaintiff’s Facebook, defamed Plaintiff and once again

9 threatened criminal penalties and civil liability.

10
24. At this time, Plaintiff’s only communication with Defendant, ALEX VELTO was the
11
February 2024 cease and desist e-mail.
12
300 S. Arlington Avenue, Ste B

25. Plaintiff never met, nor had any direct communication with Defendants, CONOR
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MCQUIVEY or DEVON REESE.

(775) 234-8760

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15 26. Defendant, ALEX VELTO’s pattern and course of conduct of harassing behavior

16 underscores the intentional and malicious nature of Mr. Velto’s actions toward Plaintiff.
17 27. On or about March 22, 2024, Defendant, ALEX VELTO responded to Plaintiff’s
18
February 23, 2024, email stating, “I would recommend you retain counsel. Your email makes clear
19
you are not interested in acknowledging any wrongdoing. We will be filing suit. Will you waive
20
service pursuant to NRCP 4.1?”
21

22 28. On or about March 29, 2024, Defendant, ALEX VELTO filed two lawsuits against

23 Plaintiff with him being attorney of record on both lawsuits. To wit, Defendant ALEX VELTO filed

24 CV24-00692 on behalf of Defendants, SARAH SMITH and ALEX VELTO on behalf of REESE
25 RING VELTO, PLLC, and CV24-00690 on behalf of Defendant, CONOR MCQUIVEY.
26
29. Defendant, ALEX VELTO filed an Emergency Ex Parte Request for Temporary
27
Restraining Order and Preliminary Injunction (NRCP 65 (A) and (B), on March 29, 2025, in CV24-
28

6
 1 000692. The Temporary restraining order was granted on April 1, 2024, and set for hearing on April
2 23, 2024, as to whether a preliminary injunction should be issued.
3
30. Defendant, ALEX VELTO filed a Notice of Proposed Exhibit[s] Submitted by
4
Plaintiff’s for Motion for Preliminary Injunction on April 23, 2024, on April 19, 2024, that did not
5
include a list of prospective witnesses that included Defendant, CONOR MCQUIVEY.
6

7 31. At the April 23, 2024, Defendant, DEVON REESE, represented Defendants, ALEX

8 VELTO and SARAH SMITH on behalf of REESE RING VELTO, PLLC.

9 32. At the April 23, 2024, Defendant, CONOR MCQUIVEY, though not noticed,
10
testified. The motion for preliminary injunction was granted with Defendant, DEVON REESE being
11
charged with drafting the order. The Order, once filed, included Findings of Fact not made on the
12
300 S. Arlington Avenue, Ste B

record and was not provided to Plaintiff for review pursuant to Second Judicial District Court Rule
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9.
(775) 234-8760

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15 33. Plaintiff entered into a Settlement Agreement and Mutual Release of Claims with

16 Defendants, ALEX VELTO and SARAH SMITH on May 15, 2024, in which Defendant, ALEX
17 VELTO, as attorney of record, included the Findings of Fact, Conclusions of Law and Judgment filed
18
on May 13, 2024, in CV24-00692 as terms.
19
34. Defendant, CONOR MCQUIVEY and Plaintiff entered into an almost identical
20
settlement agreement on June 11, 2024.
21

22 35. Both settlement agreements included one-way clauses for stipulated damages without

23 an enforcement mechanism and agreed to a dismissal and mutual release of all respective complaints

24 and counter/cross claims, with prejudice in CV24-00692 and CV24-00690, respectively. Notably, the
25 identical agreements state, “[t]he parties agree to a mutual release and waiver of any and all known
26
claims against each other arising out of or related to the matters set forth in the Complaint and
27
counterclaims.”
28

7
 1 36. Based upon the record, Plaintiff was not given an opportunity to review the language
2 of the settlement agreements or stipulation to dismiss the cases with an attorney before being required
3
to sign such documentation.
4
37. Notably, Defendant ALEX VELTO, by and through his law firm, REESE RING
5
VELTO PLLC, included a waiver of attorney review for Plaintiff in the Settlement Agreement.
6

7 38. On or about May 23, 2024, Defendants, ALEX VELTO and SARAH SMITH and

8 Plaintiff entered into a Stipulation to Dismiss Case with Prejudice. The Court granted the dismissal

9 on May 29, 2024, in CV24-00692.

10
39. On or about June 21, 2024, Defendant, CONOR MCQUIVEY, by and through his
11
attorney of record, Defendant, ALEX VELTO, and Plaintiff entered into a Stipulation to Dismiss
12
300 S. Arlington Avenue, Ste B

Case with Prejudice. The Court granted the dismissal on June 24, 2024, in CV24-00690.
13
Reno, Nevada 85901
AHMADLAW

40. On or about March 14, 2025, Plaintiff, a frequent customer of Belleville Wine Bar,
(775) 234-8760

14

15 arrived at the bar at or about 7:00 p.m. for a glass of wine. The bar in question was at capacity.

16 41. Belleville Wine Bar is located at 400 W. 5th Street, #101, Reno, NV 89503.
17 42. As a frequent and well-known customer, Plaintiff was given a glass of wine and seated
18
by the entrance until a spot opened at the bar.
19
43. Plaintiff was soon after seated at the bar, near other well-known regulars.
20
44. Plaintiff did not search out the bar to determine who was and was not there.
21

22 45. Plaintiff did not see Defendant, DEVON REESE, in the bar.

23 46. At some point Defendant, DEVON REESE appeared at Belleville Wine Bar for

24 matters related to his employment at REESE RING VELTO PLLC.

25 47. While Plaintiff was minding his own business, Defendant, DEVON REESE,
26
menacingly approached Plaintiff’s bar stool from behind and began berating Plaintiff for being in the
27

28

8
 1 bar in violation of a protective order. Defendant DEVON REESE threatened to call law enforcement
2 if Plaintiff did not vacate the bar within five minutes.
3
48. Plaintiff calmly responded that the parties do not have a protective order in place that
4
serves as a stay away order and commented on his behavior being unbecoming of Reno City
5
Councilmember. Plaintiff went on to explain the contents of the Stipulated Agreement entered with
6

7 Defendant, ALEX VELTO as attorney.

8 49. Defendant, DEVON REESE, then stormed out of the bar to make a phone call.

9 50. Based upon Defendant, DEVON REESE’s behavior, Plaintiff believed that law
10
enforcement was being called and felt his immediate safety was put at risk.
11
51. After the altercation, Plaintiff left his drink unfinished and left the bar out of fear for
12
300 S. Arlington Avenue, Ste B

his safety and embarrassment from Defendant, DEVON REESE’s behavior.

13
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52. Defendant DEVON REESE’s pattern and course of conduct of threatening and
(775) 234-8760

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15 harassing behavior underscores the intentional and malicious nature of Defendant DEVON REESE’s

16 actions toward Plaintiff.

17 53. Plaintiff promptly emailed Defendant ALEX VELTO as soon as he left Belleville
18
Wine Bar, stating:
19
Alex,
20 I was just at the Belleville Wine bar sitting at the bar with my back to
the tables and Devon Reese came up to me and said that I was in
21 violation of a protective order and told me to leave or else he would
22 call the police. He got aggressive with me in front of a crowed bar
including people who know me and said leave in 5 minutes. Then he
23 went outside and started calling someone. I presume that he called you
as the police said that they didn't have a call for service. I paid and left
24 within 1-2 minutes. I was there first. I did not confront Devon. I had
my back to him and I didn't know that he would be there. This is a
25 regular place for me and the owner and bartender know me well and
26 know what I was there first and didn't confront Devon and they will
vouch for me. I presume that Devon will try to get you to file a civil
27 complaint against me and I'm just letting you know that I did not violate
our agreement and I will not agree to any payment for this incident.
28

9
 1 Furthermore I do not appreciate Devon getting rude with me in front of
people and I will make a public issue of it if it goes further.
2 Michael
3
54. Plaintiff was so uncomfortable by Defendant DEVON REESE’s actions that he filed
4
a police report with law enforcement following the event. A true and correct copy of the police report
5
(Report Number: 250102513).
6

7 55. Despite Plaintiff’s email being directly in line with the Stipulated Agreement,

8 Defendant ALEX VELTO, responded the following day as follows:

9 Mr. Leonard,
I am disappointed to hear from you. The tone and tenor of your email
10
suggests both that you are back to your old tricks and that your distorted
11 view of reality continues to be of grave concern. I am once again
reminded of the danger you pose to our me, my wife, my law partner,
12 our friends and our community. Your email of March 14, 2025,
300 S. Arlington Avenue, Ste B

misrepresents both the facts and your obligations. The email itself, is a
13 breach of the agreement. Let me be clear: you are in violation of our
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agreement and will be held accountable for your continued harassment.

(775) 234-8760

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15 Mr. Reese and his friends were at the Belleville Wine bar on Friday,
March 14, 2025 one hour before you arrived. Your arrival coincided
16 with the arrival of one of Mr. Reese’s late arriving guests who Mr.
Reese later learned you have been stalking. We have photos of your
17 arrival at approximately 6:30pm as you sat at the only available seat
near the door. Your claim that you did not violate the agreement is
18
false.
19
Regardless of your explanation, your presence at Belleville Wine Bar
20 in proximity to Devon Reese constitutes a direct breach. Further, this
very email is breach of agreement. You are prohibited from contacting
21 me or there is a $35,000 stipulated damages amount. There is no
22 allowance for you to contact me outside of litigation.

23 Further, your assertion that you “did not confront Devon” is irrelevant
and untrue, the agreement does not require a confrontation—only that
24 you avoid situations where such encounters could occur. Mr. Reese
was alerted to your presence only when the woman you have been
25 stalking alerted him that you had arrived after she did. Moreover, Mr.
26 Reese’s back was to you and he did not speak with you until he politely
asked you to leave the bar. You refused and became belligerent to Mr.
27 Reese who calmly informed you that you were in violation of the
subject Agreement. You told him “I am going to get you…The FBI is
28 investigating you… I will support your opponent financially, I will not

10
 1 leave.” Mr. Reese then excused himself to alert police to your
unhinged and stalker behavior. You subsequently left the bar. There
2 are 5-10 witnesses to your behavior and your brand of crazy. We are
3 also acquiring by the video camera footage from the bar that will show
you arrived after Mr. Reese.
4
Your attempt to shift blame by alleging that Devon was “rude” or
5 “aggressive” is also irrelevant. What matters is your failure to abide by
your obligations. Additionally, your statement that you will “make a
6
public issue of it” if this matter proceeds further is noted, but any such
7 actions on your part will not change your breach nor absolve you of
your responsibilities. You have a pattern of trying to shift blame to
8 your victims which will not be tolerated.

9 Accordingly, I demand payment of $35,000 no later than Friday,

March 21, 2025. If payment is not received in full by this deadline, we
10
will have no choice but to file suit—for your breach of the settlement
11 agreement by contacting both Devon and me—to recover the full
amount owed, along with any additional damages and legal costs
12 associated with enforcing the agreement.
300 S. Arlington Avenue, Ste B

13 This is your final opportunity to resolve this matter without litigation.

Reno, Nevada 85901
AHMADLAW

If you have any questions, you may direct them to me, but absent full
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payment by the deadline, we will proceed accordingly.
15
Thank you,
16 Alex
17 56. On or about March 15, 2025, Our Town Reno, a local blog, obtained a copy of
18
Plaintiff’s police report and shared it on their platform.
19
57. The story was later shared by This is Reno, a local Reno publication.
20
58. On or about March 16, 2025, Defendant, CONOR MCQUIVEY, took to social media
21

22 and despite not being present, posted the following:

23 Edit: in light of today’s detailed reporting by This is Reno, I am making

this post public and turning off comments for the safety of myself and
24 friends.
I have some info to share to my friends ahead of some news reporting
25 coming this week. I’ll likely post and explain more later but for now:
26 A bit over a year ago, a deranged local man named Michael Leonard
stalked, harassed, and threatened me. I won’t go into any details right
27 now for my own protection, but I will say that he is a dangerous serial
stalker with MANY local victims dating back several years, often
28 young women. Some of you may remember previous posts about it that

11
 1 didn’t mention him by name. I have never met him or seen him out of
court and my being targeted felt (and still feels) profoundly confusing
2 and terrifying.
3 I gathered tons of evidence but RPD failed to arrest and charge him,
which is a genuine scandal if you ask me. His actions are clearly and
4 undeniably criminal (NRS 200.571)
I sued him and settled out of court last summer. During this process he
5 was also found liable in district court for “extreme and outrageous”
infliction of emotional distress that was “intentional and malicious”
6
and a “clear and present danger to [another victim]’s safety”
7 My lawyer was Alex Velto, who is law partners with Devon Reese.
Devon didn’t represent me, but did represent a different victim of
8 Michael’s (I told you, there are many).
I didn’t choose to pursue any public reporting about this incident
9 because I truly hoped that by finally receiving a consequence for his
actions, Michael would stop and change his ways. My settlement
10
agreement prohibits him from contacting me, and the injunction signed
11 by the district court judge mentioned above permanently prohibits him
from contacting me, Alex, Devon, and anyone who works at their firm.
12 He did not stop. He has apparently moved on to new victims. This
300 S. Arlington Avenue, Ste B

weekend he filed a police report claiming Devon threatened and

13 defamed him at a local wine bar. Without fail, Michael has attempted
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to garner sympathy and deflect from his own actions by presenting

(775) 234-8760

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himself as a victim. He uses the exact same DARVO tactic, time and
15 again. This is all documented clearly within dozens of pages of
evidence, much of it filed with the court already and more in my
16 personal records.
The other tactic he uses is trying to get others to disseminate his lies
17 and false accusations for him. I strongly suspect one reason he
originally targeted me is that he emailed me (August 2023) trying to
18
get me to report negatively on a wine bar he held a vendetta against
19 (they were another victim of his stalking- multiple protective orders
and all. I have video of him throwing a wine bottle towards employees.
20 Again, it is a scandal that he was not jailed for it).
I ignored his email and suspect he felt slighted and held some sort of
21 grudge against me for it. He started his stalking campaign against me
22 shortly after. It sounds crazy because it is. This man is genuinely
deranged and a danger to our community.
23 The police report from this weekend was posted on local news social
media channels without any context, and just as Michael intended,
24 some in the comments are credulously believing his story. I was not at
that wine bar, but I need to make it abundantly clear before anyone
25 believes a word of what he wrote about Devon in that report, this man
26 is absolutely deranged and his police report fits his standard MO to a
T. Not a single word should be trusted. Thank God he is actually bad
27 at all of this and his lies and tactics are so blatantly transparent.
While it may be tempting to share or believe salacious news (like police
28 reports about elected officials), I hope our local journalists don’t make

12
 1 themselves tools of this deranged vile criminal, wittingly or otherwise.
I also ask the same of my friends. Thanks for your support in what has
2 been a very difficult time (and I imagine will now be difficult all over
3 again in a whole new way. Great.)
I will not hesitate to sue him again if appropriate. I had really hoped
4 that he would quit this deranged criminal behavior on his own but don’t
believe he will stop unless arrested and jailed. None of us are safe from
5 him.
6

7 59. On or about March 17, 2025, Defendant DEVON REESE, shared Defendant, CONOR

8 MCQUIVEY’s social media post with the following language:

9 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,
10
and friends have been harassed, stalked, and victimized by Michael
11 Leonard. Lots of factual details in the This is Reno story today - I’m
posting the pics of the article for ease.
12 Our Town Reno/Biggest Little Streets (Nico Colombant), Picon
300 S. Arlington Avenue, Ste B

Press (Candy Green), and others continually try to spin a false narrative
13 about me using the term “news.” This Is Reno is usually in that camp,
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though today’s coverage is actually refreshingly fair (minus the

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headline, which is in itself ugly to have the accusation in the headline
15 and the truth behind the paywall). If you want further context on who
the individual is whose lies they are printing to smear me, read Conor’s
16 post.
And while I very much value local and independent journalism
17 - please consider the source. What is their bias? What is the objective?
Why do they chose the headlines they choose? What is motivating them
18
to cover the stories they cover? Why do they obsess about one elected
19 and fawn over others?
Read and consume news from lots of different sources but just
20 know that there is always more to the story. And if you have any
questions for me, just ask; if there is one lesson I learned the hard way
21 from Emily, it’s that you have to live your life out loud and in public.
22

23 60. Defendant, ALEX VELTO, then took to social media to attack Our Town Reno and

24 further commented, “Our Town Reno that’s an excuse. There are public records on Michael
25 Leonard’s conduct: he harasses, he stalks, he lies. All of this is in the public record.”
26
61. Defendant, SARAH SMITH condoned all actions by Defendants ALEX VELTO,
27
DEVON REESE, REESE RING VELTO, PLLC, and CONOR MCQUIVEY.
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 1 62. A cease-and-desist letter entitled, was delivered to the City of Reno, City Attorney,
2 Karl Hall on March 20, 2025.
3
63. City of Reno City Attorney, Karl Hall, responded on March 21, 2025, stating, “This
4
matter has nothing to do with the City of Reno.”
5
64. On or about March 21, 2025, Plaintiff provided Defendants, ALEX VELTO, DEVON
6

7 REESE, and CONOR MCQUIVEY, with a cease-and-desist letter demanding the following:

8 1. Remove all public, inflammatory and incorrect statements to

people/entities in person and/or online intended solely to malign Mr.
9 Leonard’s character;
2. Cease making public, inflammatory and incorrect statements to
10
people/entities in person and/or online intended solely to malign Mr.
11 Leonard’s character;
3. Issue a formal public apology to Mr. Leonard on all personal
12 social media pages and to the media;
300 S. Arlington Avenue, Ste B

4. Cease any contact with Mr. Leonard for the next two (2) years
13 and abstain from approaching him in public absent a actual and
Reno, Nevada 85901
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legitimate safety issue, e.g. if a building you are both in is on fire and
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one of you needs help exiting the building; and
15 5. Cease making disparaging and false comments to any third
person or online.
16 6. In addition to the above actions, Mr. Leonard hereby demands
Mr. McQuivey pay him $30,000.00 for his bad faith actions.
17

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65. On or about Saturday, March 22, 2025, Defendant, ALEX VELTO, responded stating
19
that, “I write in my capacity as an attorney for Mr. McQuivey to confirm receipt. In the interim, I’ve
20
be authorized to waive service of behalf of Mr. McQuivey under NRCP 4.1 when you file suit. My
21

22 lawyer will be responding separately.”

23 66. To date, counsel for Defendants, ALEX VELTO, CONOR MCQUIVEY,

24 RENOITES, DEVON REESE, REESE, RING, VELTO, PLLC, have not responded to the cease-and-
25 desist letter.
26
67. To date, Defendants have kept all posts defaming and disparaging Plaintiff on social
27
media and have continued to disparage and defame Plaintiff to members of the public.
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 1 68. To date, Defendants have instigated members of the public, including Elliot Malin,
2 Abbi Holtom Whitaker of the Abbi Agency, and others to attack Plaintiff and Our Town Reno for
3
publishing the police report, on social media and in other publications.
4
FIRST CLAIM FOR RELIEF
5 (Harassment)
Against Devon Reese
6

7 69. Plaintiff realleges and incorporates all prior allegations as if fully set forth herein.

8 70. Under NRS 200.571(1)(D), a person is guilty of harassment if the person to do any act

9 which is intended to substantially harm the person threatened or any other person with respect to his
10
or her physical or mental health or safety; by words or conduct that places the person receiving the
11
threat in reasonable fear that the threat will be carried out.
12
300 S. Arlington Avenue, Ste B

71. On or about March 14, 2025, Defendant, DEVON REESE, and two affiliates,
13
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AHMADLAW

menacingly approached Plaintiff while at Belleville Wine Bar, and demanded that Plaintiff leave the
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15 bar for being in violation of an alleged protective order.

16 72. A protective order does not in fact exist in the parties’ Stipulated Agreement.
17 73. Defendant, DEVON REESE aggressively and threateningly got into Plaintiff’s face
18
and repeatedly told him to leave within five (5) minutes, or he would call the police. Defendant
19
DEVON REESE and his associates stood menacingly on either side of Plaintiff to threaten Plaintiff
20
and prevent him from getting off the bar stool.
21

22 74. Defendant, DEVON REESE previously entered into a deferral agreement with the

23 Nevada Ethics Commission over his relationship with several employee union groups, inclusive of

24 the Reno Protective Police Association.

25 75. On or about September 2024, a Nevada Commission on Ethics Review Panel found
26
credible evidence to support a determination that just and sufficient cause exists regarding the
27
violations of NRS 281A.400(2) and NRS 281A.400(9) against, Defendant, DEVON REESE.
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 1 76. Based upon Defendant, DEVON REESE’s allegations of ethics violations, and
2 purported relationship with the Reno Protective Police Association, Plaintiff had a reasonable fear
3
that the threat of an arrest and possible jail time would be carried out, despite there being an absence
4
of a stay-away order between Defendant, DEVON REESE and Plaintiff.
5
77. The continued harassment has forced Plaintiff to retain counsel and Plaintiff as such
6

7 has been damaged in an amount in excess of Fifteen Thousand Dollars ($15,000.00).

8 78. Plaintiff seeks injunctive relief preventing Defendant from further harassing Plaintiff

9 to leave places of business in Reno.

10
79. The conduct of Defendant, DEVON REESE alleged herein was intentional,
11
oppressive, malicious and in conscious disregard for Plaintiff’s rights, justifying an award of
12
300 S. Arlington Avenue, Ste B

exemplary damages in an amount according to proof at trial.

13
Reno, Nevada 85901
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SECOND CLAIM FOR RELIEF

(775) 234-8760

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(Stalking)
15 Against Devon Reese, Conor McQuivey, and Alex Velto

16 80. Plaintiff realleges and incorporates all prior allegations as if fully set forth herein.
17 81. Under NRS 200.575, a person who, without lawful authority, willfully or maliciously
18
engages in a course of conduct directed towards a victim that would cause a reasonable person under
19
similar circumstances to feel terrorized, frightened, intimidated, harassed or fearful for his or her
20
immediate safety or the immediate safety of a family or household member, and that actually causes
21

22 the victim to feel terrorized, frightened, intimidated, harassed or fearful for his or her immediate

23 safety or the immediate safety of a family or household member, commits the crime of stalking.

24 82. To wit, on or about March 14, 2025 onwards, Defendants, DEVON REESE, ALEX
25 VELTO, SARAH SMITH, CONOR MCQUIVEY and RENOITES podcast, engaged in a course of
26
conduct directed towards Plaintiff that made him feel terrorized, frightened, intimidated, harassed or
27
fearful for his or her immediate safety by excessively posting and inciting others to post, comment,
28

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 1 and write opinion editorial articles demeaning Plaintiff for the March 14, 2025 incident in which
2 Defendant DEVON REESE harassed Plaintiff and any editorials/blogs/or people supportive of
3
Plaintiff.
4
83. To wit, Defendants’ actions resulted in other parties like Gordon Gossage also
5
harassing and stalking Plaintiff by commenting:
6

7 Every community has extremely deranged individuals who threaten

neighbors. Michael Leonard is one. There must be zero tolerance for
8 them. They must be contained legally. Their behavior must not be
condoned or supported. Most importantly, they must be sanctioned by
9 the community, until and unless, they cease their behavior. Michael
Leonard’s threats against his targets, their spouses, and their kids is not
10
in a grey area. He must be stopped by the full weight of Our
11 Community.

12 84. Defendant DEVON REESE endorsed Mr. Gordon Gossage’s misinformed and
300 S. Arlington Avenue, Ste B

13 inaccurate post in an attempt to further stalk and harass Plaintiff.

Reno, Nevada 85901
AHMADLAW

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85. To wit, Defendants’ actions resulted in other parties like Elliot Malin also inciting
15
mistrust towards Plaintiff by publishing an Opinion Editorial Article in which he claimed that Our
16
Town Reno’s publication of Plaintiff’s Police Report only told one side of the story. Defendant
17
DEVON REESE endorsed the April 30, 2025 Opinion Editorial Our town, Reno, deserves better.
18

19 86. To wit, Defendants’ actions resulted in other parties like Colin Smith of Roundabout

20 Catering also harassing Plaintiff by posting on March 14, 2025:

21 Devon was busy that night helping me and a fellow restauranter out of
22 a situation. He was working even during his down time. These
knuckleheads that waste the time of hard working productive people
23 are the problem with todays environment. I wish for the days when
someone could just pull him out of the bar and whoop his ass.
24
87. The above examples are only a few of many in which Defendants CONOR
25

26 MCQUIVEY, DEVON REESE, and ALEX VELTO, utilized their platforms as public officials to

27 further incite their social media followers to mistrust, defame, insult, and otherwise harass, stalk, and

28 threaten harm against Plaintiff.

17
 1 88. Based upon Defendants’ actions, Plaintiff has been terrorized, frightened, intimidated,
2 harassed or fearful for his or her immediate safety.
3
89. The continued stalking has forced Plaintiff to retain counsel and as such Plaintiff has
4
been damaged in an amount in excess of Fifteen Thousand Dollars ($15,000.00).
5
90. Plaintiff seeks injunctive relief to prevent Defendants from further stalking Plaintiff.
6

7 91. The conduct of Defendants alleged herein was intentional, oppressive, malicious and

8 in conscious disregard for Plaintiff’s rights, justifying an award of exemplary damages in an amount

9 according to proof at trial.

10
THIRD CLAIM FOR RELIEF
11 (Defamation Per Se)
Against Devon Reese and Conor McQuivey
12
300 S. Arlington Avenue, Ste B

92. Plaintiff realleges and incorporates all prior allegations as if fully set forth herein.
13
Reno, Nevada 85901
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93. Plaintiff is a retired Product Marketing Specialist, who moved to Nevada in 2019 to
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14

15 live out his retirement in Northern Nevada.

16 94. Defendants knowingly made false accusations against Plaintiff.

17 95. Defendant CONOR MCQUIVEY recklessly and falsely represented that Plaintiff is a
18
“deranged” “serial stalker with MANY local victims dating back several years” and that Plaintiff
19
“stalked, harassed, and threatened” him. Defendant, CONOR MCQUIVEY has personal knowledge
20
that Plaintiff was not deranged, or a serial stalker with “many” victims dating back several years.
21

22 Defendant effectively alleged Plaintiff committed a crime.

23 96. Defendant CONOR MCQUIVEY recklessly and falsely committed perjury in the May

24 7, 2024, hearing on the Motion for Preliminary Injunction in CV24-00692, by testifying that This
25 comes after defendants falsely claimed in Court that a Reno Police Department Deputy confirmed
26
that his stalker was Plaintiff, while neither the email nor Seeking.com account in question in CV24-
27
00690 was never verified. Based upon Defendant CONOR MCQUIVEY’s false testimony,
28

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 1 Defendant, CONOR MCQUIVEY continued to falsely represent in writing on social media that
2 Plaintiff is untrustworthy and deranged.
3
97. Defendant, CONOR MCQUIVEY published his false statements about Plaintiff on
4
his Facebook account and over his podcast, RENOITES.
5
98. Defendant, DEVON REESE falsely claimed on social media that, “clients, and friends
6

7 have been harassed, stalked, and victimized by Michael Leonard” and falsely claimed that Our Town

8 Reno expressed a false narrative by posting Plaintiff’s police report. Defendant, a learned attorney,

9 knew his statements to be false based upon his presence at the May 7, 2024 hearing in CV24-00692.
10
99. Defendants negligently made statements to harm Plaintiff’s relationships, standing in
11
the community and subject Plaintiff to public ridicule.
12
300 S. Arlington Avenue, Ste B

100. Defendants’ statements have resulted in a loss of business income, loss of salary, loss
13
Reno, Nevada 85901
AHMADLAW

of business opportunities to Plaintiff’s status as an independent contract and resulted in costs to

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15 restore Plaintiff’s reputation in the community in an amount in excess of Fifteen Thousand Dollars

16 ($15,000.00).
17 FOURTH CLAIM FOR RELIEF
(Fraudulent Misrepresentation)
18
Against Alex Velto and Reese Ring Velto PLLC
19
101. Plaintiff realleges and incorporates all prior allegations as if fully set forth herein.
20
102. Defendants by and through attorney, Defendant, ALEX VELTO, Esq., falsely
21

22 represented that the stipulated settlement agreements, inclusive of the one-way clauses for stipulated

23 damages without an enforcement mechanism would serve as a mutual release of all respective

24 complaints and counter/cross claims, with prejudice in CV24-00692 and CV24-00690, respectively.
25 103. Defendant ALEX VELTO, in his position as a party opponent and counsel
26
representing REESE RING VELTO PLLC, drafted a stipulated agreement in which:
27
No Contact Provision: Defendant Leonard agrees not to contact,
28 directly or indirectly:

19
 1 …Alex Velto or his family,
Any owner or employee of Reese Ring Velto, PLLC
2

3 104. Defendant ALEX VELTO, in his position as a party opponent and co-owner of REESE

4 RING VELTO PLLC, included an exception to the no contact order in which:

5 The sole exception to this no contact provision is that the Parties agree
that Defendant Leonard may contact Plaintiff Alex Velto about the
6
pending lawsuit involving Conor McQuivey or other litigation in
7 which Michael Leonard is a party or Alex Velto is an attorney.

8 105. Defendant ALEX VELTO, in his position as a party opponent and counsel

9 representing REESE RING VELTO PLLC, also included the following stipulated damages clause:
10
Defendant Leonard further agrees that any violation of this no contact
11 provision shall be considered a material breach of this Agreement and
entitle Plaintiffs to recover a the amount of $35,000. The Parties agree
12 that it is difficult to determine the monetary value of a breach of the No
300 S. Arlington Avenue, Ste B

Contact provision, so $35,000 Is fair compensation in the event

13 Defendant breaches the agreement. Further, in the event of a breach of
Reno, Nevada 85901
AHMADLAW

the No Contact provision by Defendant Leonard, Plaintiffs shall also

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14
be entitled their reasonable attorneys fees and costs in seeking recovery
15 under this section of the Agreement. Plaintiffs shall also be able to
recover monetary damages for any additional emotional or physical
16 harm caused by Defendant Leonard's violation of this provision.
17 106. Defendants ALEX VELTO, DEVON REESE, and REESE RING VELTO, PLLC,
18
entered into this agreement knowing that it would not be followed.
19
107. Instead, on March 15, 2025, after Plaintiff reached out Defendant ALEX VELTO in
20
his capacity as an attorney in the two 2024 civil cases, Defendant ALEX VELTO told Plaintiff that
21

22 “Let me be clear: you are in violation of our agreement and will be held accountable for your

23 continued harassment.”

24 108. Defendant ALEX VELTO then informed Plaintiff in the same communication,
25 “Regardless of your explanation, your presence at Belleville Wine Bar in proximity to Defendant,
26
DEVON REESE constitutes a direct breach. Further, this very email is breach of agreement. You are
27

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 1 prohibited from contacting me or there is a $35,000 stipulated damages amount. There is no
2 allowance for you to contact me outside of litigation.”
3
109. Defendant ALEX VELTO knew with belief and full knowledge that his statement was
4
a misrepresentation regarding the existing past fact, in this case the parties’ agreement.
5
110. Defendant ALEX VELTO made misrepresentation to compel Plaintiff to pay him an
6

7 additional $35,000.00 in fear of further litigation.

8 111. As Defendant ALEX VELTO wrote the stipulated agreement and is a practiced

9 professional and co-owner of REESE RING VELTO, PLLC, Plaintiff justifiably relied upon
10
Defendant ALEX VELTO’s statements.
11
112. Plaintiff suffered damages in the form of emotional distress, loss of sleep, loss of
12
300 S. Arlington Avenue, Ste B

appetite, significant anxiety, and fear of his person based upon Defendant ALEX VELTO’s
13
Reno, Nevada 85901
AHMADLAW

misrepresentation.
(775) 234-8760

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15 113. Based upon Defendant ALEX VELTO’s misrepresentation has forced Plaintiff to

16 retain counsel and Plaintiff as such has been damaged in an amount in excess of Fifteen Thousand
17 Dollars ($15,000.00).
18
114. Defendant ALEX VELTO and REESE RING VELTO, PLLC, recklessly made the
19
false representation to gain a financial benefit from Plaintiff and to intentionally inflict further
20
emotional distress on Plaintiff.
21

22 FIFTH CLAIM FOR RELIEF

(Intentional Infliction of Emotional Distress)
23 Against all Defendants

24 115. Plaintiff realleges and incorporates all prior allegations as if fully set forth herein.
25 116. Defendants’ actions were intended or reasonably believed to result in infliction of
26
emotion distress.
27

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 1 117. Defendants’ actions complained of herein were severe and extreme resulting in
2 Plaintiff suffering from emotional distress as a result of the conduct.
3
118. Defendants recklessly and/or knowingly caused Plaintiff emotional distress in such a
4
manner to constitute malice or oppression with conscious disregard for the rights and safety of
5
Plaintiff, thereby entitling him to punitive damages.
6

7 119. As a direct and proximate result of the conduct, Plaintiff has been required to obtain

8 the services of an attorney, incurred costs, and is entitled to recovery prejudgment interest.

9 120. As a further direct and proximate result of Defendants’ conduct, Plaintiff has past and
10
future special damages; past and future general damages, suffered physical, mental, and emotional
11
distress, aggravation, and worry, and will suffer future damages, all to his substantial and additional
12
300 S. Arlington Avenue, Ste B

damages in excess of Fifteen Thousand Dollars ($15,000.00).

13
Reno, Nevada 85901
AHMADLAW

SIXTH CLAIM FOR RELIEF

(775) 234-8760

14
(Elder Abuse)
15 Against all Defendants

16 121. Plaintiff realleges and incorporates all prior allegations as if fully set forth herein.
17 122. Plaintiff is over the age of sixty (60) years of age, and retired.
18
123. Defendants were put on notice of Plaintiff’s age, retirement status, and status as a pre-
19
diabetic on or about May 9, 2024.
20
124. Defendants have willfully inflicted emotional distress on Plaintiff by harassing,
21

22 stalking, and fraudulently misrepresenting amounts owed to them by Plaintiff for stipulated damages.

23 125. Defendants’ conduct intended to deprive Plaintiff of his retirement income for food,

24 shelter, and medication under threat of continued and future litigation, and threats of obtaining
25 Plaintiff’s assets to deprive him of his home.
26
126. Defendants have fraudulently misrepresented significant settlement terms in an
27
attempt to coerce Plaintiff to pay Defendants additional income, threatened further litigation if
28

22
 1 additional stipulated damages are not paid, and harassed, stalked, and defamed Plaintiff and incited
2 others to harass, stalk and defame Plaintiff to prevent him from quiet enjoyment of his life.
3
127. Defendants have and continue to attempt to financially exploit, mentally abuse, and
4
isolate Plaintiff from the community resulting in significant emotional distress, fear of bodily harm,
5
and loss of retirement income.
6

7 128. Plaintiff was forced to retain counsel to protect his retirement interests under the threat

8 of further litigation and other retaliatory action, after Plaintiff reached out to Defendant ALEX

9 VELTO in his capacity as an attorney on CV24-0062 and CV24-0060.

10
129. As a further direct and proximate result of Defendants’ conduct, Plaintiff has past and
11
future special damages; past and future general damages, suffered physical, mental, and emotional
12
300 S. Arlington Avenue, Ste B

distress, aggravation, and worry, and will suffer future damages, all to his substantial and additional
13
Reno, Nevada 85901
AHMADLAW

damages in excess of Fifteen Thousand Dollars ($15,000.00).

(775) 234-8760

14

15 130. The conduct of Defendants alleged herein was intentional, oppressive, malicious and

16 in conscious disregard for Plaintiff’s rights, justifying an award of exemplary damages in an amount
17 according to proof at trial.
18
WHEREFORE, Plaintiff prays for judgment against Defendants as follows:
19
1. Awarding Plaintiff all available compensatory damages for the cause of action,
20
including but not limited to past and future medical expenses; past and future lost wages and loss of
21

22 earning capacity; past and future emotional distress; consequential and/or special damages; and all

23 available noneconomic damages, including but not limited to pain, suffering, loss of consortium, and

24 loss of enjoyment of life;

25 2. Disgorgement of profits and/or restitution;
26
3. Punitive damages, attorneys’ fees and expenses;
27
4. The costs of this action;
28

23
 1 5. Pre- and post-judgment interest; and,
2 6. For such other and further relief as the Court deems just and proper in the
3
circumstances.
4
AFFIRMATION
5
Affirmation pursuant to NRS 239B.030, the undersigned declares that this document does not
6

7 contain the personal information of any person as defined by NRS 603A.040.

8 Dated this 4th day of June 2025.

AHMADLAW
9

10
//s// Hawah S. Ahmad _
11 HAWAH S. AHMAD, ESQ.
300 S. Arlington Avenue, Ste. B
12 Reno, NV 89501
300 S. Arlington Avenue, Ste B

(775) 234-8760
13 [email protected]
Reno, Nevada 85901
AHMADLAW

Attorney for Plaintiff

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