Electronically Filed

12/6/2023 3:19 PM
Steven D.Grierson
CLERK OF THE COURT
1 COMP
ANTHONY P. SGRO, ESQ.
2 Nevada Bar No. 3811
ALANNA C. BONDY, ESQ.
3
Nevada Bar No. 14830
4 SGRO & ROGER CASE NO:A-23-882960-C
2901 El Camino Avenue, Suite 204 Department 27
5 Las Vegas, Nevada 89102
Telephone: (702) 384-9800
6 Facsimile: (702) 665-4120
tsgro@sgroandroger.com
7
abondy@sgroandroger.com
8 Attorneys for Plaintiffs

9
DISTRICT COURT
10
CLARK COUNTY, NEVADA
11
12 KEVIN LAPEER and LAUREN LAPEER, Case No.:
13 Plaintiffs, Dept. No.:
14 vs. COMPLAINT
15 CITY OF HENDERSON, HENDERSON
POLICE DEPARTMENT, HECTOR VILLA,
16 THEDRICK ANDRES, ANTHONY
BRANCHINI, DOE DEFENDANTS 1 through
17 20, and ROE DEFENDANTS 1 through 10,
18 Defendants.
19
20 Plaintiffs, KEVIN LAPEER and LAUREN LAPEER, by and through their attorneys,
21 SGRO & ROGER, ATTORNEYS AT LAW, complain and allege against Defendants CITY OF
22 HENDERSON, HENDERSON POLICE DEPARTMENT, HECTOR VILLA, THEDRICK
23 ANDRES, and ANTHONY BRANCHINI as follows:
24 JURISDICTION AND VENUE
25 1. This Court has subject matter jurisdiction over this matter pursuant to Article 6,
26 Section 6 of the Nevada Constitution and NRS 4.370(1)(b), as the amount in controversy exceeds
27 $15,000.00, exclusive of attorney’s fees, interest, and costs.
28 2. This Court has personal jurisdiction over the Defendants because, upon

Page 1 of 16

Case Number:A-23-882960-C
1 information and belief, each of the Defendants is a resident of and/or domiciled in the State of
2 Nevada and this Court’s exercise of jurisdiction is not inconsistent with the Constitution of the
3 State of Nevada or the Constitution of the United States. NRS 14.065.
4 3. Venue is proper in Clark County, Nevada because, upon information and belief,
5 each of the Defendants is a resident of Clark County. NRS 13.040.
6 THE PARTIES
7 4. At all times relevant to this action, Plaintiff KEVIN LAPEER (hereinafter “Mr.
8 Lapeer”), is and was a resident of Clark County, State of Nevada and a peace officer employed

9 by the Henderson Police Department.

10 5. At all times relevant to this action, Plaintiff LAUREN LAPEER (hereinafter “Mrs.
11 LaPeer”), is and was a resident of Clark County, State of Nevada and legally married to Mr.
12 LaPeer.
13 6. Defendant CITY OF HENDERSON (hereinafter the “City”) is a political
14 subdivision of the State of Nevada.
15 7. Defendant HENDERSON POLICE DEPARTMENT (hereinafter “HPD”) is a law
16 enforcement agency under NRS 289.010(2) and a division of the City. HPD employed and
17 continues to employ Mr. LaPeer. HPD conducted an internal investigation regarding Mr. LaPeer
18 which spanned from September of 2021 to June of 2023.
19 8. At all times relevant to this action, Defendant HECTOR VILLA (hereinafter
20 “Villa”), is and was an HPD employee who made various unfounded and false allegations of
21 misconduct against Mr. LaPeer.
22 9. Defendant THEDRICK ANDRES (hereinafter “Andres”), was the Chief of Police
23 of the Henderson Police Department throughout the investigation of Mr. LaPeer. As the Chief of
24 Police, Andres oversaw and directed the operations of the HPD. All actions by Andres as alleged
25 herein were taken under color of state law.
26 10. At all times relevant to this action, Defendant ANTHONY BRANCHINI
27 (hereinafter “Branchini”), was and is an HPD employee who, upon information and belief,
28 oversaw the internal investigation of Mr. LaPeer. All actions by Branchini as alleged herein were

Page 2 of 16
1 taken under color of state law.
2 11. Doe Defendants 1 through 20 are persons whose true names and identities and
3 capacities are unknown to Plaintiffs at this time, and who acted on behalf of or in concert with, or
4 at the direction of, the named Defendants or any Roe Defendant or who are officers, directors,
5 employees, or agents of any of the named or Roe Defendants.
6 12. The Roe Defendants 1 through 10 are entities whose true names and identities and
7 capacities are unknown to Plaintiffs at this time and may be corporations, associations,
8 partnerships, subsidiaries, holding companies, owners, predecessor or successor entities, joint

9 ventures, parent corporations, or related entities of the named Defendants, or any of them, or any
10 other Roe Defendant.
11 13. Plaintiffs will seek leave of this Court to substitute the true names and capacities
12 for such Doe and Roe Defendants when discovered.
13 GENERAL ALLEGATIONS
14 14. Plaintiffs re-allege and incorporate by reference all preceding paragraphs.
15 15. Mr. LaPeer has been employed as a peace officer with the HPD since February 20,
16 2007.
17 16. Mr. LaPeer has spent the majority of his career serving as a Detective on the
18 Robbery/Homicide Unit of the HPD.
19 17. On or about September 23, 2021, Mr. LaPeer was placed on paid administrative
20 leave by the HPD. HPD did not initially inform Mr. LaPeer as to why he was being placed on
21 administrative leave and he was only told that he was being placed on leave pending the outcome
22 of an internal affairs investigation.
23 18. Upon information and belief, this “investigation” commenced after Defendant Villa
24 made several unfounded allegations against Mr. LaPeer to various members of the HPD and others,
25 accusing Mr. LaPeer of being, amongst other things, a bigot and a racist, and accusing Mr. LaPeer
26 of engaging in workplace misconduct.
27 19. Upon information and belief, Villa is and was known by HPD as someone who has
28 a history of making unfounded or unsubstantiated workplace complaints.

Page 3 of 16
1 20. The City and HPD proceeded to conduct an unprecedented twenty (20) month
2 investigation into Mr. LaPeer.
3 21. Despite being put on leave by HPD in September of 2021, HPD did not begin
4 conducting witness interviews into the allegations of misconduct against Mr. LaPeer until January
5 of 2022.
6 22. Further, it was not until March of 2022 that Mr. LaPeer received two (2) “Notices
7 of Administrative Investigation” (hereinafter the “Notices”).
8 23. The Notices indicated that Robert Freeman Esq., Lt. Anthony Branchini, and

9 Amber Swartwood, would be in charge of the internal investigation and that Robert Freeman, Esq.,
10 Lt. Anthony Branchini, Amber Swartwood, and Ashley Hanks would conduct any
11 interviews/interrogations of Mr. LaPeer with respect to the internal investigation.
12 24. Robert Freeman, Esq., and Ashley Hanks are not peace officers.
13 25. The Notices were meant to outline the allegations of misconduct against Mr.
14 LaPeer. However, the Notices failed to provide Mr. LaPeer with an adequate summary of the
15 alleged misconduct that he was accused of engaging in. Rather, the Notices broadly accused Mr.
16 LaPeer of engaging in “conduct” or “behaviors” that “may” or “could” have been a violation of
17 various City and HPD policies between September 23, 2016 to September 23, 2021.
18 26. Notably, NRS 289.057 prohibits a law enforcement agency from conducting an
19 investigation into allegations that a peace officer has engaged in misconduct more than 5 years
20 after the misconduct is alleged to have occurred.
21 27. Upon information and belief, HPD utilized the maximum investigative timeframe
22 permitted by law in its Notices, in order to allow it to conduct the broadest investigation possible
23 into Mr. LaPeer.
24 28. Peace officers, such as Mr. LaPeer, are entitled to certain procedural protections to
25 safeguard the rights they possess with respect to their employment.
26 29. NRS 289.060 relevantly states that:
27 “1. Except as otherwise provided in this subsection, a law enforcement
agency shall, not later than 48 hours before any interrogation or hearing is
28

Page 4 of 16
1 held relating to an investigation conducted pursuant to NRS 289.057,
provide a written notice to the peace officer who is the subject of the
2 investigation. If the law enforcement agency believes that any other peace
officer has any knowledge of any fact relating to the complaint or allegation
3
against the peace officer who is the subject of the investigation, the law
4 enforcement agency shall provide a written notice to the peace officer
advising the peace officer that he or she must appear and be interviewed as
5 a witness in connection with the investigation. Any peace officer who serves
as a witness during an interview must be allowed a reasonable opportunity
6 to arrange for the presence and assistance of a representative authorized by
NRS 289.080. Any peace officer specified in this subsection may waive the
7
notice required pursuant to this section.
8
2. The notice provided to the peace officer who is the subject of the
9 investigation must include:
10 (a) A description of the nature of the investigation;
11 (b) A summary of alleged misconduct of the peace officer;
(c) The date, time and place of the interrogation or hearing;
12 (d) The name and rank of the officer in charge of the investigation
and the officers who will conduct any interrogation or hearing;
13 (e) The name of any other person who will be present at any
interrogation or hearing; and
14 (f) A statement setting forth the provisions of subsection 1 of NRS
15 289.080.” (emphasis added).

16 30. HPD failed to comply with the statutory notice requirements outlined in NRS

17 289.060 by failing to provide an appropriate summary to Mr. LaPeer of the misconduct he was

18 alleged to have engaged in before conducting any interrogations and by identifying non-peace

19 officers as the individuals that would be leading the investigation and conducting his

20 interrogation(s).

21 31. This lack of appropriate notice and procedure caused and allowed HPD to conduct

22 an open-ended and nearly limitless investigation into Mr. LaPeer’s character and conduct which

23 significantly and impermissibly prolonged Mr. LaPeer’s administrative leave and constituted a

24 violation of his due process rights.

25 32. Moreover, HPD’s conduct throughout the investigation resulted in a complete

26 assassination of Mr. LaPeer’s character.

27 33. For example, throughout the course of the investigation, dozens of witnesses were

28 interviewed and asked open ended and suggestive questions about Mr. LaPeer’s conduct and

Page 5 of 16
1 character including:
2 a. “Do you think Kevin LaPeer is a good, professional, law
enforcement officer?”
3 b. “Has [Kevin LaPeer] said things that are outside of the policies
and procedures of the Henderson Police Department?”
4
c. “Do you think Kevin LaPeer is a credit to the Henderson Police
5 Department?”
d. “Do you think, based upon his vocabulary, and the words that he
6 uses, that Kevin LaPeer can be reasonably described as racist?”
e. “Have you ever been a witness to Detective LaPeer using a word
7 or phrase to describe a person or group of people that would be
derogatory and outside the policies and procedures of the
8
Henderson Police Department?”
9 f. “Have I asked questions sufficient so that if you knew something
about Kevin LaPeer, you would have responded and told me
10 today?”
11 34. Upon information and belief, those involved in the investigation suggested to
12 dozens of individuals, both in written and verbal communications, that Mr. LaPeer was a bigot,
13 unprofessional, unethical and a criminal.
14 35. Upon information and belief, during this time, HPD also engaged both the Las
15 Vegas Metropolitan Police Department and the Federal Bureau of Investigation to conduct
16 criminal investigations into Mr. LaPeer. These investigations did not result in any criminal charges
17 being filed against Mr. LaPeer.
18 36. Throughout the investigation, Mr. LaPeer suffered immense emotional distress,
19 mental anguish, stress and anxiety which was so severe that he developed physical manifestations
20 of his mental and emotional suffering, such as teeth grinding and jaw clenching that ultimately
21 required surgery.
22 37. Further, the stress caused by the investigation negatively impacted Mr. LaPeer’s
23 and Mrs. LaPeer’s marital relationship.
24 38. Upon information and belief, the last witness interview conducted with respect to
25 HPD’s internal investigation into Mr. LaPeer occurred on July 14, 2022. However, Mr. LaPeer
26 remained on administrative until February of 2023.
27 39. On or about February 27, 2023, Mr. LaPeer was ordered to return to work at HPD.
28

Page 6 of 16
1 The outcome of the investigation was not communicated to Mr. LaPeer at this time.
2 40. Mr. LaPeer returned to work, as ordered in February of 2023.
3 41. While Mr. LaPeer was ultimately able to return to work following the lengthy
4 investigation, the conduct of the internal investigation resulted in a damage to Mr. LaPeer’s
5 professional reputation and loss of professional opportunities.
6 42. For instance, upon returning to work, Mr. LaPeer was removed from the
7 Robbery/Homicide Unit and placed in a different unit. Upon information and belief, this
8 reassignment was necessitated because of concerns about Mr. LaPeer’s professional reputation and

9 character following the internal investigation.

10 43. Following Mr. LaPeer’s return to duty, Defendant Villa sent an email from his work
11 email to a number of individuals with the subject line: “Det. LaPeer return to duty…let’s talk”
12 wherein Villa continued to defame Mr. LaPeer by insisting that Mr. LaPeer put his colleague
13 “down cause [sic] of his Asian race and national origin” and accused Mr. LaPeer of “gross
14 wrongdoing and criminal acts.”
15 44. Upon information and belief, Villa was never formally investigated or reprimanded
16 by HPD for this conduct.
17 45. Ultimately, on June 29, 2023, Mr. LaPeer received correspondence from HPD’s
18 new Chief of Police, Hollie Chadwick, stating that all allegations of misconduct made against Mr.
19 LaPeer were deemed to be unfounded.
20 46. Despite being cleared of wrongdoing, Villa continued to target Mr. LaPeer and
21 harass him at work, including inappropriately confronting Mr. LaPeer at work and attempting to
22 intimidate him in October of 2023.
23 47. HPD is and was aware of Villa’s conduct but failed to appropriately address the
24 situation, causing Mr. LaPeer further mental anguish.
25 FIRST CLAIM FOR RELIEF
(Defamation - Mr. LaPeer against all Defendants)
26
48. Plaintiffs re-allege and incorporate by reference all preceding paragraphs.
27
49. On numerous occasions, Defendant Villa falsely stated to multiple third parties,
28

Page 7 of 16
1 including other employees of the HPD, that Mr. LaPeer was racist, a bigot, unethical, and
2 unprofessional, and that Mr. LaPeer had engaged in misconduct and criminal behavior.
3 50. Upon information and belief, HPD launched an internal investigation into Mr.
4 LaPeer based on Villa’s false accusations.
5 51. Upon information and belief, HPD knew or had reason to know that these
6 allegations were without merit, or at a minimum, learned early on in its internal investigation into
7 Mr. LaPeer that Villa’s accusations against Mr. LaPeer were unfounded.
8 52. Despite this, HPD carried on a twenty (20) month internal investigation into Mr.

9 LaPeer, wherein those involved in the investigation, including Defendant Andres and Defendant
10 Branchini, ratified Villa’s conduct and falsely suggested to numerous individuals, including other
11 HPD employees, the Las Vegas Metropolitan Police Department, and the Federal Bureau of
12 Investigations, that Mr. LaPeer was, amongst other things, unethical, unprofessional, racist, and
13 a bigot and that Mr. LaPeer had engaged in misconduct and criminal behavior.
14 53. The administrative investigation into Mr. LaPeer was not contemplated in good
15 faith.
16 54. The Defendants’ communications were not privileged. Alternatively, if any
17 qualified privilege attached to the Defendants’ statements, the Defendants exceeded that privilege
18 and/or lost the protections of the privilege by their bad faith conduct.
19 55. Throughout the prolonged and bad faith “investigation” into Mr. LaPeer, the
20 Defendants impugned Mr. LaPeer’s honesty, integrity, honor and morality which subjected Mr.
21 LaPeer to ridicule, contempt, and disgrace and lowered his esteem in the law enforcement
22 community.
23 56. The Defendants’ statements constitute defamation per se as they tend to injure Mr.
24 LaPeer in his profession and suggest that Mr. LaPeer engaged in criminal conduct.
25 57. The Defendants’ false and defamatory statements were made with either
26 knowledge that the statements were false or with reckless disregard for the truth.
27 58. As a direct and proximate result of the Defendants’ conduct, Mr. LaPeer has
28 suffered damages in excess of $15,000.00, according to proof. Alternatively, damages are

Page 8 of 16
1 presumed.
2 59. In committing the wrongful acts as alleged herein, the Defendants are guilty of
3 oppression, fraud, or malice, express or implied, such that Mr. LaPeer is entitled to recover
4 punitive and exemplary damages, to the extent such damages are permitted by law.
5 60. Mr. LaPeer has been forced to retain legal counsel to prosecute this claim, and
6 therefore, he is entitled to an award of reasonable attorneys’ fees and costs associated with this
7 matter, and as may be permitted by law.
8 SECOND CLAIM FOR RELIEF
(Intentional Infliction of Emotional Distress - Mr. LaPeer against all Defendants)
9
61. Plaintiffs re-allege and incorporate by reference all preceding paragraphs.
10
62. Defendant Villa made false allegations against Mr. LaPeer which suggested that
11
Mr. LaPeer was a racist, a bigot, unethical, and unprofessional, and that he had engaged in
12
misconduct and criminal behavior.
13
63. Upon information and belief, HPD launched an internal investigation into Mr.
14
LaPeer based on Villa’s false accusations.
15
64. HPD placed Mr. LaPeer on administrative leave during this internal investigation,
16
starting on September 23, 2021.
17
65. Upon information and belief, HPD knew or had reason to know that these
18
allegations were without merit, or at a minimum, learned early on in its internal investigation into
19
Mr. LaPeer that Villa’s accusations against Mr. LaPeer were unfounded.
20
66. Despite this, HPD carried on a twenty (20) month internal investigation into Mr.
21
LaPeer, wherein those involved in the investigation, including Defendant Andres and Defendant
22
Branchini, ratified Villa’s conduct and falsely suggested to numerous individuals, including other
23
HPD employees, the Las Vegas Metropolitan Police Department, and the Federal Bureau of
24
Investigations, that Mr. LaPeer was, amongst other things, unethical, unprofessional, racist, and
25
a bigot and that Mr. LaPeer had engaged in misconduct and criminal behavior.
26
67. Despite being put on leave by HPD in September of 2021, HPD did not begin
27
conducting witness interviews into the allegations of misconduct against Mr. LaPeer until January
28

Page 9 of 16
1 of 2022.
2 68. Upon information and belief, the last witness interview conducted with respect to
3 HPD’s internal investigation into Mr. LaPeer occurred on July 14, 2022. However, Mr. LaPeer
4 remained on administrative until February of 2023.
5 69. The investigation caused Mr. LaPeer to suffer immense emotional distress, mental
6 anguish, stress and anxiety.
7 70. Mr. LaPeer was ordered to return to work in February of 2023, and following his
8 return to duty, Defendant Villa sent an email from his work email to a number of individuals with

9 the subject line: “Det. LaPeer return to duty…let’s talk” wherein Villa continued to defame Mr.
10 LaPeer by insisting that Mr. LaPeer put his colleague “down cause [sic] of his Asian race and
11 national origin” and accused Mr. LaPeer of “gross wrongdoing and criminal acts.”
12 71. Ultimately, the allegations of misconduct against Mr. LaPeer were deemed to be
13 unfounded.
14 72. Despite being cleared of wrongdoing, Villa continued to target Mr. LaPeer and
15 harass him at work, including inappropriately confronting Mr. LaPeer at work and attempting to
16 intimidate him in October of 2023.
17 73. The conduct of the Defendants, as described herein constitutes extreme and
18 outrageous conduct which falls outside all possible bounds of decency and which is utterly
19 intolerable in a civilized community.
20 74. The conduct undertaken by the Defendants, as described herein, was done with the
21 intent and design to cause Mr. LaPeer emotional distress or with reckless disregard for causing
22 Mr. LaPeer emotional distress.
23 75. As a direct and proximate result of the Defendants’ actions, Mr. LaPeer has
24 endured extreme anxiety, shame emotional distress, mental anguish, and humiliation. Mr.
25 LaPeer’s emotional and mental suffering is so extreme that it has manifested physically. He has
26 developed high blood pressure and he was required to undergo oral surgery to address injuries
27 that resulted from stress-induced jaw clenching and teeth grinding.
28 76. As a direct and proximate result of the Defendants’ conduct, Mr. LaPeer has

Page 10 of 16
1 suffered damages in excess of $15,000.00, according to proof.
2 77. In committing the wrongful acts as alleged herein, the Defendants are guilty of
3 oppression, fraud, or malice, express or implied, such that Mr. LaPeer is entitled to recover
4 punitive and exemplary damages, to the extent such damages are permitted by law.
5 78. Mr. LaPeer has been forced to retain legal counsel to prosecute this claim, and
6 therefore, he is entitled to an award of reasonable attorneys’ fees and costs associated with this
7 matter, and as may be permitted by law.
8 THIRD CLAIM FOR RELIEF
(Civil Conspiracy - Mr. LaPeer against all Defendants)
9
79. Plaintiffs re-allege and incorporate by reference all preceding paragraphs.
10
80. The Defendants, together, entered into an agreement to promulgate and perpetuate
11
false allegations against Mr. LaPeer for the improper purpose of harming Mr. LaPeer, destroying
12
his reputation, and damaging his career.
13
81. The Defendants acted in concert in order to accomplish this unlawful objective.
14
82. The Defendants committed one or more wrongful acts in furtherance of this
15
conspiracy, including, but not limited to, communicating false statements about Mr. LaPeer to his
16
peers and others in the law enforcement community, placing Mr. LaPeer on administrative leave,
17
and launching and maintaining an unlawful internal investigation into Mr. LaPeer which carried
18
on for twenty (20) months.
19
83. As a direct and proximate result of the Defendants’ conduct, Mr. LaPeer has
20
suffered damages in excess of $15,000.00, according to proof.
21
84. In committing the wrongful acts as alleged herein, the Defendants are guilty of
22
oppression, fraud, or malice, express or implied, such that Mr. LaPeer is entitled to recover
23
punitive and exemplary damages, to the extent such damages are permitted by law.
24
85. Mr. LaPeer has been forced to retain legal counsel to prosecute this claim, and
25
therefore, he is entitled to an award of reasonable attorneys’ fees and costs associated with this
26
matter, and as may be permitted by law.
27
///
28

Page 11 of 16
1 FOURTH CLAIM FOR RELIEF
(Violation of NRS 289.060 - Mr. LaPeer against the Henderson Police Department)
2
86. Plaintiffs re-allege and incorporate by reference all preceding paragraphs.
3
87. Chapter 289 of the Nevada Revised Statutes, commonly known as the “Peace
4
Officers’ Bill of Rights,” was enacted to protect the rights of peace officers in dealings with their
5
employers.
6
88. NRS 289.060 requires law enforcement agencies to abide by certain procedural
7
safeguards when conducting an internal investigation into one of its peace officers.
8
89. Specifically, NRS 289.060 relevantly states that:
9
“1. Except as otherwise provided in this subsection, a law enforcement agency
10
shall, not later than 48 hours before any interrogation or hearing is held relating to
11 an investigation conducted pursuant to NRS 289.057, provide a written notice to
the peace officer who is the subject of the investigation. If the law enforcement
12 agency believes that any other peace officer has any knowledge of any fact relating
to the complaint or allegation against the peace officer who is the subject of the
13 investigation, the law enforcement agency shall provide a written notice to the
peace officer advising the peace officer that he or she must appear and be
14
interviewed as a witness in connection with the investigation. Any peace officer
15 who serves as a witness during an interview must be allowed a reasonable
opportunity to arrange for the presence and assistance of a representative
16 authorized by NRS 289.080. Any peace officer specified in this subsection may
waive the notice required pursuant to this section.
17
18 2. The notice provided to the peace officer who is the subject of the
investigation must include:
19
(a) A description of the nature of the investigation;
20 (b) A summary of alleged misconduct of the peace officer;
(c) The date, time and place of the interrogation or hearing;
21 (d) The name and rank of the officer in charge of the investigation and the
22 officers who will conduct any interrogation or hearing;
(e) The name of any other person who will be present at any interrogation or
23 hearing; and
(f) A statement setting forth the provisions of subsection 1 of NRS 289.080.”
24 (emphasis added).
25 90. Defendant HPD violated the rights of Mr. LaPeer by conducting an internal
26 investigation into Mr. LaPeer without providing Mr. LaPeer with an appropriate summary of his
27 alleged misconduct and by identifying non-peace officers as the individuals that would be leading
28

Page 12 of 16
1 the investigation and conducting his interrogation(s).
2 91. This lack of appropriate notice and procedure caused and allowed HPD to conduct
3 an open-ended and nearly limitless investigation into Mr. LaPeer’s character and conduct which
4 significantly and impermissibly prolonged Mr. LaPeer’s administrative leave and constituted a
5 violation of his rights under Nevada law.
6 92. The length, nature, and manner of the investigation into Mr. LaPeer was
7 inconsistent with the intent of Chapter 289 of the Nevada Revised Statutes which contemplates
8 that investigations into allegations of misconduct should be conducted expeditiously,

9 transparently, and in good faith.

10 93. HPD’s internal investigation into Mr. LaPeer, was conducted in bad faith, and
11 resulted in undue stress, professional harm, and personal suffering for Mr. LaPeer.
12 94. The Defendants’ actions in both initiating and conducting this "investigation"
13 demonstrate a deliberate disregard for the rights and protections granted to Mr. LaPeer under NRS
14 289.060.
15 95. As a direct and proximate result of the Defendants’ conduct, Mr. LaPeer has
16 suffered damages in excess of $15,000.00, according to proof.
17 96. Mr. LaPeer has been forced to retain legal counsel to prosecute this claim, and
18 therefore, he is entitled to an award of reasonable attorneys’ fees and costs associated with this
19 matter, and as may be permitted by law.
20 FIFTH CLAIM FOR RELIEF
(Deprivation of Rights under 42 U.S.C. § 1983 - Mr. Lapeer against City of Henderson,
21 Henderson Police Department, Thedrick Andres, and Anthony Branchini)
22 97. Plaintiffs re-allege and incorporate by reference all preceding paragraphs.
23 98. The Fourteenth Amendment to the United States Constitution provides that no
24 State shall deprive any person of life, liberty, or property, without due process of law.
25 99. At all times relevant to this action, Mr. LaPeer possessed, and continues to possess,
26 a constitutionally protected interest in his reputation, particularly when coupled with his
27 constitutionally protected interest in his employment with HPD, neither of which may be deprived
28

Page 13 of 16
1 without due process of law.
2 100. In September of 2021, Mr. LaPeer was placed on paid administrative leave by HPD
3 pending the outcome of an internal affairs investigation.
4 101. Nevada law specifically provides that a peace officer who is the subject of an
5 internal investigation is entitled to receive “a summary of the alleged misconduct” before any
6 interrogation or hearing is held relating to said investigation. NRS 289.060.
7 102. Mr. LaPeer received no notice as to the reason he was placed on paid
8 administrative leave until March of 2022, when he received two (2) “Notices of Administrative

9 Investigation” (hereinafter the “Notices”).

10 103. By this point, Mr. LaPeer had already been on administrative leave for
11 approximately six (6) months and the Defendants had already conducted multiple witness
12 interviews in connection with the investigation.
13 104. Moreover, the Notices failed to provide Mr. LaPeer with an adequate summary of
14 the alleged misconduct that he was accused of engaging in. Rather, the Notices broadly accused
15 Mr. LaPeer of engaging in “conduct” or “behaviors” that “may” or “could” have been a violation
16 of various City and HPD policies between September 23, 2016 to September 23, 2021.
17 105. Upon information and belief, HPD utilized the maximum investigative timeframe
18 permitted by law in its Notices, in order to allow it to conduct the broadest investigation possible
19 into Mr. LaPeer.
20 106. Mr. LaPeer remained on paid administrative leave for seventeen (17) months
21 while HPD conducted its “investigation”.
22 107. The lack of appropriate notice and procedure caused and allowed HPD to conduct
23 an overbroad, open-ended and arbitrary investigation into Mr. LaPeer’s character and conduct
24 which significantly and impermissibly prolonged Mr. LaPeer’s administrative leave and
25 constituted a violation of his procedural due process rights, guaranteed to him under the
26 Fourteenth Amendment to the United States Constitution.
27 108. As a direct and proximate result of the Defendants’ conduct, Mr. LaPeer has
28 suffered immense damage to his reputation, emotional distress, mental anguish, stress and anxiety,

Page 14 of 16
1 resulting in damages in excess of $15,000.00, according to proof.
2 109. Mr. LaPeer has been forced to retain legal counsel to prosecute this claim, and
3 therefore, he is entitled to an award of reasonable attorneys’ fees and costs associated with this
4 matter, and as may be permitted by law.
5 SIXTH CLAIM FOR RELIEF
(Loss of Consortium - Mrs. LaPeer against all Defendants)
6
110. Plaintiffs re-allege and incorporate by reference all preceding paragraphs.
7
111. At all times relevant to this action, Mrs. LaPeer and Mr. LaPeer have been and
8
continue to be lawfully married and have shared a close, loving, and affectionate relationship.
9
112. The Defendants, in committing the wrongful actions as described herein, have
10
caused Mr. LaPeer to suffer immense emotional distress, mental anguish, stress and anxiety.
11
113. The stress and emotional and mental suffering caused by the Defendants, as
12
described herein, has negatively impacted Mr. LaPeer’s and Mrs. LaPeer’s marital relationship.
13
114. Due to Defendants’ actions, Mrs. LaPeer has suffered a loss of society, love,
14
affection, companionship, and support from Mr. LaPeer, thereby damaging their marital
15
relationship.
16
115. As a direct and proximate result of the Defendants’ conduct, Mrs. LaPeer has
17
suffered damages in excess of $15,000.00, according to proof.
18
116. In committing the wrongful acts as alleged herein, the Defendants are guilty of
19
oppression, fraud, or malice, express or implied, such that Mrs. LaPeer is entitled to recover
20
punitive and exemplary damages, to the extent such damages are permitted by law.
21
117. Mrs. LaPeer has been forced to retain legal counsel to prosecute this claim, and
22
therefore, she is entitled to an award of reasonable attorneys’ fees and costs associated with this
23
matter, and as may be permitted by law.
24
WHEREFORE, Plaintiffs pray for judgment against the Defendants as follows:
25
1. General and special damages in an amount in excess of $15,000.00;
26
2. Punitive and exemplary damages in excess of $15,000.00, and as permitted by law;
27
3. Prejudgment and post-judgment interest at the highest rate allowed by law;
28

Page 15 of 16
1 4. Costs of suit and reasonable attorneys’ fees, as may be allowed by law; and
2 5. For such other and further relief as this Court may deem just and proper.
3 Dated this 28th day of November 2023.
4 SGRO & ROGER

5
/s/ Alanna Bondy .
6
ANTHONY P. SGRO, ESQ.
7 Nevada Bar No. 3811
ALANNA BONDY, ESQ.
8 Nevada Bar No. 14830
2901 El Camino Avenue, Suite 204
9 Las Vegas, Nevada 89102
Attorneys for Plaintiffs
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Page 16 of 16