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 1 2 3
 IN THE FIRST JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA
 4
 IN AND FOR THE COUNTY OF STOREY, NEVADA
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 -o0o-
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MELANIE KEENER, : : Case No.
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 Plaintiff, : 17 TRT 00001 1E :
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 vs. : :
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GERALD R. ANTINORO, an individual;:STOREY COUNTY, a political :
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subidivision of the State of :Nevada; et al., :
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 : Defendants. :
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======================================================
131415
 DEPOSITION OF
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 GERALD ANTINORO
17
 February 8, 2018
18
 Reno, Nevada
192021222324
Reported by: DIANNE M. BRUMLEY, NV CCR #205
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 California CSR #6796
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 1
 APPEARANCES
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 FOR THE PLAINTIFF:
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 Flangas Dalacas Law Group Attorneys at Law
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 BY: GUS W. FLANGAS 3275 South Jones Blvd., Suite 105
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 Las Vegas, Nevada 89146
 8 9
 FOR THE DEFENDANTS: Rands, South & Gardner
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 Attorneys at Law BY: DOUGLAS RANDS
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 9498 Double R Blvd. #A Reno, Nevada 89521
1213
 Also present:
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 Melanie Keener
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Page 3
 1 2
 I N D E X
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EXAMINATION BY PAGE
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Mr. Flangas 4
 5 6 7 8 910
EXHIBITS
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Exhibit 1 - Policies and procedures 58Exhibit 2 - Complaint 65
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Exhibit 3 - Conclusions and findings of  Investigation 83
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Exhibit 4 - Melanie Keener's statement 119
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Kenner v. Antinoro, et alGerald AntinoroPage 1 (1 - 4)
Bonanza Reporting & Videoconference Center(775) 786-76551111 Forest Street Reno, NV 89509Page 4
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 ***
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 RENO, NEVADA, THURSDAY, FEBRUARY 8, 2018, 9:00 A.M.
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 ***
 4
 GERALD ANTINORO
 5
 having been duly sworn,
 6
 was examined and testified as follows:
 7
 EXAMINATION
 8
BY MR. FLANGAS:
 9
 Q Could you state your name and spell it for the
10
record, please?
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 A Gerald Antinoro, G-e-r-a-l-d, A-n-t-i-n-o-r-o.
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 Q You just took an oath; is that correct?
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 A Yes.
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 Q And you understand that oath has the same
15
solemnity and ramifications as though you took it in a
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court of law?
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 A Yes.
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 Q When I say ramifications, do you understand
19
that to mean same ramifications for perjury?
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 A Yes.
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 Q I know you've had your depo taken a few times
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in the past, so I'm still going to go over the ground
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rules for the record if that's okay.
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 The lady to your immediate left is the court
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reporter. She's taking down everything that's being
 
Page 5
 1
said here today and if you notice, she's doing that with
 2
her fingers and the reason I point that out is she
 3
cannot record both of us speaking at the same time, so
 4
what that means for you and I is that you need to wait
 5
until I finish my question before you give me your
 6
answer, okay?
 7
 A Yeah.
 8
 Q In that same vein, because she is doing this
 9
with her fingers, if the question calls for a yes or no
10
answer, you need to audiblize it by saying yes or no.
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Do you understand that?
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 A Yes.
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 Q The reason is because a nod of the head, a
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shake of the head, an "uh-huh" or "huh-uh" will not come
15
out clear on the transcript. Do you understand that?
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 A Yes.
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 Q I'm not here today to try to trick you with my
18
questions. However, if you do answer the question, it
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will be assumed that you understood the question, okay?
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 A Yes.
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 Q If you don't understand the question, please
22
tell me you don't understand the question and I'll ask 
23
it again, I'll rephrase it, I'll break it down into
24
smaller parts or whatever it takes to facilitate your
25
understanding, okay?
Page 6
 1
 A Yes.
 2
 Q During the course of this deposition, if you
 3
need to take a break, you're welcome to. The only thing
 4
I ask is if there's a question pending, that you finish
 5
answering the question, all right?
 6
 A Okay.
 7
 Q At the conclusion of this deposition, the court
 8
reporter is going to take down everything that was said
 9
here today and transcribe it and put it into a booklet
10
called a transcript. Do you understand that?
11
 A Yes.
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 Q After this transcript is put together, you'll
13
be given an opportunity to review the transcript should
14
you so desire. Do you understand that?
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 A Yes.
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 Q You'll also be given the opportunity to make
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changes to the transcript if you so desire as well. Do
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you understand that?
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 A Yes.
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 Q I need to caution you, however, if you do make
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changes to the transcript of a substantive nature, I
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will be able to comment upon it at any trial,
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arbitration, evidentiary hearing or motion practice as
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the case may be. Do you understand that?
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 A Yes.
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 Q When I say comment upon it, what I mean is I'll
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be able to bring your credibility into question. Do you
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understand that?
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 A Yes.
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 Q If you testify differently at any trial,
 6
arbitration, evidentiary hearing than you do today, I
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will also be able to comment upon it as well. Do you
 8
understand that?
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 A Yes.
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 Q Again, when I say comment upon it, what I mean
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is I'll be able to bring your credibility into question.
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Do you understand that?
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 A Yes.
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 Q I always have to ask these for the record, are
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you on any type of medication today that would affect
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your ability to understand my questions or answer them
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accurately?
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 A No.
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 Q And I've already asked you this in previous
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depos, but just for the purposes of this deposition,
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have you ever been convicted of a felony?
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 A No.
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 Q Have you ever been convicted of a misdemeanor
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that involves fraud, theft or dishonesty?
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 A No.
Kenner v. Antinoro, et alGerald AntinoroPage 2 (5 - 8)
Bonanza Reporting & Videoconference Center(775) 786-76551111 Forest Street Reno, NV 89509Page 8
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 Q And I know I've taken your depo before, but
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these are two separate cases, so you're going to have to
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bear with me while I go through your background again
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and I know it's already in another transcript. What is
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your level of education?
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 A I have two master's degrees.
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 Q Let's start -- obviously before you had a
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master's degree, you had to have a B.S.?
 9
 A Yes, I have a bachelor's degree.
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 Q In what?
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 A Organizational management.
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 Q Where did you get your degree from?
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 A Ashford University.
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 Q Ashford University is located where?
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 A In Clinton, Iowa.
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 Q Was that an on-line course?
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 A Yes.
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 Q What year did you get the degree?
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 A I think it was around 2009.
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 Q Where were you located when you got the degree?
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 A Virginia City.
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 Q And you got a master's degree from where? Two
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master's degree, let's start with the first one.
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 A One was from Ashford University.
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 Q In what field?
 
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 A Again, organizational management.
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 Q What year did you graduate and get your
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master's?
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 A I think it was -- I think that was the one in
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2009 and the bachelor's would have been in 2007,
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somewhere right around there.
 7
 Q And this was on-line again?
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 A Yes.
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 Q Where were you located when you did --
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 A Virginia City.
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 MR. RANDS: Let him finish his question before
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you answer. It just makes it easier for everybody.
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BY MR. FLANGAS:
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 Q Thanks, I was getting ready to say that. That
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 just reminded me of another thing, too. Occasionally
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your attorney will, and I'm not going to say most
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likely, but absolutely will object at one point in time.
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Unless you're instructed not to answer, you're going to
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have to answer the question. Do you understand that?
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 A Yes.
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 Q The next bachelor -- excuse me, master's
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degree, where did you get it from?
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 A Chicago School of Professional Psychology.
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 Q What year?
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 A I think that was 2011 or 2012.
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 Q On-line course again?
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 A Yes.
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 Q Where were you when you did the course?
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 A Virginia City.
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 Q With your master's degree in -- did you get it
 6
in psychology?
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 A Yes.
 8
 Q With your master's degree in psychology, does
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that give you any other certifications to do certain
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types of occupations or anything like that?
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 A No.
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 Q Just to kind of get a timeline, when did you
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graduate high school?
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 A 1982 is when I finished.
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 Q Where did you finish high school?
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 A San Juan County High School.
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 Q California?
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 A Blanding, Utah.
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 Q Can you spell Blanding?
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 A B-l-a-n-d-i-n-g.
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 MR. RANDS: I've been to Blanding.
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BY MR. FLANGAS:
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 Q Can't say I have. What is your present
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occupation?
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 A Sheriff of Storey County.
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 Q How long have you been sheriff?
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 A For seven years.
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 Q It's an elected position?
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 A Yes.
 5
 Q What year were you first elected or appointed
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or however the case may be?
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 A I was elected in 2010, took office in January
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of 2011.
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 Q Prior to your election as sheriff of Storey
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County -- before I go into that, do you have any other
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occupations now other than sheriff of Storey County?
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 A No.
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 Q Prior to your election as sheriff of Storey
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County, what did you do?
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 A I worked for the sheriff's office in Storey
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County.
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 Q In what capacity? And then I'm going to be
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asking you from when to when.
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 A Started working there in 2006 in the positions
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of deputy, corporal, lieutenant, chief deputy and
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assistant sheriff during those years.
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 Q When you started with the Storey County
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Sheriff's Office, you started as a deputy?
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 A Correct.
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 Q And how long were you a deputy?
Kenner v. Antinoro, et alGerald AntinoroPage 3 (9 - 12)
Bonanza Reporting & Videoconference Center(775) 786-76551111 Forest Street Reno, NV 89509Page 12
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 A About a year-and-a-half, I believe.
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 Q Who was your supervisor while you were a
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deputy?
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 A There were a few of them, so I think Ken Quirk 
 5
and Jason Dias were the patrol sergeants when I first
 6
started.
 7
 Q Jason Diaz, D-i-a-z?
 8
 A D-i-a-s, I believe.
 9
 Q And then about a year-and-a-half later you got
10
promoted to corporal?
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 A Yes.
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 Q From when to when?
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 A I think it was 2007 to 2008 I was a corporal
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and Quirk and Dias would have been sergeants and
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Christopher Parsons would have been second in command.
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 Q When you started with the sheriff's office of 
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Storey County, who was the sheriff?
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 A Jim Miller.
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 Q When you became a corporal, was Mr. Miller
20
still sheriff?
21
 A Yes.
22
 Q Was he still sheriff the entire time you were
23
corporal?
24
 A Yes.
25
 Q Then it sounds like you moved up from corporal
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