Electronically Filed

2/2/2022 1:26 PM
Steven D. Grierson
CLERK OF THE COURT

1 Timothy R. Treffinger, Esq.

Nevada Bar No.: 12877
2
2350 S Jones Blvd, D2
3 Las Vegas, NV 89146
702-333-5594 CASE NO: A-22-847668-C
4 AttorneyTreffinger@gmail.com Department 1
Attorney for Plaintiff: M. Joseph Miller, II.
5

6 DISTRICT COURT

7 CLARK COUNTY, NV
8 MACK JOSEPH MILLER, II., Case No.:
9
Plaintiff, Dept. No.:
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vs. COMPLAINT
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RICHARD L. “TICK” SEGERBLOM,
12
Defendant
13

14 COMES NOW, the Plaintiff, MACK JOSEPH MILLER, II. (hereafter “MACK MILLER), by

15 and through counsel, TIMOTHY R. TREFFINGER, ESQ., and hereby files this COMPLAINT.
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Plaintiff, MACK MILLER, complaints, alleges and avers as follows:
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I. INTRODUCTION
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1. This is a civil action for damages and relief based upon defamatory and slanderous

20 statements made by the defendant against the plaintiff to various news outlets.

21 II. PARTIES
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2. MACK JOSEPH MILLER, II., is an individual living in Clark County, NV, he is a
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business consultant, and political candidate, currently running for the office of Lt.
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25
Governor in the State of Nevada.

26 3. RICHARD L. “TICK” SEGERBLOM (hereafter “Tick Segerblom), is an individual

27 living in Clark County, NV.

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COMPLAINT - 1

Case Number: A-22-847668-C

1 III. FACTUAL ALLEGATIONS
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4. On September 21, 2021, Mr. Miller attended a County Commission Meeting in Las
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Vegas, Clark County, Nevada.
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5. During this meeting, while speaking out for the rights of, and against the aggressive
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6 actions of security personnel towards other attendees, Mr. Miller was forcefully and

7 unlawfully removed from the commission chamber.

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6. During his removal Mr. Miller was violently carried into an through a metal detector, and
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slammed to the ground.
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7. Shortly thereafter the Defendant appeared on various news outlets stating on video to at
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12 least one: “I know he (Mr. Miller) punched somebody before it all started, we have that

13 on video but we can go back and examine it all very closely, if we need to correct what
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we do, um, we’ll do that, and I would apologize to him if we did something wrong…”
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8. No such video or any other evidence was ever produced, and no such apology issued.
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9. This video statement has continued to be spread by the Defendant on his Twitter page as
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18 recently as December 2021.

19 10. When confronted with the allegations contained herein the Defendant continued to insult
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Mr. Miller and make defamatory statements publicly on his twitter page stating on
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December 28, 2021: “mack “the traitor” miller is suing me? Omg”
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11. Later on December 28, 2021, the defendant posted again on Twitter: “being sued by
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24 mack miller is like being called ugly by a frog.”

25 IV. FIRST CLAIM FOR RELIEF: SLANDER

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12. Plaintiff repeats and realleges the allegations contained in the foregoing paragraphs as
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though they were fully set forth herein.
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COMPLAINT - 2
1 13. Defendant, TICK SEGERBLOM, made the above referenced statements of fact about
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Mr. Miller, which were false, erroneous, and damaging.
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14. Defendant made an unprivileged publication of these statements to third party news
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outlets which proceeded to carry the story.
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6 15. As recently as December 29, 2021 Defendant has retweeted this video on his own Twitter

7 page which has nearly 9,000 followers.

8
16. These statements and related conduct acted negligently, recklessly, and/or intentionally in
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making and spreading these false statements.
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17. That as a result of the statements Mr. Miller’s reputation has been damaged, worse still
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12 during an election year.

13 18. As a result of this conduct Mr. Miller has been damaged in excess of $100,000 in an
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amount to be proven at time of trial.
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V. SECOND CLAIM FOR RELIEF: LIBEL
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19. Plaintiff repeats and realleges the allegations contained in the foregoing paragraphs as
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18 though they were fully set forth herein.

19 20. Defendant, TICK SEGERBLOM, in referring to Mr. Miller as a “traitor”, made a false,
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erroneous, and damaging statement.
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21. Defendant made an unprivileged publication of this statement by posting the same on his
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Twitter account on December 28, 2021 to his nearly 9,000 followers.
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24 22. These statements were made in a manner that was negligent, reckless, and/or intentional.

25 23. As a result of these actions Mr. Miller’s reputation has been damaged.
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24. As a result of the Defendant’s conduct Mr. Miller has suffered damages in excess of
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$100,000, in an amount to be proven at time of trial.
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COMPLAINT - 3
1 WHEREFORE, the Plaintiff prays for the following relief:
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1. A judgment declaring that the practices complained of herein are unlawful and in willful
3
violation of Nevada law.
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2. An award of all damages sustained by Plaintiff by Defendant’s conduct;
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6 3. An award to the Plaintiff of their costs, including reasonable attorney’s fees, and other

7 costs.
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4. An award to the Plaintiff of pre-judgment and post-judgment interest, as provided by law;
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and
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5. Any other relief deemed just and proper by this Honorable Court.
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12 Dated this 2nd of February, 2022.

13

14
Timothy R. Treffinger, Esq.
15 Nevada Bar No.: 12877

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VERIFICATION
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I, MACK MILLER, the Plaintiff in the above-captioned matter, hereby certify that I have read
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19 the attached Complaint, that I know the contents thereof, and that all allegations contained

20 therein are true to the best of my knowledge, except as to those matters stated upon information
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and belief, and as to those matters I believe them to be true.
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Dated this 2nd of February, 2022.
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24 /S/ MACK MILLER

25 M. JOSEPH MILLER, II.

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27

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COMPLAINT - 4