FILED

Electronically
CV19-00250
2019-03-01 07:02:55 PM
Jacqueline Bryant
Clerk of the Court
1 CODE: 1137 Transaction # 7144707 : csulezic
ARGENTUM LAW
2 WHITNEY DERRAH
Nevada Bar No. 9763
3 whitney@argentumnv.com
JOHN P. SANDE, ESQ.
4 Nevada Bar No. 9175
john@argentumnv.com
5 6121 Lakeside Dr., Suite 208
Reno, Nevada 89511
6 Telephone: (775) 473-5995
Attorneys for Christi Quatro
7

8 IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF

9 NEVADA IN AND FOR THE COUNTY OF WASHOE

10 NEVADA HUMANE SOCIETY,

a Nevada non-profit corporation,
11 CASE NO.: CV19-00250
Plaintiff,
12 DEPT. NO.: 4
v.
13

14 CHRISTI QUATRO, an individual and

Doing business as BIG FISH CONSULTING;
15 and DOES 1 through 10, inclusive,

16 Defendants.
/
17

18 DEFENDANT’S ANSWER AND COUNTERCLAIM

19 Defendant, CHRISTI QUATRO, an individual and doing business as BIG FISH

20 CONSULTING (“Defendant” or “Counterclaimant”), by and through her undersigned counsel,

21 WHITNEY D. DERRAH, ESQ. and JOHN P. SANDE, ESQ., in answer to Plaintiff’s Complaint,

22 hereby admits, denies and alleges as follows:

23 I. PARTIES, JURISDICTION AND VENUE.

24 1. Defendant is without sufficient knowledge or information with which to form a

25 belief as to the truth of allegations contained in Paragraph 1of Plaintiff’s Complaint.

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 1 2. Defendant admits the allegations contained in Paragraph 2 of Plaintiff’s Complaint.

2 3. Defendant is without sufficient knowledge or information with which to form a

3 belief as to the truth of the allegations contained in Paragraph 3 of Plaintiff’s Complaint and on

4 that basis denies the same.

5 4. Defendant admits the allegations contained in Paragraph 4 of Plaintiff’s Complaint.

6 5. Defendant admits, in part, denies, in part, and without sufficient information to

7 form a basis as to a portion of the allegations contained in Paragraph 5 of Plaintiff’s Complaint.

8 Defendant admits that Heels & Hounds was first held in 2015. Defendant is without sufficient

9 information to form a belief as to the accuracy of the asserted “mission” of Plaintiff. Defendant

10 denies the remaining allegations in paragraph 5 of Plaintiff’s Complaint on the basis that Heels &

11 Hounds is not an event belonging to the Nevada Humane Society and the remaining assertions are

12 vague.

13 6. Defendant admits and denes, in part, the allegations contained in Paragraph 6 of

14 Plaintiff’s Complaint in that Defendant has organized Heels & Hounds annually since 2015.

15 Defendant has offered the event to Plaintiff each year since 2015. Defendant denies the remaining

16 allegations in Paragraph 6 of Plaintiff’s Complaint as Defendant is without sufficient information

17 to form a basis as to the truth or accuracy as to Plaintiff’s advertising efforts or content.

18 7. Defendant is without sufficient knowledge or information with which to form a

19 belief as to the truth of allegations contained in Paragraph 7 of Plaintiff’s Complaint and therefore

20 denies the allegations contained in Paragraph 7 of Plaintiff’s Complaint.

21 8. Defendant admits, in part, and denies in part the allegations contained in Paragraph

22 8 of Plaintiff’s Complaint. Defendant admits she was an employee of Plaintiff from on or about

23 April of 2014 to September of 2015 and was employed by Plaintiff when she first held the Heels

24 & Hounds event in 2015. Defendant denies the remaining allegations contained in Paragraph 8 of

25 Plaintiff’s Complaint as it was in fact Defendant who originally organized the committee and
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 1 hosted committee meetings, which she paid for with her own funds, to work on her first Heels &

2 Hounds event in 2015.

3 9. Defendant admits, in part, the allegations contained in Paragraph 9 of Plaintiff’s

4 Complaint. Defendant admits that she was hired by Plaintiff as an independent contractor from

5 2016 to 2018 to organize and produce her Heels & Hounds with Plaintiff as the selected beneficiary

6 of the event. Defendant denies the remaining allegations contained in Paragraph 9 of Plaintiff’s

7 Complaint.

8 10. Defendant denies the allegations contained in Paragraph 10 of Plaintiff’s Complaint

9 to the extend it calls for Defendant to draw a legal conclusion regarding a document which speaks

10 for itself.

11 11. Defendant admits the allegations contained in Paragraph 11 of Plaintiff’s

12 Complaint.

13 12. Defendant is without sufficient knowledge or information with which to form a

14 belief as to the truth of the allegations contained in Paragraph 12 of Plaintiff’s Complaint and

15 therefore denies the allegations contained in Paragraph 12 of Plaintiff’s Complaint.

16 13. Defendant is without sufficient knowledge or information with which to form a

17 belief as to the truth of the allegations contained in Paragraph 13 of Plaintiff’s Complaint and

18 therefore denies the allegations contained in Paragraph 13 of Plaintiff’s Complaint.

19 14. Defendant is without sufficient knowledge or information with which to form a

20 belief as to the truth of the allegations contained in Paragraph 14 of Plaintiff’s Complaint as to the

21 Plaintiff’s intentions and therefore denies the allegations contained in Paragraph 14 of Plaintiff’s

22 Complaint.

23 15. Defendant is without sufficient knowledge or information with which to form a

24 belief as to the truth of the allegations contained in Paragraph 15 of Plaintiff’s Complaint as the

25 alleged quoted language apparently references an unincorporated document and if so that

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 1 document speaks for itself. Defendant therefore denies the allegations contained in Paragraph 15

2 of Plaintiff’s Complaint.

3 16. Defendant is without sufficient knowledge or information with which to form a

4 belief as to the truth of the allegations contained in Paragraph 16 of Plaintiff’s Complaint and

5 therefore denies the allegations contained in Paragraph 16 of Plaintiff’s Complaint.

6 17. Defendant is without sufficient knowledge or information with which to form a

7 belief as to the truth of the allegations contained in Paragraph 17 of Plaintiff’s Complaint and

8 therefore denies the allegations contained in Paragraph 17 of Plaintiff’s Complaint.

9 18. Defendant denies the allegations contained in Paragraph 18 of Plaintiff’s

10 Complaint.

11 FIRST CAUSE OF ACTION

(Unfair Competition Based on Trade Name Infringement)
12

13 19. N/A

14 20. Defendant denies the allegations contained in Paragraph 20 of Plaintiff’s

15 Complaint.

16 21. Defendant denies the allegations contained in Paragraph 21 of Plaintiff’s

17 Complaint.

18 22. Defendant denies the allegations contained in Paragraph 22 of Plaintiff’s

19 Complaint.

20 23. Defendant denies the allegations contained in Paragraph 23 of Plaintiff’s

21 Complaint.

22 24. Defendant denies the allegations contained in Paragraph 24 of Plaintiff’s

23 Complaint.

24 SECOND CAUSE OF ACTION

(Breach of Contract)
25
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 1 25. N/A

2 26. Defendant denies the allegations contained in Paragraph 26 of Plaintiff’s

3 Complaint.

4 27. Defendant is without sufficient knowledge or information with which to form a

5 belief as to the truth of the allegations contained in Paragraph 27 of Plaintiff’s Complaint and

6 therefore denies the allegations contained in Paragraph 27 of Plaintiff’s Complaint.

7 28. Defendant is without sufficient knowledge or information with which to form a

8 belief as to the truth of the allegations contained in Paragraph 28 of Plaintiff’s Complaint and

9 therefore denies the allegations contained in Paragraph 28 of Plaintiff’s Complaint.

10 29. Defendant denies the allegations contained in Paragraph 29 of Plaintiff’s

11 Complaint.

12 30. Defendant denies the allegations contained in Paragraph 30 of Plaintiff’s

13 Complaint.

14 31. Defendant denies the allegations contained in Paragraph 31 of Plaintiff’s

15 Complaint.

16 THIRD CAUSE OF ACTION

(Breach of the Covenant of Good Faith and Fair Dealing)
17

18 32. N/A

19 33. Defendant denies the allegations contained in Paragraph 33 of Plaintiff’s Complaint

20 to the extend they call for Defendant to draw a legal conclusion.

21 34. Defendant is without sufficient knowledge or information with which to form a

22 belief as to the truth of the allegations contained in Paragraph 34 of Plaintiff’s Complaint and

23 therefore denies the allegations contained in Paragraph 34 of Plaintiff’s Complaint.

24 35. Defendant is without sufficient knowledge or information with which to form a

25 belief as to the truth of the allegations contained in Paragraph 35 of Plaintiff’s Complaint.

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 1 36. Defendant denies the allegations contained in Paragraph 36 of Plaintiff’s

2 Complaint.

3 37. Defendant denies the allegations contained in Paragraph 37 of Plaintiff’s

4 Complaint.

5 FOURTH CAUSE OF ACTION

(Declaratory Relief – Ownership of Heels & Hounds Trade Name)
6

7 38. N/A

8 39. Defendant denies the allegations contained in Paragraph 39 of Plaintiff’s Complaint

9 to the extend it calls for Defendant to draw a legal conclusion.

10 40. Defendant admits the allegations contained in Paragraph 40 of Plaintiff’s

11 Complaint.

12 41. Defendant is without sufficient knowledge or information with which to form a

13 belief as to the truth of allegations contained in Paragraph 41 of Plaintiff’s Complaint and therefore

14 denies the allegations contained in Paragraph 41 of Plaintiff’s Complaint.

15 42. Defendant denies the allegations contained in Paragraph 42 of Plaintiff’s

16 Complaint.

17 43. Defendant denies the allegations contained in Paragraph 43 of Plaintiff’s

18 Complaint.

19 FIFTH CAUSE OF ACTION

(Preliminary and Permanent Injunction)
20

21 44. N/A

22 45. Defendant denies the allegations contained in Paragraph 45 of Plaintiff’s

23 Complaint.

24 46. Defendant denies the allegations contained in Paragraph 46 of Plaintiff’s

25 Complaint.
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 1 47. Defendant denies the allegations contained in Paragraph 47 of Plaintiff’s

2 Complaint.

3 SIXTH CAUSE OF ACTION

(Fraudulent Registration Under NRS 600.410)
4

5 48. N/A

6 49. Defendant denies the allegations contained in Paragraph 49 of Plaintiff’s

7 Complaint.

8 50. Defendant denies the allegations contained in Paragraph 50 of Plaintiff’s

9 Complaint.

10 SEVENTH CAUSE OF ACTION

(Wrongful Interference With Prospective Business Advantage)
11

12 51. N/A

13 52. Defendant is without sufficient knowledge or information with which to form a

14 belief as to the truth of the allegations contained in Paragraph 52 of Plaintiff’s Complaint and

15 therefore denies the allegations contained in Paragraph 52 of Plaintiff’s Complaint.

16 53. Defendant denies the allegations contained in Paragraph 53 of Plaintiff’s

17 Complaint.

18 54. Defendant denies the allegations contained in Paragraph 54 of Plaintiff’s

19 Complaint.

20 55. Defendant denies the allegations contained in Paragraph 55 of Plaintiff’s

21 Complaint.

22 56. Defendant is without sufficient knowledge or information with which to form a

23 belief as to the truth of the allegations contained in Paragraph 56 of Plaintiff’s Complaint and

24 therefore denies the allegations contained in Paragraph 56 of Plaintiff’s Complaint.

25
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 1 57. Defendant denies the allegations contained in Paragraph 57 of Plaintiff’s

2 Complaint.

3 EIGHTH CAUSE OF ACTION

(Business Disparagement)
4

5 58. N/A

6 59. Defendant denies the allegations contained in Paragraph 59 of Plaintiff’s

7 Complaint.

8 60. Defendant denies the allegations contained in Paragraph 60 of Plaintiff’s

9 Complaint.

10 61. Defendant denies the allegations contained in Paragraph 61 of Plaintiff’s

11 Complaint.

12 62. Defendant denies the allegations contained in Paragraph 62 of Plaintiff’s

13 Complaint.

14 II. COUNTERCLAIM

15 Defendant/Counterclaimant, CHRISTI QUATRO, an individual and doing business as

16 BIG FISH CONSULTING, by and through her counsel, WHITNEY D. DERRAH, ESQ. and

17 JOHN P. SANDE IV, ESQ., hereby incorporates the undisputed allegations and assertions set forth

18 in Plaintiff’s Complaint and now comes and counterclaims against Plaintiff/Counterdefendant,

19 NEVADA HUMANE SOCIETY, and hereby alleges as follows:

20 STATEMENT OF FACTS

21 In addition to the above, Counterclaimant Christi Quatro hereby submits the following:

22 63. Counterclaimant/Defendant is the party who created, devised, originated,

23 discovered and/or otherwise invented the “Heels & Hounds” name.

24 64. Counterclaimant is the party who created, devised, originated, discovered and/or

25 otherwise invented the Heels & Hounds concept.

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 1 65. Counterclaimant created the Heels & Hounds name and concept in her free time.

2 66. Counterclaimant created the Heels & Hounds name outside the scope of her

3 employment with the Plaintiff.

4 67. Counterclaimant was not employed to create fundraising events for Plaintiff.

5 68. Counterclaimant was not required to create a fundraising event as part of her brief

6 employment with the Counterdefendant.

7 69. Counterclaimant was never requested by Counterdefendant to create a fundraising

8 event.

9 70. Counterclaimant was not hired to be an employee-member of a specific fundraising

10 event committee for Counterdefendant.

11 71. Counterclaimant was not responsible for fundraising events during her employ with

12 Counterdefendant.

13 72. Counterclaimant told Counterdefendant of her Heels & Hounds fundraising event

14 idea months after having developed the Heels & Hounds concept and months before organizing

15 and planning the event.

16 73. But for Counterclaimant’s decision to offer her Heels & Hounds concept to

17 Counterdefendant, Counterdefendant would never have known of the idea.

18 74. Counterdefendant did not develop, create or otherwise invent the Heels & Hounds

19 name.

20 75. Counterclaimant offered to share her Heels & Hounds concept with

21 Counterdefendant for the first time in 2014.

22 76. Counterclaimant requested a meeting with Counterdefendant in order to pitch her

23 Heels & Hounds event to Counterdefendant for the 2015 calendar year.

24 77. From 2015 to present, after the end of her employee relationship with the

25 Counterdefendant, Counterclaimant approached Counterdefendant on an annual basis to determine

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 1 whether Counterdefendant would like to be the beneficiary of her Heels & Hounds event.

2 78. From 2015 through 2018, Counterdefendant accepted Counterclaimant’s offer for

3 Counterdefendant to be the beneficiary of the Heels & Hounds event.

4 79. Counterclaimant obtained registration of her “Heels & Hounds” trademark in 2018.

5 80. Counterclaimant did not sign any document with Counterdefendant in 2015

6 regarding the ownership or use of her Heels & Hounds concept or event.

7 81. Counterclaimant did not sign a document with Counterdefendant in 2016 regarding

8 the ownership or use of her Heels & Hounds event.

9 82. Counterclaimant did not sign a document in 2017 regarding the ownership or use

10 of her Heels & Hounds event.

11 83. Counterclaimant applied for and was granted a registered trademark for the Heels

12 & Hounds mark by the Nevada Secretary of State in 2018. See Exhibit 1 to Plaintiff’s Complaint.

13 84. Counterclaimant began working on the 2019 Heels & Hounds event in early Spring

14 of 2018.

15 85. Counterclaimant signed a document in 2018 regarding the use of the Heels &

16 Hounds name in 2018 in Northern Nevada.

17 86. In 2018, Counterdefendant requested that Counterclaimant submit a proposal to

18 hold the Heels & Hounds event in 2019 for the benefit of Counterdefendant.

19 87. Counterdefendant then denied Counterclaimant’s offer to hold her Heels &

20 Hounds event for Counterdefendant.

21 88. Counterclaimant continued her efforts on the 2019 Heels & Hounds event all

22 through 2018.

23 89. In good faith and reliance on her registration and ownership of the Heels & Hounds

24 trademark, Counterclaimant continued to organize and plan her 2019 Heels & Hounds after

25 Counterdefendant indicated that they did not desire Counterclaimant to hold the event for them in
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 1 2019.

2 90. In good faith, Counterclaimant continued to organize and plan her Heels & Hounds

3 event for 2019 into early 2019 until she was prevented from pursuing her annual Heels & Hounds

4 fundraising efforts based on Counterdefendant initiating this lawsuit.

5 FIRST CAUSE OF ACTION

(Unfair Competition Based on Trade Name Infringement)
6

7 91. Counterclaimant repeats and realleges paragraphs 63 through 90 as though fully set

8 forth herein and incorporates the same by reference.

9 92. The Heels & Hounds trade name and logo are a valid and protectable mark

10 belonging to Counterclaimant. Counterclaimant has used the Heels & Hounds trade name and

11 logo since 2015, and the invention, creation and use of the trade name and logo by Counterclaimant

12 predates Counterdefendant’s use of the same. Counterclaimant’s consistent use of the Heels &

13 Hounds trade name for five years has come to denote Counterclaimant as the sole source, creator,

14 organizer and/or provider of the Heels & Hounds event.

15 93. Counterdefendant has made false representations, false descriptions and false

16 designations of, on, or in connection with the Heels & Hounds event. Counterdefendant’s actions

17 have caused and, unless enjoined by this Court, will continue to cause a likelihood of confusion

18 and deception of members of the public and, additionally, injury to Counterclaimant’s goodwill

19 and reputation, for which Counterclaimant has no adequate remedy at law.

20 94. Counterdefendant’s actions demonstrate an intentional, willful and malicious intent

21 to trade on the goodwill associated with Counterclaimant’s Heels & Hounds fundraiser to the great

22 and irreparable harm of Counterclaimant.

23 95. As a result of Counterdefendant’s conduct, Counterclaimant Quatro has suffered

24 damages in excess of $15,000, and has been compelled to incur attorney’s fees and costs to defend

25 herself in this action.

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 1 SECOND CAUSE OF ACTION
(Declaratory Relief – Ownership of Heels & Hounds Trade Name)
2
96. Counterclaimant repeats and realleges the allegations of all preceding paragraphs
3
as though fully set forth herein and incorporates the same by reference.
4
97. An actual controversy has arisen and now exists among Counterdefendant and
5
Counterclaimant in that Counterclaimant is the rightful owner of the Heels & Hounds trade name,
6
that Counterclaimant has proof of ownership of the same as recognized by the Nevada Secretary
7
of State; that the Plaintiff is not the owner of Heels & Hounds trade name, and that she rightfully
8
obtained and registered the trade name Heels & Hounds with the Nevada Secretary of State.
9
98. This is a proper action for declaratory relief in that the controversy among the
10
Counterdefendant and Counterclaimant involves determining ownership of the Heels & Hounds
11
trade name and whether Counterclaimant’s registered mark of that trade name was rightfully
12
obtained and registered with the Nevada Secretary of State.
13
99. A judicial determination in favor of Counterclaimant and against Counterdefendant
14
is warranted on the issues referenced above, and Counterclaimant is entitled to a declaratory
15
judgment on that basis.
16
THIRD CAUSE OF ACTION
17 (Preliminary and Permanent Injunction)

18 100. Counterclaimant repeats and realleges the allegations of all preceding paragraphs

19 as though fully set forth herein and incorporates the same by reference.

20 101. Counterclaimant has no adequate remedy at law for the injuries being suffered as a

21 result of Plaintiff’s actions and therefore requests an injunction on the same from the Court.

22 FOURTH CAUSE OF ACTION

(Wrongful Interference With Prospective Business Advantage)
23

24 102. Counterclaimant repeats and realleges the allegations of all preceding paragraphs

25 as though fully set forth herein and incorporates the same by reference.
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 1 103. Counterclaimant has a prospective contractual relationship with multiple

2 businesses to hold, host, donate toward and otherwise support the Counterclaimant’s 2019 Heels

3 & Hounds fundraiser.

4 104. Counterdefendant had knowledge of the prospective relationships between

5 Counterclaimant and various businesses and entities and has initiated this action to interfere with

6 her business efforts and advantages.

7 FIFTH CAUSE OF ACTION

(Business Disparagement)
8

9 105. Counterclaimant repeats and realleges the allegations of all preceding paragraphs

10 as though fully set forth herein and incorporates the same by reference.

11 106. Counterdefendant falsely and disparagingly represented to third-parties that

12 Counterclaimant is not the owner of the Heels & Hounds trade name.

13 107. Counterdefendant made these representations with the intent to harm

14 Counterclaimant’s reputation and her relationships with third-parties and to harm

15 Counterclaimant’s pecuniary interests.

16 108. Counterdefendant knew at the time it made these statements that they were false.

17 109. As a result of Counterdefendant’s false statements, Counterclaimant has suffered

18 damages in excess of $15,000 and has been compelled to incur attorney’s fees and costs to defend

19 herself in this action.

20 SIXTH CAUSE OF ACTION

(Defamation)
21

22 110. Counterclaimant repeats and realleges the allegations of all preceding paragraphs

23 as though fully set forth herein and incorporates the same by reference.

24 111. Counterdefendant has made false and defamatory statements concerning

25 Counterclaimant.
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 1 112. Counterdefendant has published the false and/or defamatory statements to a third

2 party(ies).

3 113. Counterdefendant was at least negligent in making the false and/or defamatory

4 statements.

5 114. Counterclaimant has sustained actual damages as a result of Counterdefendant’s

6 statements.

7 SEVENTH CAUSE OF ACTION

(Trade Name and/or Mark Infringement)
8

9 115. Counterclaimant repeats and realleges the allegations of all preceding paragraphs

10 as though fully set forth herein and incorporates the same by reference.

11 116. Counterclaimant has a protectable right in the Heels & Hounds mark as confirmed

12 by the Nevada Secretary of State.

13 117. Counterdefendant is aware of Counterclaimant’s registered right to the Heels &

14 Hounds mark.

15 118. Counterdefendant has infringed on Counterclaimant’s rights by attempting to

16 improperly use Counterclaimant’s registered trademark.

17 119. As a result of Counterdefendant’s actions, Counterclaimant has suffered damages

18 in excess of $15,000 and has been compelled to incur attorney’s fees and costs to defend herself

19 in this action.

20 EIGHTH CAUSE OF ACTION

(Unjust Enrichment)
21

22 120. Counterclaimant repeats and realleges the allegations of all preceding paragraphs

23 as though fully set forth herein and incorporates the same by reference.

24 121. Counterclaimant has a protectable right in the Heels & Hounds mark as confirmed

25 by the Nevada Secretary of State.

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 1 122. Counterdefendant is aware of Counterclaimant’s registered right to the Heels &

2 Hounds trademark.

3 123. Counterdefendant is attempting to use and benefit from a trademark, idea, concept

4 and event that belongs to Counterclaimant.

5 124. Counterdefendant has unjustly used and attempted to use Counterclaimant’s mark

6 for its own benefit.

7 125. Counterdefendant is attempting to use and benefit from an intellectual property

8 right that belongs to Counterclaimant.

9 126. As a result of Counterdefendant’s actions, Counterclaimant has suffered damages

10 in excess of $15,000 and has been compelled to incur attorney’s fees and costs to defend herself

11 in this action.

12 WHEREFORE, Defendant/Counterclaimant requests relief as follows:

13 1. That Plaintiff’s Complaint be dismissed with prejudice in its entirety.

14 2. That Defendant’s Counterclaim be granted by the Court.

15 3. That Defendant be awarded reasonable attorney’s fees and costs incurred in

16 defending this matter;

17 4. For such other and further relief as the Court deems just and proper in the premises.

18 AFFIRMATION PURSUANT TO NRS 239B.030. The undersigned does hereby affirm

19 that the preceding document does not contain the social security number of any person.

20 DATED this 1st day of March 2019.

21 /s/ Whitney Derrah

WHITNEY DERRAH, NV. BAR NO. 9763
22 ARGENTUM LAW
Attorney for Christi Quatro
23

24

25
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 1 CERTIFICATE OF SERVICE

2 Pursuant to NRCP 5(b), I certify that I am an employee of ARGENTUM LAW, and that

3 on the 1st day of March 2019, I

4 deposited for mailing in the U.S. Mail, with sufficient postage affixed thereto

5 sent via Federal Express or other overnight delivery service

6 delivered via email to:

7 personally delivered

8 caused to be delivered via Reno-Carson Messenger Service

9  served through the Court’s electronic notification system

10
the foregoing document addressed to:
11
Elizabeth J. Bassett, Esq.
12 John D. Tennert, Esq.’
FENNEMORE CRAIG, P.C.
13 300 E. Second Street, Suite 1510
Reno, NV 89501
14

15

16 /s/ Sharon Ellis

Sharon Ellis
17 ARGENTUM LAW

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