FILED

Electronically
CV19-00250
2019-02-08 03:47:00 PM
Jacqueline Bryant
1 1670 Clerk of the Court
John D. Tennert, Esq. (SBN 11728) Transaction # 7110698 : yviloria
2 Elizabeth J. Bassett, Esq. (SBN 9013)
FENNEMORE CRAIG, P.C.
3 300 E. Second Street, Suite 1510
Reno, Nevada 89501
4 Tel: 775-788-2234 Fax: 775-786-1177
jtennert@fclaw.com; ebassett@fclaw.com
5
Attorneys for Plaintiff Nevada Humane Society
6
IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA
7 IN AND FOR THE COUNTY OF WASHOE
8 NEVADA HUMANE SOCIETY, a Nevada CASE NO.: CV19-00250
9 non-profit corporation,
DEPT. NO.: 9
10 Plaintiff,
vs.
11
CHRISTI QUATRO, an individual and doing
12 business as BIG FISH CONSULTING; and
13 DOES 1 through 10, inclusive,

14 Defendants.

15 EX PARTE MOTION FOR ORDER SHORTENING TIME ON

MOTION FOR ORDER TO SHOW CAUSE RE: CONTEMPT
16

17 Plaintiff Nevada Humane Society, by and through its counsel of record, Fennemore Craig

18 P.C., files this Ex Parte Motion for Order Shortening Time concurrently with its Motion for

19 Order to Show Cause Re: Contempt. This Motion is supported by the following memorandum of

20 points and authorities and all pleadings and papers on file herein.

21 Pursuant to WDCR 11(3), counsel for Nevada Humane Society provided notice to

22 counsel for Defendant, Whitney Derrah, Esq., that Plaintiff would be filing its Ex Parte Motion

23 on today’s date. See Declaration of Elizabeth J. Bassett, attached hereto as Exhibit 1 and

24 Exhibit 1 thereto.

25 MEMORANDUM OF POINTS AND AUTHORITIES

26 As set forth in more detail in its Motion for Order to Show Cause re: Contempt,

27 Defendant Christi Quatro violated this Court’s February 4, 2019 (1) Order Granting Ex Parte

28 Temporary Restraining Order and (2) Order Setting Hearing on Motion for Preliminary

300 E. SECOND ST. 14602862

SUITE 1510
RENO, NEVADA 89501
775-788-2200
 1 Injunction (“Order”) after receiving notice of and being served with the Order Ms. Quatro
2 posted a Facebook announcement promoting her own Heels & Hounds event and linked to a
3 webpage in which she repreatedly references that she owns the Heels & Hounds name and event.
4 The post also shows that she has contacted a number of third-parties regarding her Heels &
5 Hounds event.
6 This violation of this Court’s Order by Ms. Quatro is seriously damaging to both Nevada
7 Humane Society and the viability and profitability of its Heels & Hounds fundraiser–which is the
8 exact harm that the Order was meant to prevent. If Ms. Quatro’s actions go unchecked and if she
9 further violates the TRO, this damage could become irreparable and Nevada Humane Society’s
10 ability to hold this fundraiser in the future and to fund its nonprofit objectives will be
11 permanently damaged, if it hasn’t been already. It is crucial that Ms. Quatro’s contempt by
12 addressed by this Court as soon as possible.
13 Nevada Humane Society therefore respectfully requests that Ms. Quatro be required to
14 respond to its Motion for Order to Show Cause re: Contempt within the shortest period of time
15 this Court deems possible and appropriate under the circumstances and that this Court hold a
16 hearing on Nevada Humane Society’s Motion within the shortest period of time this Court deems
17 possible and appropriate under the circumstances.
18 AFFIRMATION
(Pursuant to NRS 239B.030)
19
The undersigned does hereby affirm that the foregoing does not contain the social
20
security number of any person.
21

22 DATED: February 8, 2019.

23 FENNEMORE CRAIG, P.C.

24 By: /s/ Elizabeth J. Bassett

John D. Tennert, Esq.
25
Elizabeth J. Bassett, Esq.
26 Attorneys for Plaintiff Nevada Humane Society

27

28
300 E. SECOND ST. 2
SUITE 1510 14602862
RENO, NEVADA 89501
775-788-2200
 1 CERTIFICATE OF SERVICE
2 Pursuant to Nev. R. Civ. P. 5(b) and N.E.F.R. 9(b)(d), I certify that on February 8, 2019,
3 a true and correct copy of the EX PARTE MOTION FOR ORDER SHORTENING TIME
4
ON MOTION FOR ORDER TO SHOW CAUSE RE: CONTEMPT, was electronically
5
served via the court’s electronic filing system to the following attorney(s) associated with this
6
case. If the following person(s) is not registered with the court’s e-filing system, then a true and
7

8 correct paper copy of the above-named document was served via U.S. Mail to the following:

9
Whitney Derrah, Esq.
10 ARGENTUM PARTNERS
6121 Lakeside Drive, Suite 208
11 Reno, NV 89511
whitney@argentumnv.com
12

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15
/s/ Pamela Carmon
16 An Employee of Fennemore Craig, P.C.

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300 E. SECOND ST. 3
SUITE 1510 14602862
RENO, NEVADA 89501
775-788-2200
 1 EXHIBIT INDEX
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DESCRIPTION NO. OF EXHIBIT
3 PAGES
Declaration Elizabeth J. Bassett 7 1
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300 E. SECOND ST. 4
SUITE 1510 14602862
RENO, NEVADA 89501
775-788-2200