1. Federal Statutory & Criminal Violations (U.S. Code)

• 18 U.S.C. § 1343 (Interstate Wire Fraud): – Utilizing interstate electronic communications (e-filing systems, email, electronic service) to execute a scheme to defraud or transmit fraudulent declarations to a tribunal.
• 18 U.S.C. § 1001 (Statements or Entries Generally): – Knowingly submitting false or fraudulent statements in matters within the jurisdiction of the federal government or connected regulatory agencies.

2. Nevada Criminal Statutes (Nevada Revised Statutes)

• NRS 199.480 – Conspiracy: when two or more persons agree to commit an unlawful act (Category B Felony).
• NRS 199.120 & § 199.145 – Perjury, Subornation of Perjury & False Declarations: Executing and offering false material statements under oath or written declaration in judicial proceedings (Category D Felony).
• NRS 199.210 – Offering False Evidence: Knowingly offering and presenting false or perjured written documents, declarations, and affidavits into evidence in a court proceeding (Category D Felony).
• NRS 199.220 – Destroying or Concealing Evidence / Obstructing Process: Concealing or suppressing corporate alter-ego status, operational records, or service details to frustrate judicial discovery or service of process.
• NRS 199.480 – Criminal Conspiracy: Conspiring to obstruct justice, suborn perjury, or commit fraudulent acts in judicial proceedings.

3. State Bar of Nevada Grievances & Professional Violations

• NRPC Rule 1.2(d) (Scope of Representation): Prohibits a lawyer from assisting or advising a client to engage in conduct that the lawyer knows is criminal or fraudulent.
• NRPC Rule 3.1 (Meritorious Claims and Contentions): Prohibits bringing or defend a proceeding, or assert or controvert an issue therein, unless there is a basis in law and fact for doing so that is not frivolous, which includes a good faith argument for an extension, modification or reversal of existing law.
• NRPC Rule 3.3 (Candor Toward the Tribunal): Prohibits making false statements of material fact or law to a tribunal, and prohibits offering or failing to withdraw evidence known to be false.
• NRPC Rule 3.4 (Fairness to Opposing Party and Counsel): Prohibits obstructing another party's access to evidence, altering or concealing material documents, or assisting in giving false testimony.
• NRPC Rule 5.1 (Responsibilities of Partners, Managers, and Supervisory Lawyers): Mandates that a partner in a law firm, and a lawyer who individually or together with other lawyers possesses comparable managerial authority in a law firm, shall make reasonable efforts to ensure that the firm has in effect measures giving reasonable assurance that all lawyers in the firm conform to the Rules of Professional Conduct
• NRPC Rule 8.4(c) (Misconduct): Prohibits engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation.
• NRPC Rule 8.4(d) (Prejudice to Justice): Prohibits engaging in conduct that is prejudicial to the administration of justice.
NRCP Rule 11 & EDCR Local Rules: Under Nevada Rules of Civil Procedure Rule 11, local counsel’s signature on filed papers certifies that the factual contentions have evidentiary support. Filing false declarations or frivolous oppositions exposes McDonald Carano to mandatory monetary sanctions, fee awards, and striking of pleadings.

PENDING PROCEEDINGS: TWO FORMAL MOTIONS FOR TERMINATING AND PUNITIVE SANCTIONS (NRS 7.085)

Due to the pervasive, continuous, and coordinated subornation of perjury, bad-faith litigation tactics, fraudulent submittals, and procedural extortion executed by defense counsel and corporate respondents, there are currently two separate formal motions for terminating and punitive sanctions pending before the Court:

• First Motion for Terminating and Punitive Sanctions: Filed against all named Defendants and defense counsel pursuant to NRS 7.085 (liability of attorney for maintaining frivolous, fraudulent, or bad-faith filings) and the inherent powers of the Court, seeking the immediate strike of defense pleadings, entry of default judgment, and punitive monetary assessments.
• Second Motion for Terminating and Punitive Sanctions: Filed as a standalone, targeted motion directly addressing the subsequent bad-faith maneuvers, continued reliance on known perjured declarations, manufactured procedural delays, and extortionate demands conditioning the withdrawal of moot filings upon the unlawful surrender of private web domains.

All substantive hearings on both pending terminating sanctions motions are presently stayed and awaiting immediate calendar setting upon final determination of the pending judicial disqualification proceedings scheduled for September 16, 2026.