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Complainant: case number 24-CR-043543 (District Attorney Case Number 202421350C)
Complaint upon Brian J. Koechvar # 5691- Deputy District Attorney, Nevada
200 Lewis Ave. Las Vegas, NV 89155 | (702) 671-2583
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Subject: Formal Complaint Against Deputy District Attorney “Brian J. Koechvar # 5691” for Ethical and Professional Misconduct
This complaint arises from serious misconduct, professional negligence, and violations of the Nevada Rules of Professional Conduct (RPC), especially in connection with the failure to disclose material exculpatory evidence in violation of due process, Brady violation concern Brady v. Maryland, 373 U.S. 83 (1963).
Nature of Misconduct:
The DDA Brian J. Koechvar # 5691 submitted a criminal complaint, signed under penalty of perjury, that omitted key material facts. Specifically, the alleged victim stated no fewer than four times in her voluntary statement to the LVMPD that her vehicle was in reverse at the time of our collision. This fact is central to determining fault and disproving criminal intent. Despite its relevance, this information was entirely excluded from the police reports and the criminal complaint signed under perjury by Brian J. Koechvar # 5691.
This omission deprived me of a fair and honest charging process. The DDA’s obligation under Brady v. Maryland, 373 U.S. 83 (1963), and RPC 3.8(d) was to disclose any evidence that tends to negate guilt — and this was flagrantly disregarded.

Violations of Nevada Rules of Professional Conduct:
RPC 3.8 – Special Responsibilities of a Prosecutor:
• Subsection (a): Refraining from prosecuting a charge that the prosecutor knows is not supported by probable cause.
• Subsection (d): Failing to make timely disclosure to the defense of all evidence known to the prosecutor that tends to negate guilt.
RPC 8.4 – Misconduct:
• Subsection (c): Engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation.
• Subsection (d): Conduct that is prejudicial to the administration of justice.

Further Concerns:
The failure to include the victim’s reverse movement was not a minor oversight. This fact was directly linked to who was at fault in the alleged incident and, if known, would have negated probable cause entirely. The three officers involved — L. Chavez (Badge #14486), J. Lefler (Badge #14645), and Detective Conry — also excluded this information, but DDA Brian J. Koechvar # 5691 had an independent duty to review and correct those omissions before filing charges.
Moreover, DDA’s Brian J. Koechvar # 5691 presentation of a version of events that contradicts the victim’s own words undercuts the foundation of the entire prosecution. These actions reflect either:
• Intentional misrepresentation,
• Negligent failure to investigate,
• Or reckless indifference to justice.

I am submitting this detailed complaint to request a formal investigation into serious civil rights violations and prosecutorial misconduct committed Brian J. Koechvar # 5691.
Brian J. Koechvar # 5691 omitted critical exculpatory evidence from the formal criminal complaint filed against me, in violation of Brady v. Maryland and the Nevada Rules of Professional Conduct. The omission revolves around the fact that the alleged victim stated on four separate occasions in her voluntary statement that her vehicle was in reverse at the exact moment of impact during a traffic incident involving my vehicle.
This key fact was not mentioned in any of the following:
• The police incident report
• The traffic report prepared by Officer Lefler
• The Brian J. Koechvar # 5691 criminal complaint signed under penalty of perjury
Instead, a version of events was presented that implied I was the sole cause of the collision and that my actions were intentional, reckless, and felonious. This portrayal was not only false but legally unsupported once the reverse movement of the other party is considered.

The omissions violate:
• Brady v. Maryland, 373 U.S. 83 (1963): Failure to disclose evidence favorable to the accused that is material to guilt or punishment
• Nevada RPC 3.8(a): Prosecuting a charge not supported by probable cause
• Nevada RPC 3.8(d): Failing to disclose exculpatory evidence
• RPC 8.4(c): Engaging in conduct involving dishonesty, fraud, deceit, or misrepresentation
• RPC 8.4(d): Conduct prejudicial to the administration of justice
In addition to Brian J. Koechvar # 5691 DDA’s actions, the traffic investigator, Officer J. Lefler, failed to create or submit a diagram showing how the accident occurred — a standard duty in such traffic-related incidents. This failure further deprived me of a clear reconstruction of the scene and minimized accountability for the other party's unsafe reverse driving.
Further, under Nevada law NRS 484B.117, backing a vehicle must only occur when it is safe and does not interfere with other traffic. The alleged victim violated this statute by reversing into a narrow driveway lane at a time when I was attempting to exit the premises and addmitted it in her signed statement to the police. I attempted to avoid the collision but was unable to do so in time. This shows a clear lack of criminal intent on my part and shifts liability to the reversing party — a view supported by insurance standards that assign fault to drivers ...
Despite these facts, I am currently facing a felony charge for Battery with Use of a Deadly Weapon Resulting in Substantial Bodily Harm — a charge that carries extreme penalties and reputational damage. There is no mention in the complaint of Brian J. Koechvar # 5691 mentioning the reversing vehicle, the spatial limitations of the location, or my effort to avoid the crash. Instead, the DDA Brian J. Koechvar # 5691 proceeded with a misleading complaint that contradicts both the physical evidence and the victim’s own statements.

Requested Action:
I respectfully request that the Nevada State Bar and/or the Nevada Attorney General’s Office Public Integrity Unit initiate a full investigation into the prosecutorial actions in this matter and determine whether civil rights violations or disciplinary actions are warranted.
I am prepared to provide:
• The full voluntary statement from the victim
• The criminal complaint
• Traffic and officer reports
• My written narrative
• All related documentation showing the omissions
The omissions described above have placed an unjust and defamatory criminal charge on my name, created emotional and legal hardship, and represent a breach of both professional duty and public trust.
“The victim, in her own signed written statement, said multiple times she was in reverse at the time of the incident. That fact goes directly to the issue of intent and contradicts the charges.”
“None of the officers included that key fact in their narratives, and the complaint filed by the DDA Brian J. Koechvar # 5691 made it appear as though the victim was stationary, which is misleading.”

“This involves a material omission by officers and the DDA Brian J. Koechvar # 5691 that affects my constitutional rights.”

In my complaint against DDA Brian J. Koechvar # 5691 for unethical violations and misconduct stem from the victim’s voluntary written statement and is clearly Brady material because:
• She admitted multiple times she was in reverse, which contradicts Brian J. Koechvar # 5691 claim that I intentionally rammed her.
• That fact supports a possible accident or at least reasonable doubt about intent.
• It was omitted from the criminal complaint by Brian J. Koechvar # 5691 and every police narrative — despite being in their possession.
If Brian J. Koechvar # 5691 knew about this and failed to provide it (or knowingly used a misleading complaint), that could be:
A Brady violation
A due process violation under the 5th and 14th Amendments
Grounds for disciplinary action or corrective measures on Brian J. Koechvar # 5691

Inconsistent Statements = Fabrication / Misrepresentation
• The District Attorney, in collusion with the officers, submitted a version of events that:
◦ Omitted the victim’s 4 statements.
◦ Contradicted the actual sequence of events described by the victim.
• Presenting altered or incomplete facts to the court to establish probable cause constitutes:
◦ Misrepresentation of material facts.
◦ Potential prosecutorial misconduct.
◦ A due process violation under Giglio v. United States, 405 U.S. 150 (1972).

Additional Grounds for Disciplinary Action
• Selective presentation of facts to justify arrest and charging is a due process violation.
• If knowingly done, DDA Brian J. Koechvar # 5691 and officers may be liable for:
◦ Abuse of process.
◦ Malicious prosecution.
◦ Violation of ethical obligations under Nevada Rules of Professional Conduct (e.g., Rule 3.8 – Special Responsibilities of a Prosecutor).
• The totality of the misconduct casts doubt on the credibility of the entire prosecution narrative.
This complaint to this Nevada State Bar should be seriously reviewed because:
• Critical exculpatory evidence was withheld by Brian J. Koechvar # 5691 (Brady violation).
• The victim was clearly at fault based on traffic law (NRS 484B.113) and standard liability.
• The DDA and officers presented a knowingly incomplete and misleading case.
• The actions of all involved violate due process, legal ethics, and constitutional rights.
• No legally sufficient probable cause exists under the Fourth and Fourteenth Amendments to proceed.
This complaint against Brian J. Koechvar # 5691 seeks investigation due to:
1. The intentional and material omission of exculpatory evidence by Brian J. Koechvar # 5691 - in violation of Brady v. Maryland;
2. The victim’s clear violation of NRS 484B.113, rendering her the proximate cause of the collision;
3. The presentation of altered or false narratives by the Deputy District Attorney Brian J. Koechvar # 5691 and officers;
4. A lack of legally sufficient probable cause to support the charges; of Brian J. Koechvar # 5691
5. The professional misconduct of Brian J. Koechvar # 5691, the prosecuting authority in initiating and maintaining these charges.

STATEMENT OF FACTS
1. The incident underlying the charge, involving a traffic collision between the Defendant and the alleged victim.
2. The alleged victim was at the time actively backing up into a lane of travel, contrary to NRS 484B.113(2).
3. The victim made four separate admissions, captured on scene or noted by witnesses, including:
◦ She was in reverse at the moment of impact.
◦ She was attempting to reposition her vehicle.
◦ She did not see the other vehicle approaching.
◦ She entered the flow of traffic against the natural direction.
4. These statements were knowingly omitted by three officers (Badge Nos. [Insert]) in their written reports, body cam summaries, and testimony presented to Brian J. Koechvar # 5691 D District Attorney.
5. Brian J. Koechvar # 5691, relying on this incomplete record, submitted a charging affidavit and probable cause narrative that misrepresented key facts to the court.
LEGAL ARGUMENT
A. Brady Violation – Suppression of Exculpatory Evidence
Under Brady v. Maryland, the suppression by the prosecution of evidence favorable to an accused violates due process where the evidence is material either to guilt or to punishment.
• The victim’s four admissions directly support the Defendant’s innocence and undermine any theory of criminal intent or recklessness.
• The failure to disclose or document these facts constitutes a clear Brady violation, especially when law enforcement acted in concert with the prosecuting office ie: Brian J. Koechvar # 5691.
Misrepresentation of Facts and Prosecutorial Misconduct
• The prosecution Brian J. Koechvar # 5691 submitted a version of the events that deliberately excluded the exculpatory details from the victim’s own mouth.
• This constitutes:
◦ Misrepresentation of material facts to the court.
◦ Violation of Rule 3.8 of the Nevada Rules of Professional Conduct.
◦ Potential abuse of process and malicious prosecution under Nevada tort law.
◦ A violation of Giglio v. United States, 405 U.S. 150 (1972), which extended Brady to impeachment evidence and false testimony.
The charges in this case are built upon:
• A fabricated and incomplete record;
• A clear Brady violation;
• A failure to establish probable cause;
• The victim’s own unlawful conduct as the true cause of the incident;
• Misconduct by law enforcement and prosecutorial authorities.
Breakdown of the Omission by Brian J. Koechvar # 5691 and Its Impact
What the Complaint Says (Lines 17–21):
“…did willfully, unlawfully, and feloniously use force or violence upon the person of [victim] with use of a deadly weapon, to wit: a vehicle, by intentionally driving into and/or crashing into a vehicle occupied by the said [victim] resulting in substantial bodily harm…”
⚠️ What's Missing:
• No mention that the alleged victim was driving in reverse at the time of the crash.
• No context about how the cars were positioned or moving.
• No mention that the victim was trying to escape and was moving backward across the lot, increasing the possibility of a collision or confusion.
• No mention of the possibility that the contact was not an aggressive act, but a consequence of the reverse movement combined with my forward movement or my attempt to leave.
Legal Relevance
The omission of her reversing at the time of impact is potential Brady material:
• Under Brady v. Maryland, the prosecution Brian J. Koechvar # 5691 must disclose all exculpatory evidence.
• This omission could be seen as presenting a one-sided, misleading version of events to obtain charges.
It also affects:
• Intent – I may not have “willfully” used the car as a weapon if she was reversing.
• Causation – Her movement in reverse could have contributed significantly to the collision.
• Credibility – Her statement contradicts the clean-cut version the police and Brian J. Koechvar # 5691 gave the court.
:
1. DDA Brian J. Koechvar # 5691 swore under oath that the complaint is true — but it misrepresents the facts as documented in the victim’s own words.
2. That’s Brady material — potentially a violation of my due process rights because
◦ This was not disclosed to the honorable court or my attorney in full,
◦ Or they used it to withhold or misstate material evidence in front of a judge.
3. This can be used to:
◦ Undermine probable cause
◦ Challenge the credibility of the complaint
◦ Possibly move to dismiss or reduce charges
LEGAL ISSUES ALREADY EVIDENT:
• Omission of reversing movement: If she was driving, especially in reverse, it may void or mitigate claims of intentional ramming.
• Photos show damage consistent with low-speed collision or shared movement, not a high-speed intentional attack.
• DDA Brian J. Koechvar # 5691 seem to cherry-pick victim’s fears without documenting the full context she gave.
FINAL ANALYSIS: Misrepresentation and Omission of Key Facts by Brian J. Koechvar # 5691 (Misconduct, Negligence)
📌 Allegation:
I am being charged with:
• Battery with use of a deadly weapon resulting in substantial bodily harm (SBH)
• Intentional ramming of a vehicle with malice or force
🧾 Evidence Presented in the Police Narrative and DDA Brian J. Koechvar # 5691 Complaint (Pages 1–6):
• Describes me as “speeding,” “targeting,” and “ramming” her.
• Mentions she was in her vehicle and scared.
• Cites rear-end and side vehicle damage.
• Includes no crushed rear bumper damage only scrapes and a pried off bumper shown on her car.
• Says the victim was yelling and fearful.
• Nowhere mentions that she was reversing.
MAJOR ISSUES FOUND:
🔴 1. Omission of Key Victim Admission by DDA Brian J. Koechvar # 5691:
Victim repeatedly states in her own words:
“I’m in REVERSE trying to avoid the impact…”
“I hurried up and put the car in REVERSE TO AVOID THE HEAD ON.”
“I finally get backed up enough I could clear the exit gate…” “At the point that I was in reverse the driver hits the car...”
🔻 Yet this is completely absent from:
• The DDA Brian J. Koechvar # 5691 formal complaint
• The officer’s sworn narrative
• The “modus operandi” and investigative summary
🔒 Legal Impact: This omission conceals exculpatory evidence that directly affects whether my actions were criminal or part of a shared vehicle movement scenario — possibly even self-defense or accident.
Summary for your investigation on Brian J. Koechvar # 5691
The victim in this case stated repeatedly in her own signed voluntary statement (March 7, 2024) that she was in reverse at the time of the impact.
This crucial fact was omitted from all subsequent law enforcement and Brian J. Koechvar # 5691 DDA filings, including:
• The formal criminal complaint dated May 15, 2024,
• The investigation report by Officer S. Conry (pages 1–6),
• And the Modus Operandi/Narrative section.
The omission of the victim’s reversing undermines the State’s narrative of an intentional ramming and instead introduces the possibility of mutual vehicle movement and/or accident.
Furthermore, photos provided show no front-end damage to the alleged suspect vehicle, inconsistent with a “high-speed intentional attack.”
This constitutes material exculpatory evidence, potentially falling under Brady v. Maryland, and I request that an investigation be conducted.
Legal Grounds for Misconduct by Brian J. Koechvar # 5691
⚖️ 1. Brady v. Maryland Violation (U.S. Const. Amend. XIV)
• Officers L. Chavez (Badge #14486), Traffic Officer J. Lefler (Badge #14645), and Detective Conry in concert with Brian J. Koechvar # 5691 all failed to disclose material exculpatory evidence — the victim stated four separate times that her car was in reverse at the time of the collision.
• Under Brady v. Maryland, 373 U.S. 83 (1963), the government is obligated to disclose evidence favorable to the defense that is material to guilt or punishment.
• The omission of this key fact violates due process and undermines the fairness of the proceeding.
🛑 2. False or Misleading Probable Cause Affidavit (Perjury Concern)
• The criminal complaint signed by the DDA (referred to as “Brian J. Koechvar # 5691”) under penalty of perjury completely omits the reversing detail, despite it being central to fault.
• Presenting a one-sided narrative that omits exonerating evidence is misleading, and could amount to a form of constructive fraud or malicious prosecution.
🚔 3. Professional Misconduct / Negligence by DDA Brian J. Koechvar # 5691
• Brian J. Koechvar # 5691 failed to report, diagram, or document the victim's car reversing into oncoming traffic.
• Traffic Officer Lefler, whose role includes scene investigation, neglected to create a collision diagram showing the position and direction of the vehicles at impact.
• This failure to preserve and disclose critical scene evidence constitutes gross negligence and may rise to dereliction of duty or official misconduct under NRS 197.200.
• Under Nevada criminal law, battery with a deadly weapon causing substantial bodily harm requires specific intent — which is absent here.
• My behavior shows an effort to avoid harm, not cause it.
📋 6. Insurance Liability Standard (Civil Perspective)
• Auto insurance carriers determine fault based on right-of-way and hazardous movement.
• In virtually all jurisdictions, a vehicle backing into traffic is presumed liable, especially when the oncoming vehicle is traveling straight and lawfully.
• If this had been an insurance claim, the reversing driver would have been assigned 100% fault.
🧾 7. Statements Presented by Brian J. Koechvar # 5691 Do Not Match Victim’s Own Words
• Officers’ and DDA’s version of events omit or mischaracterize the victim’s voluntary statement.
• When the Deputy District Attorney filters or alters factual accounts, it undermines judicial integrity and may constitute misfeasance or reckless disregard for truth.

📌 Conclusion: Grounds for Investigation and Discipline on Brian J. Koechvar # 5691
• There is no probable cause when:
◦ Material exculpatory facts are deliberately omitted.
◦ There is no evidence of intent to commit a crime.
◦ The only eyewitness (the alleged victim) admits her vehicle was in reverse — creating the hazard.
• The omissions by DDA has tainted the charging process, and continuing the case violates your constitutional rights.
• The totality of the evidence — especially when accurately presented — does not support a reasonable belief that a crime was committed by me.

Why This Is Critical:
Since this declaration is made under penalty of perjury, omitting material exculpatory facts — like the victim admitting she was in reverse at the time of the crash — raises serious legal and ethical red flags.

Key Finding:
The criminal complaint omits the victim's critical admission that she was driving in reverse at the time of impact, despite that being clearly and repeatedly stated in her own signed statement.
This is not just a minor omission — it fundamentally alters the nature of the incident and presents a false or incomplete narrative to the court.

THEREFORE AND RESPECTFULLY,

I urge you to conduct a thorough, independent, and nonbiased review of the prosecutorial conduct detailed in this complaint. The integrity of our legal system depends on prosecutors upholding their duty to pursue justice, not convictions at any cost. When a prosecutor knowingly proceeds with charges based on incomplete, misleading, or selectively omitted evidence, it is not just a lapse in professional judgment — it is a betrayal of public trust and a direct assault on due process. This is not a matter of differing interpretations, but of objective omissions of material facts that any reasonable attorney would recognize as exculpatory. I respectfully expect the Bar to take this matter with the gravity it deserves and to take corrective and disciplinary action where violations are found.

Tags	deputy district attorney Brian J. Koechvar
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