Alleged facts

  1. Joseph Hong (NV Bar #5995) filed written false statements, filed frivolous unsupported harassing pleadings, knowingly made false verbal statements, made fraudulent misrepresentations of material facts, concealed/failed to disclose material facts, conspired with others, received or transferred ill-gotten proceeds for his own benefit or for the benefit of clients or co-conspirators, on multiple dates, as evidenced by court and property records included in Exhibit 1:
  2.  6/9/15 DEED, Jimijack’s recorded deed is inadmissible pursuant to NRS 111.345 as fraught with notarial violations. See 1/17/17 Tobin declaration. See 4/10/19 stricken Tobin motion for summary judgment. See Tobin 2/1/17 unheard AACC vs. Jimijack.
  3. 6/16/15 COMP:  Jimijack complaint sued Bank of America that had no recorded interest and did not sue Nationstar that did. Hong never served the complaint on the HOA and never submitted these claims, the only ones filed on behalf of Jimijack, to mediation per NRS 38.310. Hong never filed any NRCP 16.1 disclosures and so there is no evidence in the record to support that Jimijack is a legal entity (No trust instrument); no deed to replace Jimijack’s defective deed; no evidence to refute the HOA ownership record, the Resident Transaction Report, that shows that Jimijack took possession as the second owner of the property on 9/25/14, and that there is no record of either  of Hong’s current or past clients, F. Bondurant LLC or Opportunity Homes, LLC ever having been owners of the property.
  4. 8/12/15, Summons to Bank of America is to the wrong address
  5. 10/16/15 JDDF judgment of default vs. Bank of America was recorded by Hog on 12/1/15 but no notice of entry of order was ever filed. NRS 40.110 prohibits a court from making a quiet title determination without an evidentiary hearing. Nationstar attorney Edgar Smith lied about knowing about this recorded order when he filed the 4/12/16 motion to set aside the BANA default and substitute Nationstar for BANA as the real party in interest.
  6. 6/8/16 AFFD, In an affidavit to support an order shortening time, Joseph Hong made statements in paragraphs4, 5, 6, 7, 8, 9, 10, and 11 that are were known to be false and are contradicted by other records.
  7.  8/30/16 OPPM, Hong opposed the Tobin/Hansen 7/29/16 motion to intervene because the proposed pleadings weren’t attached. Hong did not oppose Nationstar’s 4/12/16 motion to intervene on the basis of no attached pleadings. On 4/23/19, Joseph Hong misinformed the court that the 7/29/16 MINV Tobin/Steve Hansen motion to intervene into A-16-730078-C had been granted, but that the 11/15/16 MINV of Nona Tobin, an individual, and trustee of the Gordon B. Hansen Trust, dated 8/22/08, had been denied. Hong’s statements are contradicted by the record: 9/29/16 minutes, 9/29/16 RTRAN, 9/29/16 minutes, On 9/23/16 AFFD, Tobin filed a sworn affidavit that includes a challenge to both Jimijack’s and Nationstar’s standing, but Hong and the court ignored it at the 9/29/16 hearing. Hong did not prepare the order as instructed by the court. Later in 2018, Akerman attorneys’ awareness of this 9/23/16 AFFD, refused to join Tobin in a motion for summary judgment to void the HOA sale, for the sole improper purpose of stealing Tobin’s property without foreclosing in the manner required by NRS 107.080.
  8. 12/5/16 OPPM:  Hong’s opposition to Tobin/Hansen Trust 11/15/16 MINV. Again, the court record shows the falsity of Hong’s claims: 12/20/16 minutes, 12/20/16 RTRAN,
  9. 3/13/17 RCCM: In Hong’s opposition to Tobin/Hansen Trust’s 2/1/17 AACC. Hong did not enter into the court record any evidence to refute the Tobin/Hansen Trust’s claims against Jimijack in the 3/13/17 RCCM or at any other time. Hong did not produce a new deed to replace Jimijack’s 6/9/15 dee that was inadmissible per NRS 111.345. Hong did not ever move the court to admit the Jimijack deed. Hong prepared a defective 6/24/19 order that falsely claimed that the causes of action in the Nona Tobin’s 2/1//17 AACC vs. Jimijack were adjudicated at trial when they were not addressed at all. Hong did not file any counter claims vs. Tobin or the Hansen Trust in his 3/13/17 RCCM or at any other time.
  10.  3/13/17 RCCM:  Hong’s equally vacuous response to Tobin/Hansen Trust’s 2/1/17 CRCM cross-claim vs. Yuen K. Lee dba F. Bondurant LLC did not refute any of the claims vs. Lee and never produced any evidence and never served any NRCP 16.1 disclosures. Hong did not file any cross- claims vs. Tobin or the Hansen Trust on behalf of Yuen K. Lee dba F. Bondurant LLC in his 3/13/17 RCCM. Hong prepared a defective 6/24/19 order that falsely claimed that the causes of action in the Nona Tobin’s Tobin/Hansen Trust’s 2/1/17 CRCM cross-claim vs. Yuen K. Lee dba F. Bondurant LLC were adjudicated at trial when they were not addressed at all. Neither Lee nor F. Bondurant LLC are listed in the HOA property records as ever having owned the subject property. Hong did not disclose that he has a controlling interest in F. Bondurant LLC or that he is the one who got CluAynne M. Corwin to fraudulently use her notary stamp to witness Yuen K. Lee to execute Jimijack’s deed as if Thomas Lucas stood before her.
  1.  12/5/18, DISC Joseph Hong prepared Joel Stokes’ response to Tobin’s interrogatories. This defective, deceptive, duplicitous response is Hong’s only entry of “evidence” into the court record in any eight court cases related to the dispute over the title to the subject property from 6/16/15 to the present.
  1.  3/25/19 RCCM On 3/25/19, Joseph Hong finally provided a response to Nationstar’s 6/2/16 AACC, but only after Nationstar filed on 3/18/19 a NITD notice of intent to take default and a motion for summary judgment on 3/21/19 MSJ (See also 3/21/19 MSJ pages 1-9 annotated. Hong did not file any counter-claims against Nationstar  in this 3/25/19 RCCM – or ever. On 4/12/19 NS, Hong and Morgan served notice of a Jimijack-Nationstar “settlement”, but Hong never filed any claims against Nationstar on behalf of Jimijack to “settle”. Nationstar never took default against Jimijack in three years of non-response. Nationstar withdrew its MSJ vs. Jimjack on 4/23/19 NWM immediately after Hong and Morgan’s ex parte meeting with Judge Kishner had succeeded in obstructing any judicial scrutiny of Tobin’s evidence (See 4/17/19 stricken reply to support Tobin joinder to Nationstar’s MSJ vs. Jimijack) and had obstructed the adjudication of Tobin’s two motions for summary judgment (Tobin stricken MSJ vs. Jimijack and the Tobin stricken MSJ vs. all parties) in the pro se filings stricken at the 4/23/19 hearing held ex parte due to Hong’s deceptive 4/15/19 SAO and 4/22/19 NTSO notices that the hearing was continued to 5/7/19.
  2.  3/26/19 Minutes (Hong’s oral motion to join MSJ was denied) are it is proved by the transcripts: 3/26/19 RTRAN,  3/26/19 annotated transcript),
  3. Hong served notices through the Court eFile Odyssey system that the 4/23/19 hearing was continued, but then met ex parte anyway:  4/15/19 SAO (notice served of order to continue 4/23/19 hearing),  4/22/19 NTSO (notice of entry of order to continue 4/23/19 hearing),   4/23/19 minutes (continued 4/23/19 hearing held ex parte) Hong lied to get Tobin’s pro se filings stricken),   
  4. Hong’s lies at the 4/23/19 exp parte hearing are well documented: 4/23/19 minutes,

4/23/19 RTRAN, 4/23/19 RTRAN annotated, and NCJD 2012-026 Attachment 14.

  1. The severe detrimental impact on Nona Tobin by Hong’s and Morgan’s 4/23/19 ex parte misrepresentations to the court are also documented in NCJD 2021-026 Attachment 16 Stricken, not Heard which is 963 pages of Nona Tobin’s Pro Se notices, motions, oppositions, and documentary evidence stricken solely because Judge Kishner reasonably expected officers of the court to tell her the truth.
  2. 4/25/19 Pre-trial conference Minutes
  3. Joseph Hong violated NRCP 11 (b)(1) by attending the pre-trial conference on court call.
  4. Hong’s misconduct in not attending the pre-trial conference, and faking the existence of a co-trial counsel, is well documented by 4/25/19 minutes, 4/25/19 RTRAN.
  5. Also notable at the 4/25/19 pre-trial conference was Hong’s representation to the court that he had no evidence and no witnesses for either of his clients, Jimijack and F. Bondurant LLC.
  6. 5/3/19 JOIN, 5/23/19 STOKES-CFS DOT annotated, 6/24/19, 6/28/19, 8/7/19, 8/13/19,
  7. Settlement documents status check hearing: 5/21/19 minutes, 5/21/19 transcript, 5/21/19 annotated transcript Hong’s deceiving the court about the Jimijack-Nationstar “settlement” is on display at the 5/21/19  settlement documents status check hearing where Judge Kishner relied on Hong’s misrepresentations and did not check the documents.
  8. Hong concealed the 5/1/19 Jimijack to Joel Stokes deed (See  5/1/19 Jimijack to Joel Stokes DEED annotated,).
  9. By virtue of Hong’s concealing this material fact, Judge Kishner was not aware the Jimijack did not have any recorded interest at the time of the Hansen Trust vs. Jimiack quiet title trial on 6/5/19.
  10. More importantly, Hong concealed from the court that neither Jimijack nor Nationstar were parties to the “Jimijack – Nationstar agreement”. Hong concealed from the court the “agreement” executed by non-parties, Joel A. Stokes, an individual, and Civic Financial Services, LLC, and recorded on 5/23/19,
  11. On 5/24/19 OPPM, Hong continued his relentless pursuit of obstructing Nona Tobin’s case with more misrepresentations to the Court regarding Nona Tobin’s standing that were without any basis whatsoever in fact or law, and Joseph Hong knew it. This opposition, like virtually all of Hong’s motions, oppositions, drafted orders and oral arguments, were produced for the sole purpose of obstructing the administration of justice.

 5/29/19 video, 5/29/19 RTRAN,

  • Joseph Hong Joseph Hong refused to meet with attorney Joe Coppedge in May 2019 to prepare the mandatory EDCR 2.67 joint pre-trial memo and refused to respond to Nona Tobin’s pro se .
  • Judge Kishner issued erroneous as 6/3/19 RTRAN, 6/3/19 video, 6/5/19, 6/5/19 video, 6/5/19 RTRAN, 6/5/19 video, 6/6/19 RTRAN9/3/19 RTRAN, 9/3/19 video, 6/25/20, 7/1/20,  8/3/20 annotated,, 8/11/20 video, 8/11/20 RTRAN, 10/8/20, 10/8/20 annotated, 10/16/20 OST, 10/16/20 NEO, 10/29/20 RTRAN, 10/29/20 video, 11/3/20 video, 11/3/20 RTRAN
  • Third-party Defendants Hong  made the following false representations regarding the facts, the court record and the law:
  • At the time of the Misrepresentations, Defendants knew each Misrepresentation was false.  Defendants intended to induce the Court to act in reliance upon their Misrepresentations. 
  • Judge Kishner justifiably relied on the Misrepresentation by Melanie Morgan and Joseph Hong, expecting them to be true to their duty of candor to the tribunal, to Nona Tobin’s detriment. 
  • In reliance on Defendants’ Misrepresentations, Judge Kishner made erroneously rulings against Nona Tobin, an individual, without actually knowing what the facts, the court record,  and the law were.
  • Judge Kishner never heard or considered Nona Tobin’s 4/24/19 MVAC and MSJ motion to vacate the order entered on 4/18/19 pursuant to  the Agreement therefore lacked mutual assent.  As a direct, proximate, and foreseeable result of Defendants’ acts, Plaintiff has been damaged in excess of [$15,000 (State Court) or $75,000 (Federal Court)], and in an amount to be determined at the time of trial. 
  • Defendants’ acts were committed with fraud, oppression, and/or malice, entitling Plaintiff to punitive damages pursuant to NRS 42.005 in an amount to be determined at the time of trial. 
  • As a direct, proximate, and foreseeable result of the Defendants’ acts, it has become necessary for Plaintiff to secure the services of an attorney, and Plaintiff is entitled to recover fees and costs incurred herein as damages
  • Joel and Sandra Stokes 5/1/19 DEED conveyance of Jimijack’s inadmissible 6/9/15 DEED was for the purpose of evading detection that Jimijack had no standing and no evidence to pursue a quiet title claim at the 6/5/19 trial. Joseph Hong concealed this material fact from the court, and lied to her on 5/21/19 when she specifically asked him.

Mr. Hong, can you restate you were speaking on behalf of which parties?

MR. HONG: Yes, Your Honor. The Stokes parties, the plaintiffs.

THE COURT: You’ve got to be clearer than that, counsel. Remember, we have unique aspect in this case that you’re — you have clients that are — so, are you JimiJack Irrevocable Trust as well or just the Stokes?

MR. HONG: It’s the JimiJack Irrevocable Trust through its trustees, Joe and Sandra Stokes, the Stokes, Your Honor.

5/21/19 status check hearing, Page 7, 6-16, Joseph Hong concealed that the Jimijack-Nationstar “settlement” was between non-parties Joel Stokes and Civic Financial Services, so
Hong’s his fraud covered up a fact that benefited his co-conspirators
        All subsequent transfers in the chain of title, 12/27/19 DEED 1, 12/27/19 DEED 2 Chiesi, are void, as the fruit of the poison tree.
  1. Bank of America (Youda Crain robo-signer, Teresa D. Williams notary fraud) recorded a false claim on 4/12/12.
  2. RRFS recorded false claims on 12/14/12, 3/12/13, 4/3/13, 4/8/13, and executed the foreclosure deed Thomas Lucas recorded on 8/22/14.
  3. Thomas Lucas’ 2/23/15 RPTT refund should be investigated.
  4. 6/8/15 CluAynne M. Corwin notarized Yuen K. Lee’s signature claiming Thomas Lucas stood before her and made no entry in her notary journal
  5. Joel & Sandra Stokes and or Joseph Hong and/or Robert Goldsmith recorded false claims on 6/9/15, 6/9/15, 12/1/15, 5/1/19, 5/23/19, 5/28/19, 7/24/19, 12/3/19, 12/27/19, and 12/27/19 and aided and abetted false claims to be recorded on 6/3/19, 6/4/19, 7/10/19, 7/17/19,  12/27/19, 2/6/20, 2/6/20,  and 12/4/20
  6. Bank of America engaged in mortgage lending fraud. See 5/20/19 DECL Doug Proudfit. B of a was aided and abetted in this fraud by attorneys- Miles, Bauer, Bergstrom, & Winters LLP, e.g., Rock K. Jung on 4/8/13, 5/8/13, 
  7. Attorneys for Wright, Finley, Zak, aided and abetted mortgage servicing fraud of both Bank of America and Nationstar Mortgage by filing into these quiet title civil actions statements known to be false and disclosing false evidence Edgar Smith (NV bar #5506) on 1/11/16, 4/12/16 DECL, 4/12/16, 5/10/16, 6/2/16, 6/3/16, 6/10/16, 3/27/17 DECL , 3/27/17, 11/9/17, 2/9/18, (Dana Johnson Nitz NV Bar #0050, Michael Kelly NV Bar #10101)
  1. Attorneys for Akerman LLP (Melanie Morgan NV Bar #8215, Karen Whelan NV Bar #10466, Donna Wittig NV Bar #11015). 5/15/18, 2/7/19, Thera Cooper NV Bar #13468, 2/12/19, 2/12/19,  2/20/19, 2/21/19, 2/21/19, 2/27/19, 2/28/19, 2/28/19, 3/7/19, 3/12/19, 3/12/19, 3/18/19, 3/21/19, 3/26/19 RTRAN, 4/12/19, 4/15/19 (SAO signed 4/10/19), 4/19/19,  4/23/19, 4/23/19 RTRAN, 4/25/19 RTRAN, 5/3/19, 5/21/19 RTRAN, 5/29/19 RTRAN, 5/31/19, 6/24/19, 6/24/19, 6/25/19, 7/1/19, 7/22/19.
  2. 11/16/20 verified complaint vs. Nationstar provides 692 pages of evidence supporting my claim of mortgage servicing fraud and fraud on the court vs. Nationstar and its Akerman and Wright Finley Zak attorneys.

Allegations regarding why quiet title should have been granted to Nona Tobin years ago

  1. The HOA Sale Was Non-Compliant With Foreclosure Statutes
  • The sale was not authorized by valid HOA Board votes.
  • The owner was denied contractually guaranteed due process.
  • The sale was not properly noticed and bidding by bona fide purchasers was suppressed.
  • Tobin’s deed is superior to all others.
  • Bank attorneys filed false and recorded false claims.
  • BANA & NSM as they obstructed FMV sales, confiscated Tobin’s property without foreclosing.
  • All defendants recorded false claims to title.

Nona Tobin’s rejected 2017 offer cold have prevented five years of litigation

  1. Tobin’s rights as an SCA member were abridged by SCA attorney misconduct.
  2. SCA attorney David Ochoa (Herein “Ochoa”) unilaterally rejected Tobin’s March 22, 2017 offer to settle  the case without cost to SCA or Tobin, without even submitting it to the SCA Board for their consideration:

Nona Tobin would agree to:

■ No claim for attorney fees

■ No claim for damages Waive claim of Respondeat Superior

■ Withdraw 2/1/17 Cross-claim against SCA as if with prejudice

■ No further civil action or NRED complaint to hold SCA accountable for acts of SCA’s agents that resulted in a defective foreclosure sale

SCA Board would have to agree to

■ Not oppose my A720032 3/3/17 motion to void the sale for 

– statutory non-compliance NRS 116.31162 et seq & NRS 116.31085

– Failure to provide Tobin notice and due process

– Failure to distribute the proceeds per NRS 116.31164

– Improper accounting and excessive fees charge

■ Instruct the attorneys to withdraw two motions to dismiss Tobin as an individual and as trustee for NRS 38 mediation and for practicing law without a license

■ SCA Board to conduct a review of the collection process to ensure owners get the same notice and due process when their house is sold as SCA owners get when fined $25 for a dead tree.

SCA Board would affirm or deny on their merits Tobin’s 2/1/17 claims that:

■ No notice was given to owner or Ombudsman

■ Premature unnecessary referral to collections

■ Excess fees charged

■ Foreclosure deed relied on rescinded 3/12/13 NOD

■ Canceled 2/12/14 NOS of 3/7/14 sale

■ No NOS in effect when sold on 8/15/14

■ Sale not commercially reasonable – 18% of FMV when no lender approval on four FMV sales up to $395,000

■ Agents falsified records to keep their actions covert

■ Agents kept $60,000 that belonged to the GBH Trust

Allegations related to the fraudulent sale and the unlawful retention of proceeds

This action rises out of attorney misconduct during the course of legal proceedings that has caused severe damage to Nona Tobin. Defendants have violated professional and ethical standards of their profession by overzealously aiding and abetting racketeering and other criminal activities of their clients. This interpleader complaint was for the purpose of continuing to obstruct a fair, evidence-based adjudication of Nona Tobin’s claims.

2763 White Sage was sold by an unknown entity, without notice and without legal authorization by the Sun City Anthem Board of Directors. Thomas Lucas, a Berkshire Hathaway real estate salesman working under the broker Forrest Barbee, purchased it at the unnoticed sale on 8/15/14, while Forrest Barbee had an exclusive right to sale contract with Nona Tobin from 2/20/14-10/31/14 through another Berkshire Hathaway sales agent, Craig Leidy.

Lucas paid $63,100 and took title as an alter-go entity, Opportunity Homes, LLC, but there is no HOA record of the sale and no HOA record of the $63,100 and no HOA record that either Thomas Lucas or Opportunity Homes ever owned the property. The HOA records show that on 8/27/14 an entry of a collection payment on page 1336 in the Resident Transaction Report that $2,701.04 was paid to the HOA as “PIF”, payment in full of Gordon Hansen’s assessment account. On page 1137, Jimijack Irrevocable Trust was charged a new owner set up fee on 9/25/14 to become the second owners of the property. None of the opposing attorneys disclosed or refuted this discrepancy. Some disclosed doctored records. All concealed inculpatory records. Hong disclosed nothing. Nationstar and Brittany Wood disclosed and knowingly misrepresented Jimijack’s void, inadmissible 6/9/15 deed with the obvious intent to deceive the court and obfuscate that neither of their clients had valid title claims superior to Nona Tobin’s.

The unnoticed sale took place after Craig Leidy had sold the property on auction.com for $367,500 on 5/8/14, but the unidentified beneficiary of the 7/22/04 Hansen deed of trust refused to accept the high bidder.

The unnoticed sale took place after the Ombudsman had cancelled the 2/12/14 notice of sale process tracking on 6/2/14 after receiving notification, upon information and belief, from Red Rock, that the 5/15/14 trustee sale was cancelled and “the owner retained”.

The unnoticed sale took place on 8/15/14 after Nona Tobin had signed a $375,000 counter-offer on 8/1/14, pursuant to Nationstar’s instruction to Craig Leidy, to Yvonne Blum’s $358,800 7/26/14 offer that was in hand pending lender approval.

According to documents disclosed by Sun City Anthem and provided by Steven Scow in response to subpoena, the proceeds of the sale that Red Rock agent Christie Marling identified as “excess” were transmitted to Steven Scow to deposit with the court for interpleader on 8/28/14. See SCA 223-224 and RRFS 

Steven Scow did not deposit the $57,282.32 with the court for interpleader immediately after the sale as required by NRS 116.31164(3)

Nona Tobin contacted Red Rock in Sept 2014 to make a claim for the excess proceeds, but Red Rock informed her that they went to court for interpleader. See 10/14/14 email with Leidy 5/11/18 DECL.

Nona Tobin attempted to get the excess proceeds distributed to her by COA 5 i her 1/31/17 CRCM

Nona Tobin attempted to get the excess proceeds distributed to her in NRS 38.310 mediation that Steven Scow responded to on behalf of the non-responding Respondents, Joel Just, former President of RRFS, during all times relevant, and Steven Parker, President of First Services Residential, Nevada, the managing agent for Sun City Anthem and NRS 649 debt collector licensee DBA Red Rock Financial Services, a partnership (EIN 88-0805132??). Steven Scow’s only response to Nona Tobin’s 8/20/18 filed claim for mediation, was one sentence “claim is time-barred”

Nona Tobin met with Steven Scow in his office on 11/30/18 since the 11/13/18 mediation lasted less than 30 minutes and the HOA and Steven Scow refused to respond to any of Nona Tobin’s claims.

At that meeting Steven Scow informed her that he had the excess proceeds in his attorney-client trust fund and would not distribute them until the litigation was resolved.

Nona Tobin attempted again to get the excess proceeds distributed to her by COA 4 in A-19-799890-C 8/7/19 COMP.

On 8/11/20 Brody Wight, Koch & Scow LLC associate attorney speaking for Steven Scow, stated (quote) “the only reason we’re holding these funds is she keeps litigating”

Upon information and belief, Red Rock’s complaint for interpleader, signed by Steven Scow, and stamped “Electronically issued 02/03/2021 12:38 PM”  was personally served on John Thomson for Nona Tobin, on 2/15/21, but there is no affidavit of service filed into the A-21-828840-C Odessey NVefile and serve court record system to prove it. 

Steven Scow named four defendants in the complaint that did not have a recorded claim to assert an interest in the proceeds, and knowingly made the false statement in the complaint that:

“10. In connection with the foreclosure sale, the Association was paid the money it was owed, and RRFS was paid its fees and costs incurred in collecting the debt as allowed by contract and Nevada law. After paying these costs, RRFS was left with funds of $57,282.32. RRFS has no further interest in such funds. These funds have been deposited into counsel’s attorney-client trust account and $3,500 has been withheld as costs, expenses, and fees to commence this action. The remainder of such funds will be deposited with the Court until such time and place as directed by the Court.”

Steven Scow Page 3, paragraph 10, Interpleader complaint

These statements are duplicitous and self-serving by Steven Scow in that he association was paid what it was owed by Gordon Hansen’s estate, $2,701.04, on 8/27/14. Yet, Scow filed a 6/25/20 duplicitous motion to dismiss Nona Tobin’s claim for the excess process in case A-19-799890-C on the grounds of NRCP 12(b)(6) failure to join the HOA as a necessary party to protect its nonexistent interest in the excess proceeds of the sale.

There is no legal justification for Steven Scow to not have distributed the funds immediately after they were given to him by Christie Marling on 8/28/14 with instructions to deposit them with th court.

Scow’s failure to distribute the funds took a much more sinister turn when he did not put them in the HOA’s trust fund as the HOA Board is prohibited by its bylaws from losing control of ANY funds collected for the HOA.

“Finally, Tobin is attempting to void the HOA foreclosure sale, which, if successful, will impede the HOA’s ability to protect its interest in the proceeds of the foreclosure sale. The HOA’s joinder to this action is, therefore, required under NRCP 19. “

Steven Scow 6/25/20 motion to dismiss all Nona Tobin’s complaints

Gag me now

The fact that Tobin cannot name the HOA as a party because the claims against the HOA have already been litigated is further proof of the impropriety of the current action.”

Steven Scow 6/25/20 motion to dismiss all Nona Tobin’s complaints

Nona Tobin’s dispositive motions were not adjudicated in prior proceedings

Steven Scow knows, or has access to information that would have allowed him to know that, Nona Tobin’s claims were not already litigated as Nona Tobin’s 4/24/19 Motion to vacate and MSJ are languishing in the record unheard.

On 8/11/20, Brittany Wood, attorney for Quicken Loans, Inc (not LLC) and Brian and Debora Chiesi, who recorded claims adverse to Nona Tobin on 12/27/19 and who were not parties to the dispute over the excess funds, gratuitously and falsely informed the court that these excess funds belonged to two lenders and not to Nona Tobin.

Steven Scow also informed her that he had a file that showed notices had been given to Craig Leidy about the sale. Nona Tobin was shocked by this news and contacted her attorney, Joe Coppedge, informed Nona that he had a CD of disclosures from the HOA. He transmitted them to her on 12/26/18.

The Sun City Anthem disclosures in SCA 164-643 contain many false and falsified documents related to the contractual relationship between Red Rock and Sun City Anthem. 

SCA attorney David Ochoa  and Steven Scow who responded to Nona Tobin’s 2/4/19 subpoena on behalf of RRFS, the partnership, failed to disclose the HOA’s official records that show there are no HOA Board agendas or minutes of any HOA Board meeting compliant with NRS 116.31183 at which the SCA Board authorized 

  • the sale of 2763 WS or 
  • the sale of a dozen other properties that Red Rock confiscated in 2014.

by a vote of the Board and personally prevented the HOA custodian of records Elyssa Rammos from disclosing in response to Nona Tobin’s interrogatories and requests for documents

failed to disclose any documents that showed the HOA Board complied with the due process requirements of NRS 116.31162(4), NRS 116.31085, or NRS 116.31031

failed to disclose the 4/27/12 contract that requires Red Rock to indemnify the HOA

what they did disclose was the Red Rock foreclosure file (SCA 176-643 and RRFS 001-425 which will be provided to the Court separately in a request for judicial notice.  These unverified, uncorroborated filed were misrepresented to the court as the HOA’s official records. In fact, they are criminally fraudulent, falsified, incomplete, inaccurate revisionist history that covered up the theft of property and funds belonging to Nona Tobin, the individual owners of the other dozen properties, and from the HOA membership at large.

Nationstar attorneys filed false statements, claims for relief known to be unwarranted, and motions, oppositions and joinders known to be unsupported by fact or law on these dates: 

Nona Tobin moves the court to require restitution of Nona Tobin’s property, impose sanctions and penalties pursuant to NRCP 11, NRS 18.010(2), NRS 207.470(1) and (4), NRS NRS 207.377, and NRS 42.005 vs. Nationstar Mortgage LLC and its attorneys  (NAMES) 

Nationstar’s filings that contain the sanctionable statements will be compiled with Nationstar’s 

Nationstar was the servicing bank, but never was the holder of the original note. 

Nationstar’s first claim to be owed the $389,000 balance on the Hnsen deed of trust was on 12/1/14 when it recorded a claim to be BANA’s successor in interest, but Na

The third-party defendants named are individuals who failed in their duty of candor to the court, misrepresented the facts, law and the court record, presented false evidence, and/or withheld evidence of probative value to Tobin’s case, filed unwarranted, harassing motions, oppositions and pleadings that obstructed the administration of justice and made a mockery of the Nevada judicial system.

There has been no evidence-based adjudication of Nona Tobin’s claims in any Nevada Court since 7/29/16 to the present in any of the three district court cases that arose from the disputed 8/15/14 foreclosure sale. There are currently four appeals that are wasting the resources of the Nevada Courts of Appeal that were necessary because all the attorneys in the district court cases opposing Nona Tobin lied to the district court judges in order to prevent Nona Tobin’s claims and evidence from being heard.

The named third-party defendants – Steven Scow, Brody Wight, Joseph Hong, Kaleb Anderson and his subordinate attorneys, David and Angela Ochoa, in Lipson Neilson, Melanie Morgan (for her own actions and omissions and those of her subordinates in the Akerman LLP and for her knowledge of the fraud of Nationstar’s and B of A’s WFZ and Miles Bauer attorneys) 

3/15/21 RFJN Request for Judicial Notice of the 2003-2021 Clark County Recorder Property Records for APN 191-13-811-052. A table delineating the disputes relating to the property records can be accessed online here or linked as a PDF table here.

[1] 1/31/17 CRCM cross-claim vs. Sun City Anthem & DOEs 1-10 & ROEs 1-10

[1] Exhibit 2 is Tobin’s certificate of Incumbency, recorded 5/23/16 [1] Exhibit 3 is the GBH Trust deed, recorded 8/27/08.

Allegations related to Nationstar’s fraud

  1. The corrupt pattern in my case was executed by attorneys abusing the quiet title litigation process.  
  2. In my case, Nationstar was the servicing bank from 12/1/13 to the present (B of A was the servicer before)
  3. Neither B of A nor Nationstar ever recorded a notice of default or took any of the steps mandated by NRS 107.080 to foreclose on the Hansen DOT even though there were no payments after 2011 because the borrower died. 
  4. B of A/Nationstar both obstructed fair market value sales, I sold it on 5/8/14 on auction.com for $367,500 on 5/8/14, but Nationstar falsely claimed the unidentified beneficiary disapproved the sale.
  5. Nationstar refused to identify the beneficiary and let the HOA sell it for $63,100 on 8/15/14 with no notice to me whatsoever.
  6. Nationstar circled back, filed a fraudulent civil action in 2016  (1/11/16 COMP) for quiet title against Opportunity Homes who did not have any recorded interest after 6/9/15) based on the false claim that NSM was the beneficiary since 2011.
  7. Nationstar falsely claimed that the HOA sale was void because B of A had paid the super-priority of delinquent HOA fees, concealing from the court that the PUD rider prohibits any lender from twisting the payment of delinquent HOA fees into a de facto foreclosure without complying with NRS 107.
  1. I intervened to support Nationstar’s suit to void the sale and said that I had evidence that Nationstar was lying about being the beneficiary.
  2. Nationstar and Jimijack made a fraudulent side deal to prevent the court from seeing that neither of them had any evidence to support their claims. Nationstar circumvented the judicial process by dismissing its claims on 2/20/19 and 5/31/19 without going to trial.