Plaintiff repeats, realleges, and incorporates herein by this reference the allegations hereinabove inclusively as though set forth at length and in full herein.
Defendants collectively constitute a combination of two or more persons.
Defendants acted in concert by agreement, understanding, or a “meeting of the minds” regarding the objective and the means of pursuing it, whether explicit or by tacit agreement (the “Scheme”).
Defendants, and each of them, intended to and did accomplish an unlawful objective for the purpose of harming Plaintiff Nona Tobin through the Scheme.
The Scheme harmed Plaintiff Nona Tobin
As a direct, proximate, and foreseeable result of the Scheme, Plaintiff has been damaged in excess of $15,000 and in an amount to be determined at the time of trial.
Defendants’ acts were committed with fraud, oppression, and/or malice, entitling Plaintiff Nona Tobin 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 Nona Tobin to secure the services of an attorney, and Nona Tobin is entitled to recover fees and costs incurred herein as damages.