The elements of a civil claim for damages caused by racketeering are:
1. Defendants, and each of them, engaged in conduct which constitutes a pattern of racketeering activity pursuant to NRS 207.360, including (9) taking property from another under circumstances not amounting to robbery, (18) Grand larceny; (29) Perjury or subornation of perjury; (30) Offering false evidence; (35) Any violation of NRS 205.377;
2. Defendants, and each of them, engaged in conduct which constitutes a pattern of racketeering activity in violation of NRS 207.470;
3. Defendants, and each of them, committed at least two separate crimes relating to racketeering constituting a pattern of racketeering activity. (the “Predicate Acts”);
4. Defendants’ crimes are interrelated by distinguishing characteristics and are not isolated incidents but are a part of a pattern of criminal activity;
5. The Defendants, and each of them, violated NRS 207.400;
6. Plaintiff Nona Tobin has suffered damages;
7. Plaintiff Nona Tobin is entitled to treble damages against Defendants, and each of them. NRS 207.470(1);
8. Plaintiff Nona Tobin is entitled to an award of punitive damages; and
9. Plaintiff Nona Tobin is entitled to an award of attorney fees and costs as damages. NRS 207.470(1).
A partial list of the Counter-Defendants’, Cross-defendants’ and third-party defendants’ Predicate Acts
Nationstar LLC and/or Nationstar LLC dba Mr. Cooper recorded false claims on 12/1/14, 1/22/15, 8/17/15, 1/13/16, 6/7/16, 3/8/19 rescind and 3/8/19 assign, and 6/3/19.
Red Rock Financial Services 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.
Joseph Hong’s clients 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.
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).
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.
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 proceeds, on these dates, 6/9/15 DEED, 6/16/15, 6/8/16, 8/12/15, 10/16/15, 8/30/16, 9/29/16 RTRAN, 12/5/16, 12/20/16 RTRAN, 3/13/17, 3/13/17, 3/13/17, 12/5/18, 3/25/19, 3/26/19 RTRAN, 4/15/19, 4/22/19, 4/23/19 minutes, 4/23/19 RTRAN, 4/23/19 RTRAN annotated, 4/25/19 RTRAN, 5/1/19 DEED, 5/3/19, 5/21/19, 5/23/19 Agreement, 5/24/19, 5/29/19 video, 5/29/19 RTRAN, 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 RTRAN, 6/24/19, 6/28/19, 8/7/19, 8/13/19, 9/3/19 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.
Detailed allegations against defendants are delineated in complaints to the Nevada Attorney General on 3/14/19 and 11/10/20.
Detailed allegations against defendants are delineated in complaints to the Nevada State Bar on 2/14/21 and on 2/16/21.
Detailed allegations against multiple defendants are delineated in these publications
Specific allegations related to false claims recorded by multiple defendants in the Clark County Official property records are in this publication
Detailed allegations against Brittany Wood are delineated in these publications
Detailed allegations against Melanie Morgan are delineated in these publications
Detailed allegations against Nationstar are delineated in these publications
This fraud on the court publication has nine videos that show exactly how the attorneys tricked the court into letting Nationstar and Joel Stokes steal Nona Tobin’s house without ever putting on a case, meeting their Plaintiffs’ burden of proof, or refuting Nona Tobin’s claims against them.
Some allegations against Steven Scow & Brody Wight are delineated in these publications
Court records that evidence fraud on the court Joseph Hong are partially found here
Documentary evidence of abuse of process, fraud on the court, conspiracy, and racketeering are in linked exhibits to the Nevada attorney General & to the Mortgage Lending Division
Specific allegations related to false claims recorded by multiple defendants in the Clark County Official property records are in this publication
A fable to illustrate Joseph Hong’s & Melanie Morgan’s fraud on the court is in this publication
This publication of the Nevada Rules of Civil Procedure will be updated to highlight relevant rules related to proposed sanctions and proposed civil court reform
Nona Tobin’s Cross-claims vs. Nationstar and Wells Fargo and counter-claims vs. Red Rock Financial Services and motions for attorney sanctions in Nevada district court case A-21-828840-C are found in this publication
Detailed allegations vs. Joseph Hong are in these publications
Relevant Nevada case law
NRS 207.470; Stoddart v. Miller, 2008 WL 6070835 (Nev. 2008 );
Siragusa v. Brown, 114 Nev. 1384, 971 P.2d 801 (1999);
Gordon v. Eighth Judicial Dist. Ct., 12 Nev. 216, 231, 913 P.2d 240, 250-51 (1996);
Cummings v. Charter Hosp. of Las Vegas, Inc., 111 Nev. 639, 896 P.2d 1137 (1995);
Allum v. Valley Bank of Nevada, 109 Nev. 280, 849 P.2d 297 (1993);
Hale v. Burkhardt, 104 Nev. 632, 634, 764 P.2d 866, 867 (1988).