2016 Court hearings

September 29, 2016 hearing Judge Kishner

Nona Tobin & Steve Hansen 7/29/16 motion to intervene into A-16-730078-C

7/29/16 Tobin/Hansen MINV link to PDF

8/30/16 OPPM link to PDF Joseph Hong’s opposition to 7/29/16 Tobin/Hansen MINV

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.

9/9/16 Tobin reply to Hong’s opposition link to PDF

9/23/16 AFFD Nona Tobin sworn affidavit in support of motion to intervene challenges both Nationstar and Jimijack’s ability to prove their title claims

9/29/16 Amended Transcript link to PDF

9/29/16 minutes

9/29/16 video link

December 20, 2016 hearing Judge Kishner

11/15/16 motion to intervene Nona Tobin, an individual, and as trustee of the Gordon B. Hansen Trust, dated 8/22/08

Link to PDF 11/15/16 motion to intervene by Nona Tobin, an individual, and as trustee of the Gordon B. Hansen Trust, dated 8/22/08

Link to PDF 12/5/16 OPPM filed by Joseph Hong to Nona Tobin, an individual, and as trustee of the Gordon B. Hansen Trust, dated 8/22/08

Link to PDF 12/12/16 Nona Tobin Reply to Joseph Hong’s opposition

12/20/16 Transcript link to PDF

12/20/16 minutes link to PDF

12/20/16 video

1/12/17 NEO order granting Nona Tobin leave to intervene pursuant to NRCP 24(a)(2) Intervention by right

Rule 24. Intervention
(a) Intervention of Right. On timely motion, the court must permit anyone to intervene who:
(2) claims an interest relating to the property or transaction that is the subject of the action, and is so situated that disposing of the action may as a practical matter impair or impede the movant’s ability to protect its interest, unless existing parties adequately represent that interest.
NRCP 24(a)(2)

2nd complaint to the Nevada Attorney General & exhibits

Links to exhibits to 2nd complaint to the Nevada Attorney General

12/1/14 Assignment Nationstar – no power of attorney – executed B of A to Nationstar assignment of the 7/22/04 Hansen deed of trust
NSM 258-260 Nationstar disclosed it did not have the original Hansen promissory note, and the copy of the note it had was not endorsed to Nationstar
2/20/19 SODWOP Nationstar dropped all its quiet title claims against all parties except Jimijack (1/11/16 COMP in A-16-730078-C) without adjudication or any judicial scrutiny of evidence.
2/2819 RESP Pg 6 Nationstar admitted in response to interrogatories that it was not the beneficiary of the Hansen deed of trust; it was just the servicing bank for non-party Wells Fargo who has never claimed to be the beneficiary of the Hansen deed of trust. On page 7, the verification only included that Nationstar was the servicer and was signed by a previously unknown person of unknown authority.
3/8/19 Rescission Nationstar – no power of attorney – rescinded 12/1/14 B of A to Nationstar assignment of the 7/22/04 Hansen deed of trust which means that Nationstar had no recorded claim to give it standing to be in either cases A-15-720032-C or A-16-730078-C and is judicially estopped from claiming that it was the owner of the Hansen deed of trust during all relevant times or ever.
3/8/19 Assignment Nationstar – no power of attorney – executed Wells Fargo to Nationstar assignment of the 7/22/04 Hansen deed of trust
3/14/19 AG 2-2019 Complaint to the AG that was allegedly served on Melanie Morgan
3/18/19 NITD Nationstar three-day notice to take default against Jimijack since Jimijack did not answer the 6/2/16 AACC
3/21/19 MSJ Nationstar filed an MSJ against Jimijack and not against Nona Tobin, the HOA or the Gordon B Hansen Trust
4/10/19 OPP/MSJ Tobin opposition to Nationstar’s MSJ as Nationstar did not own the beneficial interest of the Hansen deed of trust; and the HOA sale was void in its entirety so foreclosure would have to have been against Tobin for any lender; plus Jimijack’s deed was void per NRS 111.345.
4/9/19 NRS 38.310(2) Notice of completion of mediation by Tobin/Hansen Trust when neither Jimijack nor Nationstar had complied with NRS 38.310 so the court lacked jurisdiction to grant them relief sought.
4/12/19 NS Jimijack (who didn’t have a valid deed never filed any claims against Nationstar or against Tobin or the Hansen Trust) prevailed in the quiet title case by “settling” out of court with Nationstar in a fraudulent deal that excluded Tobin and the Hansen Trust. Judge Kishner never examined any evidence to support their claims (Judge Kishner held 42 hearings, but never examined any evidence.)
4/17/19 TOC exhibits 600 pages of evidence to support Tobin’s claims that were stricken from the record unheard by bench orders at the 4/23/19 ex-parte hearing.
4/19/19 RESP Nationstar convinced the court that it was ok for Nationstar and Jimijack to settle the quiet title dispute without the court examining any evidence because Nationstar and Tobin/ Hansen trust weren’t really opposing parties.
4/23/19 NWM Nationstar dropped its motion for summary judgment against Jimijack without Jimijack filing an opposition (that Judge Kishner required to be filed by 4/26/19 on her 4/12/19 order continuing the hearing to 5/7/19and convinced Judge Kishner that was the end of the case because she had granted the HOA’s motion for summary judgment (based on no evidence) and Nationstar’s limited joinder (based on no evidence and explicitly contrary to the Hansen deed of trust PUD rider Remedies (f) (NSM 160) that prohibits the use of tender of delinquent HOA assessments as a de facto foreclosure.
4/23/19 Transcript Nationstar & Jimijack’s attorneys, Melanie Morgan & Joseph Hong met with Judge Kishner ex-parte after serving notice that the hearing was continued on 4/15/19 (SAO) and 4/22/19 (NTSO) in order to get Nona’s pro se motions and notices stricken unheard from the record to make a fraudulent “settlement”.
5/23/19 DOT annotated Neither Nationstar nor Jimijack are parties to $355,000 deed of trust executed & recorded on 5/23/19 by nonparties Joel A Stokes & Civic Financial Services
4/23/19 video
4/23/19 minutes
5/1/19 DEED Joel & Sandra Stokes as trustees of Jimijack dumped Jimijack’s deed by transferring the title into Joel’s name as an individual. Judge Kishner never ruled on Jimijack’s deed that Nona Tobin claimed was inadmissible per NRS 111.345 in her 2/1/17 AACC vs Jimijack and in two declarations under penalty of perjury.
5/21/19 Transcript Nationstar attorneys characterize as a settlement agreement between parties Jimijack & Nationstar that excluded parties Nona Tobin & the Gordon B. Hansen Trust from the title fight without the court examining any evidence including not examining the alleged settlement documents.
5/31/19 NESO Nationstar stipulates that it drops its remaining quiet title claim against Jimijack with prejudice so they both win without the judge ever looking at the evidence or hearing Nona Tobin’s claims against Nationstar & Jimijack.
6/3/19 Reconvey Nationstar dba Mr. Cooper falsely claimed to be both the beneficiary and the trustee of the Hansen deed of trust and reconveyed without legal authority the property to Joel A Stokes two days before the quiet title trial (A-15-720032-C) that allegedly was held to determine the title rights between the Gordon B. Hansen Trust and the Jimijack Irrevocable Trust.
Supreme Court case 79295 Online case management system – see how opposing parties were successful in getting me removed as a party by saying I was not aggrieved. See orders SC 19-37846 and SC 20-016346.
Judicial Jiu-jitsu Youtube channel contains closed-caption videos of all the A-15-720032-C court hearings from 2016-2019 and all the A-19-798990-C court hearings held in 2020 as well as brief videos explaining the trickery employed by the opposing attorneys to suppress Nona Tobin’s evidence and obstruct her access to a fair adjudication of her claims on their merits by an impartial tribunal.

11/10/20 NV AG complaint

12/4/20 rejection of the complaint by the Nevada Attorney General

1st complaint to the Nevada Attorney General & exhibits

Links to Exhibits to 3/14/19 complaint to the NV Attorney General

2011 Certified fraud examiner Amicus curiae MA Supreme Court

7/15/2004 Western Thrift Deed of Trust

7/15/2004 COPY of GBH note NSM 258-260

5/14/2008 10 SCA bylaws 3.20/3.18abefgi prohibits BOD delegation

3/11/2011 2011 anti-foreclosure fraud law AB 284

10/1/2011 NV 2011 Legislative Digest re AB 284 changes

2/1/2012 2012 National Mortgage Settlement

4/12/2012 Recorded DOT assign to BANA

8/8/2012 6 Sparkman RPA $310K

8/10/2012 Tobin counter to require lender to pay seller costs

8/10/2012 7 BANA short sale addendum

8/11/2012 8 Tobin re lender is seller

9/17/2012 9 SCA MSJ exhibit 3 re intent to lien SCA628

9/20/2012 5 Hearing Notice Sanction 4 Delinquent Assessments

10/3/2012 4 Tobin letter 2 SCA w/ 8/17/12 chk 143 + death cert

1/27/2013 BANA confusion over DOT – misc docs

6/5/2013 HUD-1 draft showing $3055.47 due to HOA out of escrow

6/19/2013 Proudfit 2 Ticor: BANA rejected buyer

12/31/2013 Mortgage transfer disclosure requirements

7/1/2014 Leidy-Tobin emails 7/24/14 through 10/24/14

7/22/2014 11 SCA 280-280 BOD denial of fee waiver request

8/21/2014 RRFS trust account check $57,282.32 to CC District court

9/9/2014 BANA recorded 8/21/14 assignment to Wells Fargo

9/25/2014 2 Res Trans Rpt 1336-7 GBH 2 Jimijack

12/1/2014 NS recorded 10/23/14 assignment to itself as BANA’s “attorney-in-fact”

3/12/2015 WF recorded substitution trustee reconvey 2nd DOT 2 GBH

4/1/2015 Thomas Baynard CA bar discipline

6/9/2015 Recorded OpHomes 2 F.Bondurant 6/4/15 quit claim

6/9/2015 3 Quit claim to Jimijack -Yuen Lee signed as T Lucas

1/13/2016 NS Lis Pendens re A-730078-C

4/1/2016 Unrecorded WF power of attorney NSM 270-272

5/9/2016 Residential Transaction Report – 2763 White Sage

6/7/2016 NS Lis Pendens re A-720032-C

9/18/2016 Tobin letter to R-J editor “”HOAs, foreclosures, and property rights”

12/28/2016 Corwin notary communications

1/3/2017 Debra Batesel journal entries re 6/4/15 quit claim & RPA

3/28/2017 Recorded GBH Trust quit claim 2 Tobin

3/28/2017 Recorded Hansen Disclaimer of Interest NSM 212-217

11/5/2018 Irma Mendez affidavit re Joel Just

2/5/2019 SCA MSJ against Tobin

2/5/2019 SCAMSJ Ex5-10/8/12 receipt + false claim of 9/20 notice

2/5/2019 SCAMSJ Ex12-notices with proofs of service

2/12/2019 Joinder to the SCA motion,

2/12/2019 NS Ltd joinder 2 SCA MSJ

2/20/2019 Gmail – compare NS disclosure with my paid off note

2/20/2019 Gmail – another nail in Nationstar’s coffin

2/25/2019 NS unrecorded rescinded 10/23/14 assignment-refiled NSM 404-408

2/25/2019 NS unrecorded refile of 10/23/14 as WF attorney in fact

2/27/2019 “HOA debt collectors wield an unlawful level of power”

2/27/2019 TOC 2 Tobin disclosures

2/27/2019 Tobin 1st sup + BHHS + RRFS

3/1/2019 Hearing minutes Spanish trail A-14-710161

3/1/2019 CA SOS letter re notary complaint

3/5/2019 opposition to the SCA MSJ

3/10/2019 Tobin draft DECL OPPC NS ex 1-10

3/12/2019 CA notary violations on 4/12/12 DOT 2 BANA misc docs

8/27/2008 1 Deed GBH 2 GBH Trust

3/8/2019 Recorded rescission of 10/23/14 assignment MSN 409-411

1/17/2017 Backup for notary subpoenas- not issued

CA notary laws

NV Attorney General’s 3/26/19 response

WHY NATIONSTAR & ITS ATTORNEYS MUST BE SANCTIONED AND PAY PUNITIVE DAMAGES

Table of Contents of Exhibits

Joseph Hong: pay Nona Tobin treble damages for stealing her house and be disbarred

Link to PDF of ABA Standards for Imposing Lawyer Sanctions (last revision 1992)

ABA Standards for Imposing Lawyer Sanctions excerpts to consider to determine level of DISCIPLINE OF JOSEPH HONG

ABA Standard C. 3.0 Factors to Consider

In sanctioning Hong, the court should consider:

Hong repeatedly violated his duty of candor to the court by concealing material facts, most notably that his client didn’t have an admissible deed and the alleged settlement was not between any parties;,
Hong made many false statements in his pleadings, motions, oppositions and oral arguments in order to cheat to win;
Hong served notice that the 4/23/19 hearing was continued to 5/7/19 and then conspired with Melanie Morgan to meet ex parte on 4/23/19 with Judge Kishner anyway;
Relying on Hong’s and Morgan’s misrepresentations, Judge Kishner bench ordered many of Nona Tobin’s pro se filings and 963 pages of her evidence stricken from the record unheard, including meritorious motions for summary judgment vs. Hong’s and Morgan’s clients
Completely through the misconduct of Hong and his co-conspirators, ALL of Nona Tobin’s evidence entered into the court record since 7/29/16 has been suppressed.
Completely through the misconduct of Hong and his co-conspirators, NO Nevada judge in ANY of these four district court cases (A-15-720032-C, A-16-730078-C, A-19-799890-C, A-21-828840-C) or these four Nevada Supreme Court cases (79295, 82094, 82234, 82294), has looked at the evidence.
Hong and his co-conspirators obstructed a fair adjudication of Nona Tobin’s claims by an impartial tribunal,
Hong and his co-conspirators made a fraudulent side deal to steal Nona Tobin’s $500,000 house, $100,000+ in 6+ years of lost rent, and over $100,000 in other actual damages to Nona Tobin.

ABA Standard 6.1 (False statements, fraud, and misrepresentation) and 6.11 Disparment is appropriate when:

Hong , with the intent to deceive the court, made many false statements, submitted false documents, improperly withheld material information, caused serious injury to Nona Tobin and had a serious impact n multiple legal proceedings.

Hong caused serious injury to Nona Tobin, lied to the court repeatedly to steal Nona Tobin’s house and cover his tracks. The specific dates and documentary evidence will be published by 3/21/21.

Disbarment is appropriate. The specific dates and documentary evidence will be published by 3/21/21.

6.2 (Abuse of the Legal Process),

ABA Standard 6.21 Disbarment for violating a court rule to seriously interfere with a legal proceeding

ABA Standard 6.3 Improper Communications with Individuals in the Legal System

6.31 Disbarment is generally appropriate when

8.0 (Prior discipline Orders),

8.1(b) (Disbarment is generally appropriate when a lawyer

Hong has five priors in Nevada

Hong has also been suspended in California

9.22 Aggravating factors that affect Hong

9.22(a) (Prior discipline Orders)

9.22(b) (dishonest or selfish motive)

(d) multiple offenses;

(f) vulnerability of the victim(s);

(g) substantial experience in the practice of law

What does it take to get disbarred in Nevada?

A Duel to the Death

A Simple Fable: Jimijack and Nationstar weaponize settlement

How a bank and a speculator think a quiet title dispute with me should be settled.

The Scheme

In April, 2019, conspirators Joseph Hong and Melanie Morgan covertly devised a scheme to “resolve all parties’ claims” for the title of 2763 White Sage!

Hong & Morgan didn’t warn Nona Tobin

Hong & Morgan’s Slick Scheme:

A duel between Jimijack and Nationstar

Back-to-back.
Pistols raised.
Count 10 paces.
They turn.
Both shoot Nona Tobin.

Hong & Morgan declare the winner!

On 4/23/19, Joseph Hong & Melanie Morgan reported to Judge Kishner that the Jimijack & Nationstar had settled the dispute over who gets the $500,000 house Nona Tobin inherited.

Hint: It’s not Nona.

Judge Kishner blessed the deal!

“Your work is done, Your Honor.
Jimijack and Nationstar have agreed.
Joel Stokes gets the title.
By the way, Nona Tobin is dead.”
Joseph Hong & Melanie Morgan, ex parte on 4/23/19

Nevada Rules of Professional Conduct

Link to PDF Nevada Rules of Professional Conduct revised to 10/19/19

NEVADA RULES OF PROFESSIONAL CONDUCT IMPLICATED PROVISIONS

Rule 1.0. Terminology.

(c) “Firm” or “law firm” denotes a lawyer or lawyers in a law partnership, professional corporation, sole proprietorship or other association authorized to practice law; or lawyers employed in a legal services organization or the legal department of a corporation or other organization.

(d) “Fraud” or “fraudulent” denotes conduct that is fraudulent under the substantive or procedural law of the applicable jurisdiction and has a purpose to deceive.

(f) “Knowingly,” “known,” or “knows” denotes actual knowledge of the fact in question. A person’s knowledge may be inferred from circumstances.

(g) “Partner” denotes a member of a partnership, a shareholder in a law firm organized as a professional corporation, or a member of an association authorized to practice law.

(h) “Reasonable” or “reasonably” when used in relation to conduct by a lawyer denotes the conduct of a reasonably prudent and competent lawyer.

(i) “Reasonable belief” or “reasonably believes” when used in reference to a lawyer denotes that the lawyer believes the matter in question and that the circumstances are such that the belief is reasonable.

(j) “Reasonably should know” when used in reference to a lawyer denotes that a lawyer of reasonable prudence and competence would ascertain the matter in question.

(l) “Substantial” when used in reference to degree or extent denotes a material matter of clear and weighty importance.

(m) “Tribunal” denotes a court, an arbitrator in a binding arbitration proceeding or a legislative body, administrative agency or other body acting in an adjudicative capacity. A legislative body, administrative agency or other body acts in an adjudicative capacity when a neutral official, after the presentation of evidence or legal argument by a party or parties, will render a binding legal judgment directly affecting a party’s interests in a particular matter.

(n) “Writing” or “written” denotes a tangible or electronic record of a communication or representation, including handwriting, typewriting, printing, photostating, photography, audio or videorecording and electronic communications. A “signed” writing includes an electronic sound, symbol or process attached to or logically associated with a writing and executed or adopted by a person with the intent to sign the writing.

(o) “Organization” when used in reference to “organization as client” denotes any constituent of the organization, whether inside or outside counsel, who supervises, directs, or regularly consults with the lawyer concerning the organization’s legal matters unless otherwise defined in the Rule.

Rule 3.1. Meritorious Claims and Contentions.

A lawyer shall not bring 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

Rule 3.3. Candor Toward the Tribunal.

(a) A lawyer shall not knowingly:

(1) Make a false statement of fact or law to a tribunal or fail to correct a false statement of material fact or law previously made to the tribunal by the lawyer;

(2) Fail to disclose to the tribunal legal authority in the controlling jurisdiction known to the lawyer to be directly adverse to the position of the client and not disclosed by opposing counsel; or

(3) Offer evidence that the lawyer knows to be false.

(b) A lawyer who represents a client in an adjudicative proceeding and who knows that a person intends to engage, is engaging or has engaged in criminal or fraudulent conduct related to the proceeding shall take reasonable remedial measures, including, if necessary, disclosure to the tribunal.

(c) The duties stated in paragraphs (a) and (b) continue to the conclusion of the proceeding, and apply even if compliance requires disclosure of information otherwise protected by Rule 1.6.

Rule 3.4. Fairness to Opposing Party and Counsel. A lawyer shall not:

(a) Unlawfully obstruct another party’s access to evidence or unlawfully alter, destroy or conceal a document or other material having potential evidentiary value. A lawyer shall not counsel or assist another person to do any such act;

(b) Falsify evidence,

(d) In pretrial procedure, … fail to make reasonably diligent effort to comply with a legally proper discovery request by an opposing party;

Rule 3.5. Impartiality and Decorum of the Tribunal

(a) A lawyer shall not seek to influence a judge, juror, prospective juror or other official by means prohibited by law.

(b) A lawyer shall not communicate ex parte with a judge, juror, prospective juror or other official except as permitted by law.

TRANSACTIONS WITH PERSONS OTHER THAN CLIENTS

Rule 4.1. Truthfulness in Statements to Others.

In the course of representing a client a lawyer shall not knowingly:

(a) Make a false statement of material fact or law to a third person; or

(b) Fail to disclose a material fact to a third person when disclosure is necessary to avoid assisting a criminal or fraudulent act by a client, unless disclosure is prohibited by Rule 1.6.

Rule 4.4. Respect for Rights of Third Persons.

(a) In representing a client, a lawyer shall not use means that have no substantial purpose other than to embarrass, delay, or burden a third person, or use methods of obtaining evidence that violate the legal rights of such a person.

Rule 5.1. Responsibilities of Partners, Managers, and Supervisory Lawyers.

(a) 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.

(b) A lawyer having direct supervisory authority over another lawyer shall make reasonable efforts to ensure that the other lawyer conforms to the Rules of Professional Conduct.

(1) The lawyer orders or, with knowledge of the specific conduct, ratifies the conduct involved; or

(2) The lawyer is a partner or has comparable managerial authority in the law firm in which the other lawyer practices, or has direct supervisory authority over the other lawyer, and knows of the conduct at a time when its consequences can be avoided or mitigated but fails to take reasonable remedial action.

Rule 5.2. Responsibilities of a Subordinate Lawyer.

(a) A lawyer is bound by the Rules of Professional Conduct notwithstanding that the lawyer acted at the direction of another person.

(b) A subordinate lawyer does not violate the Rules of Professional Conduct if that lawyer acts in accordance with a supervisory lawyer’s reasonable resolution of an arguable question of professional duty.

MAINTAINING THE INTEGRITY OF THE PROFESSION

Rule 8.3. Reporting Professional Misconduct.

(a) A lawyer who knows that another lawyer has committed a violation of the Rules of Professional Conduct that raises a substantial question as to that lawyer’s honesty, trustworthiness or fitness as a lawyer in other respects, shall inform the appropriate professional authority.

(b) A lawyer who knows that a judge has committed a violation of applicable rules of judicial conduct that raises a substantial question as to the judge’s fitness for office shall inform the appropriate authority.

Rule 8.4. Misconduct.

It is professional misconduct for a lawyer to:

(a) Violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another;

(b) Commit a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness or fitness as a lawyer in other respects;

(d) Engage in conduct that is prejudicial to the administration of justice;

(f) Knowingly assist a judge or judicial officer in conduct that is a violation of applicable rules of judicial conduct or other law.

Nevada Rules of Civil Procedure

Link to Nevada Rules of Civil Procedure PDF as revised through 10/19/19

Postpone formal charges vs. Judge Kishner

Link to PDF of 3/10/21 email to NCJD requesting postponement of formal charges

Address the need for state civil court reform

Follow the advice of the Pew Charitable Trusts’ study: