SCA’S ATTORNEY also is LOBBYIST against you the homeowner.  RED FLAG!

This is a re-print of an email that was circulating this weekend about SB 417, a very anti-homeowner bill that has tentative approval going forward and needs strong opposition from HOA homeowners to turn the tide.

Here is a link to the Nevada State Legislature’s website to get more information or track the bill. If you want to oppose SB 417 directly online, you just register up in the righthand corner. It’s free.

https://www.leg.state.nv.us/App/NELIS/REL/82nd2023/Bill/10426/Overview

Subject: SCA’S ATTORNEY also is LOBBYIST against you the homeowner.  RED FLAG! by Robert Stern.

By allowing Adam Clarkson to serve as the weaponized counsel for SCA to stifle free speech, to abuse power and disrespect the rule of law, the current board members are each one of the evil doers that ignore enforcement of the governing documents if it doesn’t fit their political agenda and goals. It’s even worse as they allow a self-serving COO to exercise her control to protect both hers and Clarkson’s gravy train.

This current board is a disgrace and a huge cancer on the future of SCA as its failed leadership thinks it’s coalition will sustain its mismanagement of power indefinitely. Hopefully the electorate over the next two elections will rid the community of the financially incompetent spenders and their disdain for the homeowners they were elected to govern. Adam Clarkson’s firm ought to be immediately relieved of its duties before more harm is done to homeowners.

Adam Clarkson of the Common Associations Institute, the lobbying arm of HOA management companies, says the state’s Real Estate Division receives “a lot of complaints from people that are just routine fighters,” and noted the bill would allow boards to prevent those people from serving on the board.

“They are not the kind of people who should be on the board,” Clarkson said. “They are not good people.”

Adam Clarkson, CAI Lobbyist, SCA attorney & debt collector

What it really is is an assault to stifle homeowner free speech and resistance to bad and fiscally irresponsible governance. Follow the money. Clarkson and his firm represent SCA’s Sandy Seddon and the board in SCA matters. Not good.

Samuel Covelli, a retired corrections officer in Las Vegas, says he was “stonewalled” when he asked his HOA for financial information. “this whole process is horribly slanted against a homeowner.”

The bill allows an association to ban a homeowner from serving on an HOA board for up to 10 years for filing a vexatious, defamatory, or  false complaint with the state, and allows board members or staff to use HOA funds to recover compensatory damages, attorneys fees, and costs from a person who takes “retaliatory action,” as determined by the State Real Estate Division( NRED).

And NRED is no friend to the ordinary homeowner. This is an attack against you the homeowner that is designed to ensure attorneys fees and power. Follow the money.

And SCA’s Weaponized counsel under Sandy Seddon and like minded board members must be gotten rid of. It is already happening and Clarkson, Seddon and certain board members must not have censorship power over you. This and future elections matter.

Las Vegas homeowner Michael Kosor says the measure is an assault on the First Amendment and serves to chill opposition to HOA governance. He says it’s also  “a rainmaker for the attorneys and management companies.”
Kosor says defamatory speech is already prohibited. The legislation, he says, allows the association to determine what is defamatory and gives the association “the ability to censor free speech based on opposing positions from that of the board.” RED FLAG!

Las Vegas homeowner Michael Kosor

Southern Highland’s developer Garry Goett’s Olympia Companies sued Kosor for defamation over statements made on-line and in-person at HOA meetings. Kosor prevailed before the Nevada Supreme Court.

“I’m a retired Air Force colonel fighter pilot with combat experience in the Gulf War,” Kosor testified Tuesday. “This experience defending the attacks of this developer on my family’s financial future was in total the most stressful experience of my life.”

retired Air Force colonel fighter pilot Michael Kosor

Kosor contends Goett has erroneously maintained control of the Southern Highlands board. He’s presented what he says is evidence to the state, but NRED has refused to investigate. SB 417 would codify the state’s ability to pick and choose investigations.


“There’s an imbalance of power between homeowners and homeowners’ associations and management companies,” Las Vegan Howard McCarley testified in opposition to the bill.  “Extensive financial resources are available to associations and managers. Residents are on their own.”

Las Vegan Howard McCarley

PROTECT YOUR POCKETBOOK AND FREE SPEECH. If you haven’t voted yet, please find your ballot and vote only for Pamela Williams (Ballot position #1) and Rick Ernest (Ballot Position #2). And please ask one more person who hasn’t voted to cast their ballot.
And be ready to support candidates in 2024 that will rid us of Seddon and Clarkson and likeminded board members.
The Community you save may be your own.

A-21-828840-C Orders are “void, not voidable merely”

“Disqualification occurs when the facts creating disqualification arise, not when disqualification is established.”); see also Hoff v. Eighth Judicial Dist. Court, 79 Nev. 108, 110, 378 P.2d 977, 978 (1963) (“That the actions of a district judge, disqualified by statute, are not voidable merely, but void, has long been the rule in this state.”); Frevert v. Smith, 19 Nev. 363, 11 P. 273 (1886) (“[T]he general effect of the statutory prohibitions … [is] to render those acts of a judge involving the exercise of judicial discretion, in a case wherein he is disqualified from acting, not voidable merely, but void.”). ”

Debiparshad v. The Eighth Judicial Dist. Court of State, 137 Nev. Adv. Op. 71, 9-10 (Nev. 2021)

A-21-828840-C Orders Are Void

9/10/2021 Doc ID# 43 “Order & Judgment On Plainiff (Sic) Red Rock Financial Services, LLC’s Motion To Dismiss Counterclaimant Nona Tobin’s Counterclaim And Petition For Sanctions And Defendants/ Counterclaimant Nona Tobin’s Motion For Summary Judgement And Motion For Sanctions”

11/30/2021 Doc ID# 70 Order Clarifying Sept. 10th, 2021 Order and Mooting Notice of Default and Motion to Strike

11/30/2021 Doc ID# 71 Order Denying Nona Tobin’s Motion to Reconsider of Order Dismissing Nona Tobin’s Counterclaim and Petition for Sanctions and Defendant/ Counter-claimant Nona Tobin’s Motion for Summary Judgment and Motion for Sanctions

5/25/2022 Doc ID# 88 Order Denying Nona Tobin’s Motion For An Evidentiary Hearing To Set Aside 9/10/21 Order And 11/30/21 Orders Pursuant To NRCP 60(b)(3)(Fraud) And NRCP 60(d)(3)(Fraud On The Court) And Motion For Attorneys’ Fees And Costs Pursuant To EDCR 7.60(1) And (3), NRS 18.010(2); And, Denying non-party Red Rock LLC’s 12/28/21 Countermotions For Abuse Of Process and Denying non-party Red Rock LLC’s motion For A Vexatious Litigant Restrictive Order Against Nona Tobin And denying For Attorney Fees And Costs

1/9/2023 01/09/2023 Order Doc ID# 115 Order Granting in Part and Denying in Part Nona Tobin’s Second Amended Motion for an Order to Distribute Interpleaded Funds with Interest to Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant to NRS 18.010(2) and EDCR 7.60(b)(1) and (3) and Motin to Correct Nunc Pro Tunc Notices of Entry of Orders Entered on November 30 2021 and May 25 2022 and Granting in Part Red Rock Financial Services’ Countermotion for Abuse of Process; for a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs

1/16/2023 Doc ID# 117 Order Granting in Part and Denying in Part Nona Tobin’s Second Amended Motion for an Order to Distribute Interpleaded Funds with Interest to Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant to NRS 18.010(2) and EDCR 7.60(b)(1) and (3) and Motion to Correct Nunc Pro Tunc Notices of Entry of Orders Entered on November 30 2021 and May 25 2022 and Granting in Part Red Rock Financial Services’ Countermotion for Abuse of Process; for a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs

Vexatious litigant restrictive bench order improperly issued without notice ex parte

2/10/23 not knowing what was going on behind my back,

I turned a proposed order into the court pursuant to EDCR 2.23(b) to grant several unopposed orders as because no one filed an a timely written opposition pursuant to EDCR 2.20(e)

If a party doesn’t file a written opposition to a motion, the court should grant the motion as unopposed. Judge Peterson excused Nationstar and Red Rock from this requirement repeatedly in this case.

“Within 10 days after the service of the motion, and 5 days after service of any joinder to the motion, the opposing party must serve and file written notice of nonopposition or opposition thereto, together with a memorandum of points and authorities andsupporting affidavits, if any, stating facts showing why the motion and/or joinder should be denied. Failure of the opposing party toserve and file written opposition may be construed as an admission that the motion and/or joinder is meritorious and a consent to granting the same.”

EDCR 2.20(e)

Order granting motions pursuant to EDCR 2.20(e)

EDCR 2.23(b) is a procedural rule telling the movant to draft an order granting the motion and submit it to the judge’s chambers for signatuere if there is no written opposition.

When I followed this rule, Judge Peterson told me to stop or she would issue an order for me to show cause why I shouldn’t be held in contempt. Then she out of the blus, skipped that step and entered a vexatious litigant restrictive order against me. That means that any compaint or motion or opposition I want to file has to first be approved by Judge Peterson and the Chief Judge of the 8th Judicial District Court. Completely unjustified and pretty annoying.

“EDCR 2.23(b) If the time to oppose a motion has passed and no opposition has been filed, counsel for the moving party may submit an order granting the motion pursuant to Rule 2.20 to the chambers of the assigned department.

EDCR 2.23(b)

I was shocked by the court’s 2/15/23 rejection email (without these details) that :

1) there was an ex parte hearing on 2/2/23;

2) the court exempted my opponents unfairly from the court rule (EDCR 2.20(e)) that requires filing a written opposition to a motion,

3) my unopposed 1/23/23 motions scheduled for hearing on 2/28/23 were denied in my absence on 2/2/23, and

My motions were scheduled to be heard on 2/28/23
My motions, scheduled to be heard on 2/28/23, were denied in my absence on 2/2/23. These minutes were published on the website, but not served on the parties, on 2/2/23, and they inaccurately misrepresent that the judge decided the matter in chambers with no one present. However, the judge met ex parte with my opponents as is show in the transcript that was published in the court record on 3/3/23 (2/2/23 ex parte transcript)

4) I was unjustly declared a vexatious litigant in absentia four hours before I filed my opposition to Nationstar’s 1/24/23 motion to have me declared one.

I submitted a new proposed order for the court to deny all my motions on the grounds that EDCR 2.20(e) was not apparently not applicable to my opponents.

I attached 230216 order denying all motions

My proposed order wrote the true facts and the conclusions of law the judge was actually nonsensically drawing.

Steven Scow responded that the court asked him to prepare the order and that he would CIRCULATE it (typically this means approve as to form and content)

The court just rejected my order without specifying a reason.

I resubmitted a detailed request emphasizing how wrong it was to have Steven Scow write an ex parte order given that 1) Scow misrepresents material facts repeatedly, 2) the court did not consider my oppositions; and 3) neither the court nor my opponents complied with court rules when they ex parte deprived me of my substantive rights.

The court reiterated its rejection and just said NO

The court stubbornly insists that i chose not to attend a hearing for which I had no notice and that on 1/23/23 I requested be vacated as moot. See below.

I received no notice of the 2/2/23 hearing. I did not receive a phone call like the court claimed in the transcript.

If the court called, why wouldn’t I have gotten a message? Did they dial the wrong number? Did they only let it ring once? Why didn’t the court send me a Bluejeans link to appear like the court sent for every other hearing i ever went to since this case began in February 2021.
Ex parte communications are improper when they damage the absent party. I don’t see how the judge can think she is being fair by telling them it is not necessary for them to file an opposition to my 1/23/23 motion to reconsider that she was just going to deny it.

On 1/23/23 I had requested that the 2/2/23 hearing be vacated as moot.

I did not receive a Bluejeans link for the 2/2/23 hearing. There was no timely written opposition filed from either of the two attorneys who were specifically agendized for 2/2/23 (Wood and Hong). Neither Turley nor Scow were scheduled on the 2/2/23 agenda

NCJC 2.9 ex parte communications are impermissible if it allows a “procedural, substantive, or tactical advantage” over the absent party

ABA standard 6.31b recommends disbarment if this type ex parte communication is orchestrated by an attorney

By 2/21/23, published Court minutes of the 2/2/23 ex parte hearing did not show my 12/19/22 motion for an order to show cause why written finding should not be forwarded to the State Bar so I submitted another unopposed order granting the motion pursuant to EDCR 2.20(e)

Apparently Judge Jessica Peterson thinks it is outrageous that attorneys should be held to any ethical standards.

Here was her answer:

Go away. Shut up.

“The next submission into OIC will result in the court issuing an order to show cause as to why you should not be held in contempt.”

2/21/23 Judge Peterson

3/28/23 – without issuing an order to show cause, and without another peep from me, the court entered a vexatious litigant restrictive order against me for what?

I think Judge Peterson’s impartiality can reasonably be questioned.

Is it unreasonable for me to have to tried to move the court to hold the attorneys, banks or debt collectors accountable to the rule of law and professional ethics standards?

Here are links to the 3/28/23 restrictive order and denial of my 12/19/22, 1/3/23, and 1/23/23 motions in absentia ex parte on 2/2/23 with opposition filed only to the 1/3/23 motions by Red Rock on 1/17/23 and by Nationstar on 1/24/23.

The court denied all my motions and did not consider the motions and replies I filed on these dates 12/14/21, 1/10/22, 1/10/22, 5/30/22, 6/27/22, 2/2/23, 2/20/23 to say that Red Rock and Nationstar should not be listened to because, basically, they are lying to cover up that they are stealing, they don’t have standing to oppose me for various other different reasons.

My 12/19/22 and 1/23/23 motions should have been granted as unopposed, just as my 3/8/21 and 6/27/22 motions should have been granted as unopposed.

but because

Judge Peterson doesn’t think the court rules apply equally to everybody, she’s telling me to shut up when I say that the attorneys are covering up fraud that frequently involves felonies, and she’s oblivious to the fact that the attorneys are lying about everything that matters.

The bottom line

Basically, everything I file is asking the court to look at the evidence because ALL THE VERIFIED EVIDENCE SUPPORTS MY CLAIMS AND NONE SUPPORTS MY OPPONENTS.

Conversely, everything my opponents file is sn opposition to me that they have on standing to make or it is a harassing motion to restrict my access to an evidence -bsed adjuciation of my legitimate claims by an impartial tribunal because NONE OF THE EVIDENCE SUPPORTS THEIR CLAIMS AGAINST ME.

That’s why no court in seven years of litigation has ever held an evidentiary hearing. Even the quiet title trial in 2019 had all the documentary evidence, witnesses, and real parties in interest exlcuded. I’m not kidding.

Vexatious litigant restrictive order was unjustly filed without notice or chance to oppose

The draft order was sent to me when it was sent to the judge for signature on Friday afternoon, 3/24/23 .

On Tuesday, 3/28/23, the judge had already signed it, filed it, and it was in effect.

My Request for time to oppose it properly was ignored

3/28/23 request for 30 days on the grounds that it was unfairly adopted at an ex parte hearing and Steven Scow had been given 50 days to prepare the order and the order was fraught with fraudulent misrepresentations of material facts

4/5/23 request to at least attached the opposition that I was able to prepare on 3/27/23 to the order is pending before the Chief Judge who no must review all documents before I can file them in court.

The screenshots below are my corrections to the factual inaccuracies in the order.

Obviously, it would be slightly deceptive to have an appeals court judge see the order as filed and not see that I really did want to oppose it, if given a fair chance.

A-21-828840-C court record

A-21-828840-C COURT RECORD

Date  Doc #Court Record
4/1/23 Register of Actions
2/3/20211Doc ID# 1 Initial Appearance Fee Disclosure
02/03/212Doc ID# 2 Complaint for interpleader
02/03/213Doc ID# 3 Electronic Summons for Nona Tobin, as an individual and as trustee for the Gordon B. Hansen Trust, dated 8/22/08
2/9/20217Doc ID# 7 Notice of Department Reassignment
2/17/20218Doc ID# 8 Affidavit of service-Republic Services
2/17/20219Doc ID# 9 Affidavit of service- Wells Fargo
2/17/202110Doc ID# 10 Affidavit of service Nona Tobin, as an individual served via attorney John Thomson
2/17/202111Doc ID# 11 Affidavit of service-Nona Tobin as trustee of the Hansen Trust served via attorney John Thomson
2/17/202112Doc ID# 12 Affidavit of service-Nationstar
2/17/202113Doc ID# 13 Disclaimer of interest – Republic Services
3/8/202114Doc ID# 14 Nona Tobin’s Answer, Affirmative Defenses, And Counter-Claim vs. Red Rock Financial Services, Cross-Claims vs. Nationstar Mortgage LLC And Wells Fargo, N.A., And Motion For Sanctions vs. Red Rock Financial Services And Nationstar Mortgage LLC, and/or Nationstar Mortgage dba Mr. Cooper Pursuant To NRCP 11(b)(1)(2)(3) and/or(4), NRS 18.010(2), NRS 207.470(1), NRS 42.005
3/15/202115Doc ID# 15 Request for Judicial Notice
Nona Tobin’s Request for Judicial Notice of the Complete Official Clark County 2003-2021 Property Records for APN 191-13-811-052
3/22/202116Doc ID# 16 Initial Appearance Fee Disclosure for Nona Tobin an Individual
3/22/202117Doc ID# 17 Nona Tobin’s Third-Party Complaint 1. Abuse Of Process; 2. Racketeering (NRS207.360(9)(18) (29)(30) (35); NRS 207.390, NRS 207.400(1)(2); 3. Fraud NRS 205.330, NRS 205.360, NRS 205.372, NRS 205.377, NRS 205.395, NRS 205.405, NRS 111.175; 4. Restitution And Relief Requested Exceeds $15,000 5. Exemplary And Punitive Damages Pursuant To NRS 42.005, NRS 207.470(1) & (4) 6. Sanctions Pursuant To NRCP 11(b)(1-4); NRPC 3.1, 3.3, 3.4,3.5(b), 4.1, 4.4, 5.1, 5.2, 8.3, 8.4 vs. Steven B. Scow; Brody R. Wight; Joseph Hong; Melanie Morgan; David Ochoa; Brittany Wood
4/4/202118Doc ID# 18
Nona Tobin’s Request for Judicial Notice of Relevant Unadjudicated Civil Claims and Administrative Complaints
4/7/202119Doc ID# 19
Nona Tobin’s Request for Judicial Notice of the Nevada Revised Statutes, Nevada Rules of Civil Procedure, Nevada Rules of Professional Conduct and Sun City Anthem Governing Documents Germane To the Instant Action
4/9/202120Doc ID# 20 Wells Fargo, N.A. and Nationstar Mortgage LLC’s Answer to Red Rock Financial Services’ Complaint for Interpleader (NRCP 22)
4/9/202121Doc ID# 21
Nona Tobin’s Request for Judicial Notice of NRCP 16.1 Disclosures and Subpoena Responses from Discovery in Case A-15-720032-C and Disputed Facts in the Court Record
4/12/202122Doc ID# 22 Nona Tobin’s Amended Motion for an Order to Distribute Interpleaded Proceeds with Interest to Sole Claimant Nona Tobin
4/14/202123Doc ID# 23 CNONCD Clerk’s Notice of Nonconforming Document (failed to say whether hearing was requested)
4/16/202124Doc ID# 24 Counter-Claimant & Cross-Claimant Nona Tobin’s Motion for Summary Judgment vs. Counter-Defendant Red Rock Financial Services and Cross- Defendants Nationstar Mortgage LLC & Wells Fargo, N.A. and Motion for Punitive Damages and Sanctions Pursuant to NRCP 11(b)(1)(2)(3) and/or(4), NRS 18.010(2), NRS 207.401(1) and/or NRS 42.005
4/16/202125Doc ID# 25 Clerk’s notice of hearing Tobin’s amended motion (22) for an order to distribute on 5/18/21
4/16/202126Doc ID# 26 Clerk’s Notice of Nonconforming Document and Curative Action
4/16/202127Doc ID# 27 Clerk’s 7:39AM notice of hearing Tobin MSJ (24) and petition for sanctions on 5/18/21
4/16/202128Doc ID# 28 Non-party Red Rock Financial Services, LLC’s Motion to Dismiss Counterclaimant Nona Tobin’s Counterclaim and Petition for Sanctions (14)
29Doc ID# 29 Clerk’s notice of hearing on 5/18/21 Non-party Red Rock LLC’s untimely motion (28) to dismiss Tobin’s Counterclaim and Petition for Sanctions (14)
4/26/202130Doc ID# 30 Nona Tobin’s Opposition to Red Rock Motion to Dismiss (28) Tobin’s Counter-Claims and Motion for Sanctions (14) Pursuant to NRCP 11(b)(1)(2)(3) and/or (4), NRS 18.010(2), NRS 207.40(1), NRS 42.005
4/26/202131Doc ID# 31 Wells Fargo, N.A. and Nationstar Mortgage LLC’s Limited Opposition to Defendant Nona Tobin’s Motion for an Order (22) to Distribute Interpleaded Proceeds
4/27/202132Doc ID# 32 Non-party Red Rock Financial Services, LLC’s rogue Joinder to Wells Fargo, N.A. and Nationstar Mortgage LLC’s Limited Opposition (31) to Defendant Nona Tobin’s Motion for an Order to Distribute Interpleaded Proceeds (22)
4/29/202133Doc ID# 33 Red Rock Financial Services’ Opposition to Nona Tobin’s Motion for Summary Judgment (24)
5/3/202134Doc ID# 34 Wells Fargo, N.A. And Nationstar Mortgage LLC’s untimely Joinder To Red Rock Financial Services, LLC’s rogue Motion To Dismiss (28) Counter-claimant Nona Tobin’s Counter-claim And Petition For Sanctions (14)
5/4/202135Doc ID# 35 Nona Tobin’s Reply To Nationstar’s & Wells Fargo’s Opposition To Tobin’s Motion To Distribute Proceeds (22) And To Their Untimely Joinder (31) To Red Rock’s rogue Motion To Dismiss (28) And Tobin’s Reply To Support Tobin’s Motion For Summary Judgment Vs. Nationstar & Wells Fargo (24)
5/5/202136Doc ID# 36 Wells Fargo, N.A. And Nationstar Mortgage LLC’s Joinder To Red Rock Financial Services’ Opposition To Nona Tobin’s Motion For Summary Judgment (24)
5/9/202137Doc ID# 37 Nona Tobin’s Reply To Red Rock’s Joinder To Nationstar’s & Wells Fargo’s Opposition To Tobin’s Motion To Distribute Proceeds
5/9/202138Doc ID# 38 Nona Tobin’s Reply To Red Rock’s Opposition To Motion For Summary Judgment And Motion To Amend Third Party Complaint
5/11/202139Doc ID# 39 Non-Party Red Rock LLC’s Rogue Reply In Support Of Its Motion To Dismiss Counterclaimant Nona Tobin’s Counterclaim And Petition For Sanctions
6/22/202140Doc ID# 40 NOTICE OF APPEARANCE – JOHN THOMSON FOR NONA TOBIN
6/26/202141Doc ID# 41 STIPULATION AND ORDER – MOVE EVIDENTIARY HEARING TO 8/18/21by stipulation, changed manually by the court to 8/19/21
7/27/202142Doc ID# 42 NOTICE OF ENTRY OF STIPULATION AND ORDER – MOVE EVIDENTIARY HEARING TO 8/19/21
9/10/202143Doc ID# 43 “ORDER & JUDGMENT ON PLAINIFF (SIC) RED ROCK FINANCIAL SERVICES, LLC’S MOTION TO DISMISS COUNTERCLAIMANT NONA TOBIN’s COUNTERCLAIM AND PETITION FOR SANCTIONS AND DEFENDANTS/ COUNTERCLAIMANT NONA TOBIN’s MOTION FOR SUMMARY JUDGEMENT AND MOTION FOR SANCTIONS”
9/10/202144Doc ID# 44 Notice of Entry of Order & Judgment granting non-party Red Rock LLC’S rogue Motion to Dismiss Tobin’s Counterclaim, Petition For Sanctions And Tobin’s Motion For Summary Judgement against counter-defendant Red Rock
9/15/202145[45] Substitution of Attorneys for Tobin from John Thomson to Taylor Simpson, Suzanne Carver, P. Kerr Sterling
10/8/202146[46] Motion for Reconsideration
10/11/202147[47] Notice of Hearing Motion for Reconsideration
8/19/202148[48] Transcript of Proceedings 8/19/21
10/12/202149[49] Notice of Voluntary Dismissal of Third-Party Claims Without Prejudice
10/13/202150Doc ID# 50 Notice of Voluntary Dismissal Without Prejudice
10/13/202151Doc ID# 51 Notice of Entry of Order
10/21/202152Doc ID# 52 Wells Fargo, N.A. and Nationstar Mortgage LLC’s Opposition to Nona Tobin’s Motion for Reconsideration
10/22/202153Doc ID# 53 Non-party Red Rock Financial Services LLC’s rogue Opposition to Motion for Reconsideration of Order Dismissing Nona Tobin’s Counterclaim and Petition for Sanctions
10/29/202154Doc ID# 54 Tobin Reply in Support
11/9/202155Doc ID# 55Notice of Change of Hearing (from 10 AM to 8 AM
11/9/202156Doc ID# 5611/09/2021 Motion for Withdrawal
11/9/202157Doc ID# 57 DECLARATION OF NONA TOBIN IN SUPPORT OF MOTION TO RECONSIDER ORDER ENTERED SEPTEMBER 10, 2021
11/10/202158Doc ID# 58 Ex Parte Application for an Order Shortening Time
11/10/202159Doc ID# 59 Clerk’s Notice of Hearing
11/10/202160Doc ID# 60 Nona Tobin’s Three-Day Notice of Intent to Take Default vs. Wells Fargo, N.A. as to Tobin’s Cross-Claims Filed on March 8, 2021
11/10/202161Doc ID# 61 Notice of Intent to Take Nationstar’s Default
11/11/202162Doc ID# 62 Motion to Withdraw As Counsel
11/12/202163Doc ID# 63 Clerk’s Notice of Hearing
11/14/202164Doc ID# 64 Declaration
11/15/202165Doc ID# 65 Clerk’s Notice of Hearing
11/15/202166Doc ID# 66 Motion to Strike
11/15/202167Doc ID# 67 Clerk’s Notice of Hearing
11/17/202168Doc ID# 68 Order to Withdraw as Attorney of Record
11/19/202169Doc ID# 69 Notice of Entry of Order
11/30/202170Doc ID# 70
Order Clarifying Sept. 10th, 2021 Order and Mooting Notice of Default and Motion to Strike
11/30/202171Doc ID# 71
Order Denying Nona Tobin’s Motion to Reconsider of Order Dismissing Nona Tobin’s Counterclaim and Petition for Sanctions and Defendant/Counterclaimant Nona Tobin’s Motion for Summary Judgment and Motion for Sanctions
11/30/202172Doc ID# 72 Notice of Entry of Order Clarifying September 10, 2021 Order And Mooting Notice of Default and Motion to Strike
11/30/202173Doc ID# 73 Denial of Motion to Reconsider
11/16/202174Doc ID# 74 Recorders Transcript of Hearing Re: Defendant/ Counterclaimant’s Motion for Reconsideration 11/16/21
12/14/202175Doc ID# 75 Nona Tobin’s Motion for an Evidentiary Hearing to Set Aside Orders and for Sanctions Pursuant to NRCP 60(B)(3) and (D)(3), NRS 18.010(2) and EDCR 7.60 (1) and (3)
12/14/202176Doc ID# 76 Notice of Hearing
12/28/2177Doc ID# 77 Non-party Red Rock Financial Services LLC’s rogue Opposition to Nona Tobin’s Motion for an Evidentiary Hearing to Set Aside September 10, 2021 Order and November 30, 2021 Orders Pursuant to NRCP 60(b)(3) (Fraud) and NRCP 60 (d)(3) (Fraud on the Court) and Motion for Attorneys’ Fees and Costs Pursuant to EDCR 7.60(b)(1) and (3), NRS 18.010(2); and, Countermotion for Abuse of Process; For a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
12/29/202178Doc ID# 78 Notice of Appearance “Aaron D. Lancaster, Esq., of Troutman Pepper LLP, will appear as Counsel for Defendant, Wells
Fargo, N.A. and Nationstar Mortgage LLC.” No IAFD. No SUBT. No Signature from Wells Fargo, Nationstar, or Akerman. “Gary Schnitzer, of Kravitz Schnitzer Johnson Watson & Zeppenfeld, Chtd., the office of which is located within the State of Nevada at 8985 S. EasternAvenue, Suite 200, Las Vegas, Nevada 89123, has agreed to serve as the Designated Attorney forservice of papers, process, or pleadings required to be served on the attorney, Aaron D. Lancaster, Esq., including service by hand delivery or facsimile transmission, as Troutman Pepper LLP does not maintain an office in the State of Nevada.”
12/29/202179Doc ID# 79 Wells Fargo and Nationistar’s Joinder to Defendant Red Rock Financial Services LLC’s Opposition to Nona Tobin’s Motion for an Evidentiary Hearing to Set Aside September 10, 2021 Order and November 30, 2021 Orders Pursuant to NRCP 60 (b)(3) (Fraud) and NRCP 60 (b)(3) (Fraud on the Court) and Motion for Attorneys’ Fees and Costs Pursuant to EDCR 7.60 (1) and (3) NRS 18.010 (2); and Countermotion for Abuse of Process; for a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
1/10/202280Doc ID# 80 Nona Tobin’s Reply to Red Rock Financial Services LLC’s Opposition to Nona Tobin’s Motion for an Evidentiary Hearing to Set Aside September 10, 2021 Order and November 30, 2021 Orders Pursuant to NRCP 60(b)(3) (Fraud) and NRCP 60(b)(3) (Fraud on the Court) and Motion for Attorneys’ Fees and Cots Pursuant to EDCR 7.60(1) and (3), NRS 18.010(2); and, Countermotion for Abuse of Process for a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
1/10/202281Doc ID# 81 Nona Tobin’s Reply To Nationstar’s And Wells Fargo’s Joinder And Countermotions For Attorney Fees And A Vexatious Litigant Order
1/11/202282Doc ID# 82 Notice of Change of Hearing
1/14/202283Doc ID# 83 Order Granting Akerman s Motion to Withdraw as Counsel for Wells Fargo, N.A. and Nationstar Mortgage LLC
1/19/202284Doc ID# 84 Notice of Entry of Order Granting Akerman s Motion to Withdraw as Counsel for Wells Fargo, N.A. and Nationstar Mortgage LLC
1/19/202285Doc ID# 85 Recorders Transcript of Hearing Re: 01/19/22
4/26/202286Doc ID# 86 Notice of Appearance No IAFD. No SUBT. No authorization by nationstar or Wells Fargo. Aaron Lancater notices begin “VANESSA M. TURLEY, of Troutman Pepper LLP, is admitted and authorized to practice in this Court, and will appear as Counsel for Defendant, Wells
Fargo, N.A. and Nationstar Mortgage LLC.”
5/25/202288Doc ID# 88 Order Denying Nona Tobin’s Motion For An Evidentiary Hearing To Set Aside 9/10/21 Order And 11/30/21 Orders Pursuant To NRCP 60(b)(3)(Fraud) And NRCP 60(d)(3)(Fraud On The Court) And Motion For Attorneys’ Fees And Costs Pursuant To EDCR 7.60(1) And (3), NRS 18.010(2); And, Denying non-party Red Rock LLC’s 12/28/21 Countermotions For Abuse Of Process and Denying non-party Red Rock LLC’s motion For A Vexatious Litigant Restrictive Order Against Nona Tobin And denying For Attorney Fees And Costs
5/25/202289[89] Notice of Entry of Order Denying Nona Tobin’s Motion For An Evidentiary Hearing To Set Aside 9/10/21 Order And 11/30/21 Orders Pursuant To NRCP 60(b)(3)(Fraud) And NRCP 60(d)(3)(Fraud On The Court) And Motion For Attorneys’ Fees And Costs Pursuant To EDCR 7.60(1) And (3), NRS 18.010(2); And, Denying non-party Red Rock LLC’s 12/28/21 Countermotions For Abuse Of Process and Denying non-party Red Rock LLC’s motion For A Vexatious Litigant Restrictive Order Against Nona Tobin And denying For Attorney Fees And Costs
5/30/202290[90] Second Amended Motion for an Order to Distribute Interpleaded Funds with Interest to Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant to NRS 18.010(2) and EDCR 7.60(b)(1) and (3) and Motion to Correct Nunc Pro Tunc Notices of Entry of Orders Entered on November 30, 2021 and May 25, 2022
5/30/202291Doc ID# 91
Exhibits To Second Amended Motion For An Order To Distribute Interpleaded Funds With Interest To Sole Claimant Nona Tobin And Motion For Attorney Fees And Costs Pursuant To NRS18.010(2) And EDCR7.60(b)(1) And (3) And Motion To Correct Nunc Pro Tunc Notices Of Entry Of Orders Entered On 11/30/21 And 5/25/22
5/31/202292Doc ID# 92
Clerk’s Notice of Hearing
6/13/202293Doc ID# 93
Non-party Red Rock Financial Services LLC’s Opposition to Nona Tobin’s Second Amended Motion for An Order to Distribute Interpleaded Funds With Interest to Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant toNRS 18.010(2) and EDCR 7.60(b)(1) and (3) and Motion to Correct Nunc Pro Tunc Notices of Entry of Orders Entered on November 30, 2021 and May 25, 2022; and Renewed Countermotion for Abuse of Process; For a Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
6/21/202294Doc ID# 94
Reply To Non-Party Red Rock LLC’s Opposition To Tobin’s Second Amended Motion For An Order To Distribute Interpleaded Funds With Interest To Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant to NRS 18.010(2) and EDCR 7.60(B)(1) and (3)
6/22/202295Doc ID# 95
Nona Tobin’s Reply To Non-Party Opposition To Motion To Correct Notices Of Entry Of Three Orders
6/27/202296Doc ID# 96
Reponse to Non-Party Red Rock Financial Services, LLC’s Countermotion for a Restrictive Vexatious Litigant Order Against Nona Tobin and Motion for Attorney Fees and Costs and Nona Tobins Counter-Motion to Adopt Tobins Proposed Final Judgment Order
6/30/202297Doc ID# 97
Notice of Appellate Decision
07/07/2022 Motion (10:00 AM) (Judicial Officer Peterson, Jessica K.)
8/29/202298Doc ID# 98
Notice Of Tobin Petition For Writ Of Prohibition And Or Mandamus
9/23/202299Doc ID# 99
Amended Notice of the Filing of a NRAP 40 Motion for Rehearing of Petition for a Writ of Prohibition and/or Mandamus
10/5/2022100Doc ID# 100
Motion for Rehearing Petition for Writ of Prohibition and /or Mandamus
11/28/2022101Doc ID# 101
Notice Of NRAP 40a Petition For En Banc Reconsideration 85251
12/19/2022102Doc ID# 102
Request for Judicial Notice Verified Complaints of Attorney Misconduct filed with the State Bar of Nevada vs. Brittany Wood
12/19/2022103Doc ID# 103
Tobin Motin For An Order To Show Cause Why Written Findings of Attorney Misconduct Should Not Be Forwarded To The State Bar f Nevada
12/19/2022104Doc ID# 104
Request for Judicial Notice Verified Complaint of Attorney Misconduct Filed With The State Bar of Nevada Vs. Steven Scow
12/19/2022105Doc ID# 105
Request for Judicial Notice Verified Complaints of Attorney Misconduct Filed with the State Bar of Nevada vs. Melanie Morgan, Esq. (SBN 8215), Akerman, LLP; and Wright, Finlay, Zak, LLP, and Draft Alternative Civil Action
12/19/2022106Doc ID# 106
Request for Judicial Notice Verified Complaint of Attorney Misconduct Filed With The State Bar of Nevada Vs. Joseph Y. Hong
12/19/2022107Doc ID# 107
Request for Judicial Notice Verified Complaints of Attorney Misconduct Filed With The State Bar of Nevada Vs. David Ochoa, Esq. (SBN 10414) and Adam Clarkson, Esq.
12/20/2022108Doc ID# 108
Corrected Motion for an Order to Show Cause Why Written Findings of Attorney Misconduct Should Not be Forwarded to the State Bar
12/20/2022109Doc ID# 109 Clerk’s Notice of Hearing
12/20/2022110Doc ID# 110 Clerk’s Notice of Hearing
12/20/2022111Doc ID# 111 Clerk’s Notice of Hearing
1/3/20231121/3/23 Motion Doc ID# 112
1) Motion to Withdraw Tobin’s Motion for an Order to Show Cause Why Written Findings of Attorney Misconduct Should Not Be Forwarded to the State Bar And 2) Motion to Withdraw Tobin’s Counter-Claims and Cross-Claims vs. Red Rock, Nationstar and Wells Fargo 3) Motion to Modify Grounds for Tobin’s Petitions for Sanctions vs. Red rock and Nationstar to Include NRS 357.040(1(a),(b),(i), and NRS 199.210, NRS 205.0824 and NRS 205.0833, and NRS 41.1395 And 4) Motion to Adopt Tobin’s Proposed Final Judgment Order
1/3/2023113Doc ID# 113
Response to Motion for an Order to Show Cause Why Written Findings of Attorney Misconduct Should Not Be Forwarded to the State Bar
1/6/20231141/6/23 Clerk’s Notice of Hearing Doc ID# 114
1/9/202311501/09/2023 Order Doc ID# 115
Order Granting in Part and Denying in Part Nona Tobin’s Second Amended Motion for an Order to Distribute Interpleaded Funds with Interest to Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant to NRS 18.010(2) and EDCR 7.60(b)(1) and (3) and Motin to Correct Nunc Pro Tunc Notices of Entry of Orders Entered on November 30 2021 and May 25 2022 and Granting in Part Red Rock Financial Services’ Countermotion for Abuse of Process; for a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
1/10/2023116Notice of Entry of Order Doc ID# 116
1/16/2023117Doc ID# 117
Order Granting in Part and Denying in Part Nona Tobin’s Second Amended Motion for an Order to Distribute Interpleaded Funds with Interest to Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant to NRS 18.010(2) and EDCR 7.60(b)(1) and (3) and Motion to Correct Nunc Pro Tunc Notices of Entry of Orders Entered on November 30 2021 and May 25 2022 and Granting in Part Red Rock Financial Services’ Countermotion for Abuse of Process; for a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
1/17/2023118Doc ID# 118
Notice of Entry of Corrected 1/9/23 Order amended solely to correct the 1/9/23 order to state that Tobin had responded, refused to sign for the reasons identified in the opposition attached to the corrected order.
1/17/2023119Doc ID# 119
Red Rock Financial Services’ Response/Opposition to (1) Motion to Withdraw Tobins Motion for an Order to Show Cause Why Written Findings of Attorney Misconduct Should Not be Forwarded to the State Bar; (2) Motion to Withdraw Tobins Counter-Claims and Cross-Claims vs. Red Rock, Nationstar and Wells Fargo; (3) Motion to Modify Grounds for Tobins Petitions for Sanctions vs. Red Rock and Nationstar to include NRS 357.0401(a), (b), (i) and NRS 199.210, NRS 205.0824 and NRS 205.0833, and NRS 41.1395; and (4) Motion to Adopt Tobins Proposed Final Judgment Order
1/23/2023120Doc ID# 120
Tobin 1/23/23 Motion to Reconsider 1/16/23 Order and Renewed Motion to Strike Non-Party Red Rock Financial Services LLC’s Rogue Filings
1/24/2023121Doc ID# 121
Clerks’ Notice of Hearing
1/24/2023122Doc ID# 122
Wells Fargo and Nationstar’s Joinder to Red Rock Financial Services’ Response//Opposition to (1) Motion to Withdraw Tobin’s Motion for an Order to Show Cause Why Written Findings of Attorney Misconduct Should Not Be Forwarded to The State Bar; (2) Motion to WIthdraw Tobin’s Petitions For Sanctions VS. Red Rock, Nationstar to Include NRS 357.0401(A), (B), (I) and NRS 199.210, NRS 205.0824 and NRS 205.0833, and NRS 41.1395; and (4) Motion to Adopt Tobin’s Proposed Final Judgment Order
1/31/2023123Doc ID# 123
Tobin’s Reply to Red Rock’s Opposition to Tobin’s Four 1/03/23 Motions to Amend Final Order
2/2/2023124Doc ID# 124 Declaration
Declaration of Steven B. Scow in Support of Attorneys’ Fees Awarded to Red Rock Financial Services
2/2/2023125Doc ID# 125 Reply to Opposition
Tobin’s Reply to Nationstar’s Opposition and Vexatious Litigant Motion
2/12/2023126Doc ID# 126 Opposition to Motion
Tobin Opposition To Scow Declaration ISO Attorney Fees
2/16/2023127Doc ID# 127 Memorandum of Costs and Disbursements
Red Rock Financial Services’ Memorandum of Costs and Disbursements as Supplement to Declaration of Steven B. Scow
2/20/2023128Doc ID# 128 Reply to Opposition
Tobin Reply in Opposition to Red Rock 2/16/23 Memo of Fees and Costs
3/3/2023129Doc ID# 129 Court Recorders Invoice for Transcript Ex parte 2/2/23 hearing
2/2/2023 recording fee and transcript
3/3/2023130Doc ID# 130 Recorders Transcript of 2/2/23 ex parte unnoticed Hearing added to court record on 3/3/23
3/28/2023131Order Declaring Nona Tobin a Vexatious Litigant, Order Denying Defendant Nona Tobin’s: (1) Motion to Withdraw Tobin’s Motion for Order to Show Cause why Written Findings of Attorney Misconduct Should no be Forwarded to the State Bar; (2) Moton to Withdraw Tobin’s Counter- Claims and Cross-Claims vs Red Rock, Nationstar and Wells Fargo/ (3) Motion to Modify Grounds for Tobin’s Petitions for Sanctions vs Red Rock and Nationstar to Include NRS 357.404(1)(A), and NRS 199.210, NRS 205.0824 and NRS 205.0833, and NRS 41.1395 and (4) Motion to Adopt Tobin’s Proposed Final Judgment Order and Order Denying Defendant Nona Tobin’s: Motion to Reconsider 1/16/23 Order and Renewed Motion to Strike Non-Party Red Rock Financial Services LLC’s Rogue Filings
3/28/2023132Doc ID# 132
Notice of Entry of Order
4/1/23Register of Actions