The Elements of Abuse of Process apply to all defendants in all related cases
Interpleader complaint was an abuse of process because Defendant Steven Scow named parties who don’t have a claim and because it was filed to obstruct the administration of justice in other cases that were improperly filed, the wrong parties were intentionally named and the correct ones intentionally omitted.
The attorneys in all the related cases have engaged in a massive fraud on the court, involving presenting false evidence,
1. Filing of a lawsuit made with ulterior purpose other than to resolve dispute
Link to “Interpleader Complaint was filed with an ulterior motive“
This interpleader complaint was filed for the corrupt purpose of continuing to obstruct a fair, evidence-based adjudication of Nona Tobin’s claims.
Links to NV Supreme Court cases 82294, 82234, and 82094
The defendants, jointly in concerted action and/or conspiracy, and each one separately,are utilizing this untimely, unwarranted, and harassing interpleader complaint in the corrupt attempt to moot the appeals of their non-meritorious claims in cases A-15-720032-C and A-19-799890-C.
Defendants improperly utilized this and the multiple related civil actions intended to the quiet title following a disputed 2014 HOA foreclosure. Their corrupt purpose was to get the court to bless their clients’ theft of Nona Tobin’s property, and the attorneys of those engaged in racketeering, conspired to cover it up.
Civil actions have been used to steal from Nona Tobin
- Attorneys have presented false evidence, withheld evidence, falsified documents to cover up FirstService Residential dba Red Rock Financial’s predatory debt collection that led to the secret foreclosure sale.
- Attorneys have presented false evidence, withheld evidence, falsified documents, to cover up Steven Scow’s, and other conspirators’ misappropriation of the proceeds o of many secretly-conducted sales.
- Joseph Hong and Melanie Morgan conspired to engineer an ex parte meeting with Judge Kishner in order to derail Nona Tobin’s case.
- Nationstar recording false claims to the title of the subject property to abuse the quiet title litigation process to get a court-sanctioned theft of Nona Tobin’s property.
- Joseph Hong conspired with others to conceal that Jimijack’s void deed had no legal capacity to hold or transfer title.
- Brittany Wood conspired with others not having an admissible deed and then fraudulently conveying it to one of the trustees as an individual.
- Joseph Hong’s and Melanie Morgan’s negotiating a fraudulent deal to steal Nona Tobin’s property that was represented to the court as a Nationstar-Jimijack settlement of all claims, but was actually a contract between non-parties to the litigation.
- Brittany Wood misrepresenting the court record, the facts and the law, in order to evade detection that her clients’ had knowingly received Tobin’s fraudulently conveyed property.
2. Wilfull act in the use of legal process not proper in the regular conduct of the proceeding
Steven Scow named five defendants in the interpleader complaint when he knew that four of those defendants had already recorded releases of their claims.
Link to Nona Tobin’s 3/15/21 Request for Judicial Notice of the Clark county Recorder’s Office records for APN 191-13-811-052.
Steven Scow’s allegations in the complaint were false and were for the corrupt purpose of evading detection that he misappropriated the proceeds of this 8/15/14 foreclosure sale and a dozen other Sun City Anthem foreclosures that were secretly, and without legal authority, conducted by Red Rock Financial Services in 2014.
Steven Scow has unlawfully retained the proceeds from multiple HOA foreclosures in an unauthorized, unaudited attorney trust account.
Link to “HOA debt collectors yield an unlawful amount of power“
Link to Sun City Anthem bylaws 3.20/3.18 (annotated) prohibition of the delegation of certain Board duties and the Board’s loss of control of funds collected for the benefit of the HOA
Link to “SCA board secretly sold a dozen houses in 2014“
Link to “We can learn a lot from this Spanish Trail HOA case“
3. Damages as a direct result of the abuse
Links to NV Supreme Court cases 82294, 82234, and 82094 that the co-conspirator defendants are attempting to moot by this unwarranted and harassing interpleader complaint.
Steven Scow filed the interpleader action more than six years after he failed to distribute the $57,282.32 excess proceeds from the 8/15/14 sale
Nevada law required the proceeds to be distributed after the sale
The HOA foreclosure sale was conducted on 8/15/14, and the 2013 statutes applied.
Link to NRS 116.3116-NRS 116.31168 (2013) – the applicable 2013 NRS provisions governing HOA foreclosures
Links to SCA 223-224 and RRFS 047-048 show Steven Scow was instructed to interplead the proceeds on 8/28/14.
