Back story of this David vs. Goliath fight
“How did Nona Tobin lose the $500,000 house she inherited from Bruce Hansen? ”
“What happened after Sun City Anthem refused Nona’s 2017 offer to settle?”
“The house that took over a life”
Case Detail A-21-828840-C as of 4/10/21


The instant case: Red Rock Financial Services filed an unwarranted interpleader complaint after unlawfully retaining the proceeds of the disputed HOA sale for over six years.

2013 Nevada law governing the distribution of proceeds after an HOA foreclosure sale was NRS 116.31164(3)

Red Rock’s interpleader prayer for relief is duplicitous as Red Rock conducted a fraudulent sale, and with no legal authority, kept virtually all the money for years.

2/3/21 Red Rock’s Complaint for 1 cause of action: interpleader
2/16/21 Red Rock Complaint was served on 5 defendants
2/17/21 Affidavit of service on Nona Tobin, as trustee of the Gordon B. Hansen Trust, dated 8/22/08
2/17/21 Affidavit of service on Nona Tobin, an individual
2/17/21 Affidavit of service vs. Nationstar Morgage LLC
2/17/21 Affidavit of service on Wells Fargo, N. A.
2/17/21 Affidavit of service on Republic Services, Inc. (garbage)
2/17/21 Republic Services filed a disclaimer of interest within 24 hours of service
2/17/21 Republic Services Disclaimer of Interest

No defendant timely answered Red Rock or filed any counter-claims or cross-claims except Nona Tobin as an individual
3/8/21 Nona Tobin’s answer, affirmative defenses, counter-claim vs. Red Rock and cross-claims against Nationstar and Wells Fargo


Nona Tobin’s 3/8/21 cross-claim against Nationstar and Wells Fargo includes three causes of action: 1) Racketeering, 2) Unjust enrichment/conversion; and 3) Fraud.
As of 4/11/21, no counter-defendant nor cross-defendant has filed a responsive pleading to refute Tobin’s claims against them.
Exhibits to Nona Tobin’s 3/8/21 counter-claims and cross-claims
- APN 191-13-811-052 Clark County Property Record and allegations of fraud vs. all opposing parties
- the sale was void for rejection of assessments.
- The alleged default was cured three times,
- SCA Board did not authorize the sale by valid corporate action
- Required notices were not provided, but records were falsified to cover it up
- SCA Board imposed ultimate sanction with NO due process
- Neither BANA nor NSM ever owned the disputed DOT
- Examples of RRFS corrupt business practices
- Attorneys’ lack of candor to the tribunal
- the proceeds of the sale were not distributed pursuant to NRS 116.31164(3) (2013)
- RRFS’s fraud, oppression & unfairness
- attorney interference in the administration of justice
- lack of professional ethics and good faith
- Presented false evidence to cover up crime
- Civil Conspiracy to cover up racketeering warrants punitive damages
- Republic Services lien releases
- Nona Tobin’s standing as an individual
- Relevant statutes and regulations
- RELEVANT HOA GOVERNING DOCUMENTS PROVISIONS
- Administrative Complaints related to the APN 191-13-811-052 title dispute
- Nevada court cases related to the APN 191-13-811-052 title dispute
- Excerpts of 1/31/17 cross-claim vs. HOA and its agents
Nona Tobin’s 3rd party complaint against six attorneys was filed on 3/22/21 but has not yet been served.
3/22/19 Nona Tobin’s third-party complaint

Nona Tobin’s Requests for judicial notice
3/15/21 RFJN Clark County official property records for APN 191-13-811-052
- 2003 recorded claims
- 2004 recorded claims
- 2007 recorded claims
- 2008 recorded claims
- 2012 recorded claims
- 2013 recorded claims
- 2014 recorded claims
- 2015 recorded claims
- 2016 recorded claims
- 2017 recorded claims
- 2019 recorded claims
- 2020 recorded claims
- 2021 recorded claims
4/4/21 RFJN Unadjudicated claims & administrative complaints
Nona Tobin’s administrative complaints
- 1/28/21 NCJD complaint to the Nevada Commission on Judicial Discipline vs. Judge Joanna Kishner
- “Recommendation to the Nevada Commission on Judicial Discipline”
- 3/14/19 AG complaint vs. Nationstar & Jimijack Irrevocable Trust
- 11/10/20 2nd AG complaint vs Nationstar; Akerman; Wright Finley Zak; Bank of America
- 12/16/20 complaint to the Mortgage Lending Division vs. Nationstar; Akerman; Wright Finley Zak; Bank of America
- 2/14/21 complaint to the State Bar of Nevada vs. Joseph Hong
- 2/16/21 complaint to the State Bar of Nevada vs. Brittany Wood
Nationstar’s and Nona Tobin’s unadjudicated civil claims in prior proceedings. No other party filed any claims.
Nationstar’s dismissed its claims without adjudication
- Nationstar’s 1/11/16 A-16-730078-C complaint Nationstar vs. Opportunity Homes
- Nationstar’s 6/2/16 AACC answer, affirmative defenses and counter-claim vs. Jimijack
- 2/20/19 Nationstar’s stipulation to voluntarily dismiss all its filed claims except against Jimijack.
- 5/31/19 Nationstar’s stipulation to voluntarily dismiss all its filed claims against Jimijack.
Nona Tobin’s unadjudicated pleadings in prior proceedings
- Summary of Nona Tobin’s unadjudicated pleadings
- Nona Tobin’s unadjudicated claims vs. Sun City Anthem
- Nona Tobin’s unadjudicated claims vs. Jimijack
- Nona Tobin’s unadjudicated claims vs. Yuen K. Lee dba F. Bondurant LLC
- Nona Tobin’s unadjudicated claims vs. Thomas Lucas dba Opportunity Homes LLC
- Nona Tobin’s unheard 8/7/19 quiet title & equitable relief, unjust enrichment & abuse of process complaint
Nona Tobin’s unadjudicated district court motions
- 3/3/17 Nona Tobin’s unheard motion to void the sale for statutory non-compliance
- Nona Tobin’s unheard 4/10/19 motion for summary judgment vs. Jimijack Irrevocable Trust
- Nona Tobin’s unheard 4/10/19 motion for summary judgment vs. all parties
- Nona Tobin’s unheard 4/24/19 motion to vacate 4/18/19 order pursuant to NRCP 60(b)(3) and motion for summary judgment
- Nona Tobin’s unheard 6/17/19 motion to intervene as an individual
- Nona Tobin’s unheard 7/22/19 motion for a new trial pursuant to NRCP 54(b) and NRCP 59(a)(1)(A)(B)(C)(F)
- Nona Tobin’s unheard 7/29/19 motion to dismiss for lack of jurisdiction pursuant to NRS 38.310(2)
Orders that disposed Nona Tobin’s claims without any evidentiary hearings
- 8/11/17 order granting Opportunity Homes’s motion for summary judgment vs Nona Tobin and the Hansen Trust that was unfairly filed after order denying Opportunity Homes’s motion for summary judgment vs. Nationstar was entered on 6/22/17.
- 9/20/17 stipulation and order to dismiss Nona Tobin’s and the Hansen Trust’s 1/31/17 cross-claims, except for quiet title, and withdrawing her 3/3/17 motion to void the sale and SCA’s 3/31/17 opposition thereto pending the completion of NRS 38.310 mediation
- 4/18/19 order that granted SCA motion for summary judgment as to the Hansen Trust’s quiet title cause of action and Nationstar’s joinder
- 5/31/19 order denying motion to reconsider 4/18/19 order
- 6/24/19 order granting quiet title to Jimijack who had no deed, denying all the Hansen Trust’s claims, not just quiet title, expunging Nona Tobin’s lis pendens, and declaring the ruling binds non-party Nona Tobin as an individual
- 9/4/19 order that denied Nona Tobin the right to appeal as an individual
- 11/22/19 order that formalized Judge Kishner’s 4/23/19 striking of all Nona Tobin’s individual claims and motions from the court record unheard and expunged her lis pendens
- 4/30/20 order that denied Nona Tobin any right to appeal the 11/22/19 order that declared her a non-party, as an individual, but which bound her to the rulings that excluded her and struck her filings unheard from the court record
- 10/8/20 order that sanctioned Nona Tobin $3,455 to Joel A. Stokes’s attorney pursuant to EDCR 7.60 (1) and/or (3) for filing the A-19-799890-C complaint on 8/7/19, one week before the five-year statute of limitations, after being denied access to the A-15-720032-C 6/5/19 trial.
- 11/17/20 order that sanctioned Nona Tobin $8,849 pursuant to NRS 18.010(2) on the grounds that her filing the A-19-799890-C complaint on 8/7/19, one week before the five-year statute of limitations, was unwarranted and for the sole purpose of harassing Quicken Loans & Brian & Debora Chiesi who recorded claims adverse to Tobin on 12/27/19 while Tobin had two recorded lis pendens.
- 12/3/20 order that dismissed all Nona Tobin’s claims unheard pursuant to NRCP 12(b) (5), on the grounds of non-mutual claims preclusion, and NRCP 12(b)(6) for failure to join the HOA as a necessary party regarding the distribution of the excess proceeds.
Nona Tobin’s pending appeals before the Nevada Supreme Court or the Court of Appeals
- 79295 Gordon B. Hansen Trust vs. Jimijack, Nationstar, Sun City Anthem, Yuen K. Lee dba F. Bondurant LLC
- 82094 Nona Tobin vs. Joel & Sandra Stokes as trustees of Jimijack, Jimijack Irrevocable Trust & Joel A. Stokes, an individual
- 82234 Nona Tobin vs. Quicken Loans LLC and/or Inc. & Brian & Deborah Chiesi
- 82294 Nona Tobin vs. Red Rock Financial Services, Joel & Sandra Stokes as trustees of Jimijack, Jimijack Irrevocable Trust & Joel A. Stokes, an individual, Quicken Loans LLC and/or Inc. & Brian & Deborah Chiesi
4/7/21 RFJN Relevant laws and regulations
- Exhibit 1: 2013 Nevada HOA Lien & Foreclosure Laws
- Exhibit 2: Limits on HOA Board’s authority to impose sanctions
- Exhibit 3: Limits on HOA agents’ & managers’ authority to act
- Exhibit 4: Limits on conveyance of real property
- Exhibit 5: Limits on Fraud and Racketeering
- Exhibit 6: Sanctions & damages
- Exhibit 7: Victim access to remedies
- Exhibit 8: Documentary evidence
- Exhibit 9: Declaratory Judgments
- Exhibit 10: Actions to determine conflicting claims to real property
4/9/21 RFJN evidence and disputed facts in the court record
Exhibit 1: ENTERED BY JOSEPH HONG (NV BAR #5995) FOR JIMIJACK IRREVOCABLE TRUST
12/05/18 Hong response to Tobin interrogatories was all the evidence in the record to support Jimijack’s title claims
Exhibit 2: ENTERED BY MELANIE MORGAN (NV BAR #8215) NATIONSTAR MORTGAGE
- 2/9/18 Initial disclosures
- 2/7/19 1st supplemental disclosures
- 2/12/19 Nationstar 2nd supplemental disclosures NSM 258-403
- 2/27/19 Nationstar 3rd supplemental disclosures NSM 404-408
- 3/12/19 Nationstar 4th supplemental disclosures NSM 404-413
- 2/21/19 Nationstar response to Tobin Interrogatories
- 2/12/19 Nationstar 2nd supplemental disclosures NSM 258-403
- 2/27/19 Nationstar 3rd supplemental disclosures NSM 404-408
- 3/12/19 Nationstar 4th supplemental disclosures NSM 404-413
- 2/21/19 Nationstar response to Tobin Interrogatories
- 2/28/19 Nationstar 1st supplemental response to Tobin Interrogatories
- 2/28/19 Nationstar 1st supplemental response to Tobin Request for documents
EXHIBIT 3: DAVID OCHOA PROFFERED FOR SUN CITY ANTHEM
- 5/31/18 SCA Initial disclosures
- SCA 001-116 Sun City Anthem CC&Rs 2008 3rd restatement
- SCA 117-145 Sun City Anthem bylaws 2008 3rd restatement
- SCA 146-163 Sun City Anthem Rules and Regulations
- SCA 164-167 Sun City Anthem 2007 Red Rock Financial Services Debt Collection contract
- SCA 168-175 Sun City Anthem 2013 Delinquent Assessment Policy
- SCA 176-643 Red Rock Financial Services Foreclosure File redacted
- 2/11/19 SCA 1st supplemental disclosures
- 2/26/19 SCA response to Tobin interrogatories
- 2/26/19 SCA Response to Tobin Request for Documents
- 2/26/19 SCA response to Tobin Request for documents annotated
EXHIBIT 4: NONA TOBIN & THE HANSEN TRUST PROFFERED EVIDENCE
- 7/13/18 Nona Tobin & the Hansen Trust Initial disclosures
- 2/27/19 Nona Tobin & the Hansen Trust 1st supplemental disclosures
- “All statements under oath support Nona Tobin’s claims”
- Ombudsman’s contemporaneous log of HOA foreclosure notices
EXHIBIT 5: RED ROCK FINANCIAL SERVICES RESPONSE TO TOBIN SUBPOENA
EXHIBIT 6: BERKSHIRE HATHAWAY RESPONSE TO TOBIN SUBPOENA
EXHIBIT 7: NEVADA LEGAL NEWS RESPONSE TO TOBIN SUBPOENA
EXHIBIT 8: DISPUTED MATERIAL FACTS ENTERED BY RED ROCK & SUN CITY ANTHEM
EXHIBIT 9: DISPUTED MATERIAL FACTS PROFFERED BY NATIONSTAR MORTGAGE
“Nationstar evidence was not examined”
4/9/21 Nationstar & Wells Fargo filed an answer to Red Rock’s 2/16/21 complaint


Nona Tobin’s Pending Appeals of cases A-15-720032-C and A-19-799890-C
Prior 8th Judicial District Court actions
Case summary A-15-720032-C

Register of Actions A-16-730078-C (consolidated in 2016 when Nona Tobin filed a motion to intervene)

Case summary A-19-799890-C

6/3/20 Nona Tobin’s 1st amended complaint

The abuse of process cause of action against the attorneys whose fraud on the court prevented adjudication of Tobin’s claims in the prior proceedings was bifurcated, on the advice of counsel, since it judges don’t like it when the attorneys are named as the culpable party vs. their clients.
9/6/20 order (NEOJ 10/8/20) to sanction Nona Tobin $3,455 for filing the complaint payable to Joseph Hong

11/17/20 order to sanction Nona Tobin $8,949 for filing the complaint payable to Brittany Wood

12/3/20 order of dismissal with prejudice and expungement of lis pendens as if never recorded


