Nationstar did not have standing


  1. NSM never was beneficiary of the Hansen 7/22/04 1st Deed of Trust, but recorded false claims to confiscate Tobin’s property without foreclosing.
  2. NSM was not BANA’s successor in interest and so even if Miles Bauer’s 5/9/13 tender of $825 preserved the security interest, NSM has no right to any benefit from the preservation of the security interest
  3. Tobin/Hansen trust did not file any claims against NSM in the first proceedings because she was joining NSM in its bid to void the defective sale in its entirety.
  4. NSM had no standing to claim that the sale was valid for the sub-priority portion of the HOA’s lien because there was no sub-priority portion on 5/9/13, and NSM made that claim for the sole improper purpose of stealing the house from Tobin because NSM knew it had no standing to foreclose on Tobin if the sale were voided in its entirety.
  5. The PUD rider remedies provision limits any lender’s recovery of delinquent assessments on behalf of the borrower to adding the amount paid to the outstanding balance of the loan plus interest at the note rate, and NSM’s attempt to get relief by confiscating Tobin’s property without meeting the foreclosure requirements of NRS 107.080, as amended by AB 284 (2011) is fraud.
  6. NSM was not the servicing bank on behalf of Wells Fargo as it first claimed the hour before discovery ended, but whether it was or not, NSM did not protect the interest of the beneficiary by foreclosing on the Hansen deed of trust in 2012 after the owner died and payments stopped. should have protected t
  7. NSM did not have a recorded power of attorney for its agent Mohamed Hameed to execute an assignment of the Hansen 1st DOT from Wells Fargo to itself, recorded on 3/8/19 and disclosed two weeks after the end of discovery.
  8. it is not Wells Fargo’s successor in interest as the beneficiary of the 1st DOT
  9. NSM concealed its 5/28/14 $1100 super-priority offer so it cannot now claim that its rejection by Red Rock
  10. it is judicially estopped by its false and inconsistent claims, concealing of evidence, and its unwarranted civil action, from claiming any of Tobin’s statements of fact are false.

Table of Violations


NRS 116.3116Super-priorityMiles Bauer tendered $825 that SCA agents rejected
NRS 116A.640 (8)HOA Manager can’t: “8.  Intentionally apply a payment of an assessment from a unit’s owner towards any fine, fee or other charge that is due.”   “check (142) for HOA dues”  was applied first to fees 10/18/12 by RRFS as partial payment; 11/9/12 applied as “RRFS collection payment” in Resident Transaction Report   See “RRFS Claims vs Actual”  
NRS 116A.640(9)HOA Manager can’t: “9.  Refuse to accept from a unit’s owner payment of any assessment, fine, fee or other charge that is due because there is an outstanding payment due.”  RRFS refused BANA’s 5/9/13 tender of $825. RRFS did not present Nationstar’s $1100 offer to close the escrow opened on 5/8/14 on the $350,000 sale (SCA 302) rejection of BANA tender was when only nine months were delinquent as of 4/30/13 NSM $1100 offer rejected as if it was an owner request for waiver
NRS 116A.640(10)HOA Manager can’t: “10.  Collect any fees or other charges from a client not specified in the management agreement.”    Nature of the financial intertwinement of the manager and debt collector was concealed, allowing for the covert, unaudited, unsupervised application of unauthorized fees and charges.

Managing agent FSR (fka RMI) held the NRS 649 debt collection license dba Red Rock Financial Services (RRFS)       4/27/12 RRFS debt collection agreement   2/26/10 RMI management agreement   3/31/14 FSR management agreement    

Red Rock’s response to Tobin’s 2/4/19 subpoena concealed the 4/27/12 contract. The lack of enforcement of the 4/27/12. contract’s indemnification provision has resulted in over $100,000 in charges to be forced onto HOA homeowners and unlawfully avoided by Red Rock for 11 cases stemming from 2014 SCA foreclosures, i.e.,

A-15-720032 Jimijack Irrevocable Trust v. BANA, N.A. & SCACAI,

A-14-707237-C  LN Management LLC series Pine Prairie v. Deutsche Bank

A-15-711883-C  My Global Village LLC v BAC Home Servicing

A-15-724233-C  TRP Fund IV LLC v Bank of Mellon et al

A-14-702071   Citi-mortgage, Inc v. SCA, (SCA paid $55K to settle in 2017)

2:17-cv-1800-JAD-GWF   FNMA v SCACAI

2:17-cv-02161-APG-PAL Bank of NY Mellon v. SCACAI

A-16-735894-C    TRP FUND IV v. HSBC Bank
NRS 116.31162 –   SCA Board Resolution Delinquent Assessment Policy and Procedure           Can’t file a notice of intent to lien “or take any other action to collect prior to “60 days after the obligation becomes due’.

7/30/12 was date “obligation was past due’ for quarter ending 9/30/12   10/3/12 check 143 for $300 submitted & ID’d as “check for HOA dues” to pay $275 assessments and $25 late fee   lien recorded with no prior notice for $925.76 when only $300 was due     See annotated SCA 168-SCA 175  SCA Delinquent Assessment Policy  
NRS 116.31162 (4)Must provide schedule of fees, proposed repayment plan, right to hearing by BOD + proceduresNo schedule of fees, repay plan, or hearing provided ever. No exception exists in the law to providing these notices or holding a hearing if an account has been sent to collections as claimed by SCA.   See 3/26/19 RTRAN, pgs. 23-24.
NRS 116.311635NOS – publish 3 times. Date & time & place of sale, mail certified to owner,2/12/14 NOS  complied with NRS 116.311635, but the single complaint notice was cancelled by notice to Ombudsman  on 5/15/14. See Ombudsman NOS compliance record of HOA notice published 2/12/14 for a 3/7/14 sale. No new compliant NOS was published prior to the 8/15/14 sale. All parties with a known interest (the owner, the listing agent, the servicing bank, all SCA members and BFPVs whose FMV offers had been rejected by the lender) were explicitly excluded from notice of the sale and were given no notice after it was sold. See
NRS 116.311365(2b3)Give NOS to OMBNo 2nd NOS – 8/15/14 sale held without notice to any party with a known interest.   RRFS did provide a 2nd NOS in two other SCA foreclosures where the 1st NOS was cancelled  
NRS 116.31164(3)(b)Deliver copy of foreclosure deed within 30 days after sale8/15/14 sale was held without having a 2nd NOS and without giving the OMB the foreclosure deed EVER   All parties with a known interest (the owner, the listing agent, the servicing bank, all SCA members and BFPVs whose FMV offers had been rejected by the lender) were not given any notice after the property was sold
NRS 116.31164(3)(c)Manner in which proceeds of sale are to be distributedOn 11/30/18, Steve Scow said that the funds were still in the Red Rock Financial Services account.   SCA 217 & SCA 223-224 were deceptive.     SCA 224 disclosed a $57,282 check, dated 8/27/14, to Clark County District Court, to create to mis-perception that the funds had been distributed.   In 2014, RRFS misled Tobin so she could not submit a claim for the proceeds through interpleader.   Tobin has been prevented from making the claim that she is entitled to the proceeds because NSM is not entitled to them as NSM’s claims to be the beneficial owner of the Western Thrift deed of trust are provably false.  
NRS 116.31166Deed recitals are deemed to be conclusive of a valid sale that removed the owner’s right of redemptionDeed recitals were false.   The HOA & its agents failed to comply with all legal requirements that were conditions precedent to a valid sale.   The default did not occur as was stated on the 3/12/13 rescinded Notice of default (NOD).   Payments were made after 7/1/1, i.e. check 143 was credited as paying all the quarter ending 9/30/12.   The Miles Bauer tender of $825 on 5/9/13 would have paid all delinquent assessments through 6/30/13.   RRFS misrepresented SCA 302 (NSM 5/28/14 offer of $1100) and called it an owner request for waiver in SCA 295 .  
NRS 116.1113Obligation of good faithFSR d/b/a RRFS had a financial conflict of interest serving both as the HOA’s managing agent and as its debt collector. FSR and RRFS advised the HOA BOD that it was required to handle collections and foreclosure in secret meetings.   FSR/RRFS falsely advised the HOA BOD that all BOD decisions related to “public” auctions of foreclosed properties were confidential by law.   FSR/RRFS did not act in good faith when it advised the BOD that there was an exception to due process requirements and owner protections in the law and in the deed restrictions if the proposed sanction was foreclosure.   FSR/RRFS prevented the BOD from complying with the requirements for taking valid corporate actions by getting the BOD to make all the decisions leading up to the sale of the property in unnoticed, closed meetings and without giving the owner an opportunity to prevent the sale.  
NRS 116.3102 (m)(1) (m) May impose reasonable fines for violations of the governing documents of the association only if the association complies with the requirements set forth in NRS 116.31031.  FSR/RRFS advised the HOA BOD that this provision did not apply when the HOA was imposing fines that were mis-named collection costs.   FRS/RRFS advised the HOA BOD that selling an owner’s home for the alleged violation of delinquent assessments was not a fine or a sanction.
NRS 116.3102 (3)(4) 3.  The executive board may determine whether to take enforcement action by exercising the association’s power to impose sanctions or commence an action for a violation of the declaration, bylaws or rules, including whether to compromise any claim for unpaid assessments or other claim made by or against it. The executive board does not have a duty to take enforcement action if it determines that, under the facts and circumstances presented:       (a) The association’s legal position does not justify taking any or further enforcement action;       (b) The covenant, restriction or rule being enforced is, or is likely to be construed as, inconsistent with current law;       (c) Although a violation may exist or may have occurred, it is not so material as to be objectionable to a reasonable person or to justify expending the association’s resources; or       (d) It is not in the association’s best interests to pursue an enforcement action.  
NRS 116.3102 (3)(4)Enforcement must be prudent, not arbitrary and capricious4.  The executive board’s decision under subsection 3 not to pursue enforcement under one set of circumstances does not prevent the executive board from taking enforcement action under another set of circumstances, but the executive board may not be arbitrary or capricious in taking enforcement action.   The BOD was arbitrary and capricious in its decision to make foreclosure decisions based solely on the allegations of its financially-conflicted agents,.   The HOA BOD allowed non-uniform enforcement and unjust enrichment of the agents to occur without supervising or auditing the agents’ actions or allowing owners to know what actions the agents were taking.  
NRS 116.3103BOD and agents are fiduciaries, business judgment rule, duty bound to act solely and exclusive in the best interest of the HOAHOA agents were unjustly enriched by usurping the policy authority and duties the SCA Board is prohibited from delegating by its governing documents.   It is not in the best interests of the HOA for the Board to allow agents to give higher priority to their own business interests than to the interests of the SCA membership given that the HOA a mutual-benefit association that exists solely to protect the common good (common areas and general property values) of the homeowners.   SCA agents have no statutory or contractual authority independent of the association.   The Association owes no duty to its agents.  
NRS 116.31031   CC&Rs 7.4   Bylaws 3.26   Resolution Establishing the Governing Documents Enforcement Policy & ProcessLimits on BOD power to impose sanctions   HOA BOD must provide:   Notice of violation Notice of hearing and procedures Notice of sanction & chance to appeal Notice of appeal hearing procedures AppealSCA alleged it sent a 9/20/12 notice of hearing for proposed sanction of suspension of membership privileges, but there was no hearing and no notice of sanctions alleged.   None of the contractually-defined  notice requirements guaranteed to all SCA homeowners prior to the imposition of a sanction for an alleged violation of any kind were met:   No Notice of violation (also no quarterly delinquency report as required by SCA bylaws 3.21(f)(v))   No Notice of hearing and proceduresNo Notice of sanction & chance to appealNo Notice of appeal hearing proceduresNo Appeal hearing held   Check 143 for $300 was submitted on 10/3/12 to pay $275 assessments through 9/30/12 plus $25 late fee authorized (SCA170).   RRFS credited $300 on 10/18/12 to unauthorized fees instead of to cure the delinquency as the owner stated was her intention.  
NRS 116.310313An HOA can charge reasonable fees to collect; this provision applies equally to an HOA agentRRFS claims to have independent authority to charge fees unlimited by this provision.   SCA BOD has abdicated to that view and memorialized it in SCA Delinquent Assessment Policy (SCA168-175).  
NRS 116.116.3106 (1)(d)HOA must define in its bylaw which of BODs duties SHALL not be delegated  FSR/RRFS misled the HOA Board
SCA Bylaws 3.20/ 3.18a, b, e, f, g, i Adopted pursuant to NRS 116.3106(d)Can’t delegate (a) budget; (b) levying or collecting assessments, (e) deposit in approved institutions for HOA’s behalf, (f) making/ amending use rules, (g) opening bank accounts and controlling signatories, (i) enforcing governing documentsFSR/RRFS usurped the collection and foreclosure process by asserting total proprietary control over all financial records. They structured a system that excluded the HOA Board from ability to supervise or audit the agents’ work.   FSR/RRFS had signatory control over SCA accounts covering all assessments collected.   SCA maintained no independent records to document that the sale occurred in the manner claimed by FSR/RRFS (or occurred at all).   SCA’s ownership records (Resident Transaction Report) show only two owners of the property (Hansen and Jimijack before 2016 while RRFS shows three owners and Jimijack claims there were four.    SCA has no record that the property was sold on 8/15/14 or on any other date.   The HOA has no record that $63,100, or for any other amount, was collected from selling the property.   The HOA has no records of what happened to whatever money was collected for whatever properties were sold by agents exercising the HOA’s statutory right to foreclose in whatever unknown manner they chose.
NRS 116.31083Defines Requires HOA BOD meetings to be open to all owners except in four limited circumstances  No notice to the membership when any decision to foreclose a particular property was made.   The Board meets in closed session to discuss and act on topics outside the four permissible ones.
NRS 116.31083 (6)   NRS 116.3108(4)  agenda must clearly describe topicsThis property was never on any Board agenda for any reason.   NRS 116.3108 (4) 4.  The agenda for a meeting of the units’ owners must consist of:       (a) A clear and complete statement of the topics scheduled to be considered during the meeting, including, without limitation, any proposed amendment to the declaration or bylaws, any fees or assessments to be imposed or increased by the association, any budgetary changes and any proposal to remove an officer of the association or member of the executive board.       (b) A list describing the items on which action may be taken and clearly denoting that action may be taken on those items. In an emergency, the units’ owners may take action on an item which is not listed on the agenda as an item on which action may be taken.       (c) A period devoted to comments by units’ owners regarding any matter affecting the common-interest community or the association and discussion of those comments. Except in emergencies, no action may be taken upon a matter raised under this item of the agenda until the matter itself has been specifically included on an agenda as an item upon which action may be taken pursuant to paragraph (b).  
NRS 116.31083 (9)minutes must include date, time and place of meeting; directors present, substance of matters discussed, record of vote, owners’ commentsNothing in any minutes indicate the SCA Board authorized this property to be sold.   No Board vote on record related to this property at all.
NRS 116.31065Rules must be uniformly enforced or not at allSCA asserts that foreclosure is a statutory right that exempts the HOA Board & its agents from providing an owner the notice and due process required by NRS 116.31031 and CC&Rs 7.4 prior to the Board’s imposing any sanction against an owner for an alleged infraction of the HOA’s governing documents.   Tobin asserts that there is no exception in the law that exempts an HOA from providing all of the notice and due process delineated in NRS 116.31031 and CC&Rs 7.4 when the Board imposes any sanction. It is ludicrous for an HOA Board to assert that the ONLY exception to an owner’s rights to due process was when an unsupervised agent imposed the harshest possible sanction, i.e., permanent revocation of membership privileges, 100% of the owner’s title rights and a fine 200 times the debt, for an alleged violation of the governing documents fo delinquent assessments.
NRS 116.31175     SCA bylaws 6.4 SCA bylaws 3.26  HOA agents do not control HOA records. The Board controls the records and must provide owners access to all BOD agendas, minutes, & all HOA records (with statutorily-defined exceptions), including contracts, court filings when HOA is a party. which must be reported quarterly by nameThe HOA and its agents did not put provide any agenda that specified any proposed action to sanction the owner of 2763 White Sage for delinquent assessments or to sell the property to collect.   SCA did not  provide any minutes of meetings where those actions are taken and does not allow access to court records or contracts so they allow people to basically steal. There is no record of which houses are taken and sold or where the money went   SCA withheld compliance records requested in 2016 unless they received a request from the court.   SCA withheld all minutes of Board meetings at which the owner or the property or Nona Tobin were discussed or actions taken to impose sanctions   SCA withheld all the documents requested in discovery.   SCA withheld reports given to the Ombudsman and told Tobin she had to obtain them from the Ombudsman. Then, SCA told the court that the red Rock foreclosure file was SCA’s official record, and the Ombudsman’s compliance records were inadmissible.    
NRS 116.31175   SCA bylaws 3.21(f)(v)“(v) a delinquency report listing all Owners who are delinquent in paying any assessments at the time of the report and describing the status of any action to collect such assessments which remain delinquent…”  FSR f/k/a RMI, as the HOA’s managing agent, never provided a quarterly delinquency report to the HOA BOD. The absence of this mandated report facilitated FSR d/b/a RRFS’s predatory collection practices which included adding
NRS 116.31085(4)BOD SHALL meet in exec session to hold a hearing on an alleged violation of the governing documents unless the person who is about to be sanctioned requests an open hearing by the BOD. If the person requests in writing that an open hearing be conductedNo hearing was ever provided because no notice was ever given to the owner that the Board intended to impose a sanction of permanent revocation of membership privileges by selling the house.   SCA alleges that it offered on 9/20/12 a hearing scheduled for 10/8/12 prior to the imposition of a sanction of the temporary loss of membership privileges because, as of 9/20/12, the $275 assessment payment for the quarter ending 9/30/12  had not yet been received.
NRS 116.31085(4a)Owner who is being sanctioned for an alleged violation is entitled to attend all portions of the Board hearing, including the presentation of evidence and the testimony of witnessesNo notice to attend
NRS 116.31085(4b)Owner is entitled to due process which must include without limitation the right to counsel, right to present witnesses and the right to present information relating to any conflict of interest of any member of the hearing panel (BOD)No due process provided
NRS 116.31085(5)subsection 4 establishes the MINIMUM protections the BOD must provide before it makes a decisionSCA didn’t provide the minimum protections
NRS 116.31085(6f)any matter discussed in exec session must be noted briefly in the minutes of the Executive Board. The Board shall maintain minutes of any decision related to subsection concerning the alleged violation and upon request shall provide a copy of the decision to the owner subject to being sanctioned or repNever gave info that could be considered actual or constructive notice
NRS 116.31087(1)right of owners to place allegation of violations of NRS 116 or the governing documents if they give a written request to the BODTobin was blocked multiple times from telling the HOA BOD that their agents were stealing.   Tobin was told she would have to get a court order to even see the records about the sanctions they took sanctioning for dead trees at the property  
NRS 116.31087(2)Board has 10 business days to place on next regular BOD meetingDidn’t do it


See SCA Board did not comply with HOA meeting laws

See “The sale was void for rejection of assessments

See “RRFS Claims vs Actual $$ Due

SeeWhat Lawsuit?” originallypublished 3/18/17

See “Abusive debt collection practices cost us all more than you think

Cause of action: Quiet title

According to Jay Young, on the Nevada Law Blog, in Nevada, the elements for a claim of quiet title are:

  1. Action may be brought by any person against another who claims an estate or interest in real property, adverse to him, for the purpose of determining such adverse claims. NRS  40.010;
  2. Complaint must be verified. NRS 40.090-1;
  3. Summons must be issued within one year of filing the complaint and served per NRCP. NRS 40.100-1;
  4. Lis Pendens must be filed with the county recorder within 10 days of filing of the complaint. NRS 40.090-3;
  5. Copy of the Summons must be posted on the property within 30 days after the summons is issued, and an affidavit of posting must be filed with the court. NRS 40.100-2;
  6. Disclaimer must be filed. NRS 40.020;
  7. Affidavit to unknown heirs must be filed. NRS 14.040(3);
  8. Court must hold a hearing on the evidence in order to issue judgment. Quiet title may not be obtained through default judgment.  NRS 40.110; and
  9. Record a certified copy of the judgment quieting title. NRS 247.120(o).

The elements – most critically #8, the mandatory evidentiary hearing, for awarding quiet title were not met in case A-15-720032-C

  1. Neither Jimijack nor Nationstar brought any claims for quiet tile against Nona Tobin in either of her capacities. Nationstar voluntarily dismissed all its quiet title claims before the trial, on 2/20/19 and 5/31/19, without adjudication. Nationstar is judicially estopped from claiming it ever was the beneficial owner of the disputed Hansen deed of trust based on its multiple false and conflicting recorded and filed claims. Nationstar, acted without legal authority when it ignored the restrictions of the PUD Rider Remedies turn the lender payment of delinquent fees into a de facto foreclosure without complying with the foreclosure requirements of NRS 107.080.
  2. Neither Jimijack nor Nationstar had any verified, unrefuted evidence to support their title claims. Jimijack did not ever enter any evidence into the record to refute Nona Tobin’s NRS 111.340 rebuttal of its 6/9/14 recorded deed that was inadmissible as evidence pursuant to NRS 111.345. Jimijack dumped its defective deed covertly before the trial. Joel A. Stokes never had a valid title claim because Jimijack had no interest to transfer. Nationstar and Jimijack met ex parte with Judge Kishner and got Nona Tobin’s verified evidence and verified complaints stricken from the record unheard based on misrepresentations to the court and presentation of false evidence.
  3. Neither Jimijack nor Nationstar served any summons on Nona Tobin in either of her capacities. Nationstar never served any summons on F. Bondurant LLC but simply added it as a third part without filing any claims against it.
  4. Nationstar recorded two lis pendens that were fraudulent insofar as they were based on false claims to title in the manner prohibited by NRS 205.377. Jimijack never recorded any lis pendens, but without legal authority falsely claimed that one of Nationstar’s lis pendens belonged to trustees Joel and Sandra Stokes and released it before the trial.
  5. No summons was posted on the property.
  6. Nona Tobin did not ever file a disclaimer. However, disclaimers of interest were filed in 2017 by F. Bondurant LLC, Yuen K. Lee, Thomas Lucas, Opportunity Homes LLC, and Steven Hansen. Subsequently in the 2021 interpleader, Republic Services, LLC filed a disclaimer of interest.
  7. No affidavit to unknown heirs was filed by Nationstar or by Jimijack.
  8. There were no evidentiary hearings in case A-15-720032-C. See links to all hearing minutes, transcripts and videos. See video “How Nationstar won without proof
  9. The recorded copy was not certified. A small technicality, unless you consider that the Ombudsman’s notice of sale records that proved the 8/15/14 sale was conducted without ANY published notice, were rejected as evidence based on the exact same technicality. The State of Nevada’s official HOA notice of sale compliance records, authenticated on 4/15/19, nearly two months before the trial were re-entered into the court record on 4/24/19, 4/29/19 and 5/23/19, but were erroneously ignored by the court.

And another technicality when the interpretation of HOA governing documents is at issue

Judge Kishner lacked jurisdiction to grant Jimijack its requested relief because no parties except Nona Tobin in both her capacities was compliant with NRS 38.310 (1) and therefore, NRS 38.310(2) required Judge Kishner to dismiss the action pending their completion of mediation.

NRS 38.310  Limitations on commencement of certain civil actions.

      1.  No civil action based upon a claim relating to:

      (a) The interpretation, application or enforcement of any covenants, conditions or restrictions applicable to residential property or any bylaws, rules or regulations adopted by an association; or

      (b) The procedures used for increasing, decreasing or imposing additional assessments upon residential property,

Ê may be commenced in any court in this State unless the action has been submitted to mediation or, if the parties agree, has been referred to a program pursuant to the provisions of NRS 38.300 to 38.360, inclusive, and, if the civil action concerns real estate within a planned community subject to the provisions of chapter 116 of NRS or real estate within a condominium hotel subject to the provisions of chapter 116B of NRS, all administrative procedures specified in any covenants, conditions or restrictions applicable to the property or in any bylaws, rules and regulations of an association have been exhausted.

      2.  A court shall dismiss any civil action which is commenced in violation of the provisions of subsection 1.

Nona Tobin’s motion was dismissal pursuant to NRS 38.310(2) was stricken unheard

7/29/19 Tobin motion to dismiss

Request for judicial notice: unadjudicated claims and administrative complaints

Administrative Complaints have been rejected for lack of jurisdiction or deferred pending adjudication of A-21-828840-C by Judge Jessica K. Peterson

Link to 1/28/21 NCJD complaint to the Nevada Commission on Judicial Discipline vs. Judge Joanna Kishner
Link to “Recommendation to the Nevada Commission on Judicial Discipline
Link to 3/14/19 AG complaint vs. Nationstar & Jimijack Irevocable Trust
Link to 11/10/20 2nd AG complaint vs Nationstar; Akerman; Wright Finley Zak; Bank of America
Link to 12/16/20 complaint to the Mortgage Lending Division vs. Nationstar; Akerman; Wright Finley Zak; Bank of America
Link to 2/14/21 complaint to the State Bar of Nevada vs. Joseph Hong
Link to 2/16/21 complaint to the State Bar of Nevada vs. Brittany Wood

Prior district court civil actions did not adjudicate filed claims based on evidence

Link to Register of Actions A-16-730078-C Nationstar vs. Opportunity Homes LLC

Link to Case Summary A-15-720032-C Jimijack Irrevocable Trust vs. Bank of America and Sun City Anthem Community Association, Inc.

Link to case summary A-19-799890-C 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

The minutes of all hearings in the case summaries show that there were no evidentiary hearings and that neither Plaintiff, nationstar nor Jimijack, met their burden of proof.

Link to “Nationstar’s evidence was not examined

Link to 3/8/21 Request for Judicial Notice of the Clark County official property records for APN 191-13-811-052 that shows the fraudulent claims that were recorded by Nationstar, Red Rock Financial Services, Joel A. Stokes, Jimijack Irrevocable Trust, Bank of America, Quicken Loans, Brian & Debora Chiesi.

Nationstar’s pleadings were unadjudicated

Nationstar voluntarily dismissed all its claims for quiet title and equitable relief without ever presenting a case or meeting its burden of proof that it owned any interest in the disputed Hansen deed of trust.

Nationstar’s only filed claims

Link to Nationstar’s 1/11/16 A-16-730078-C complaint Nationstar vs. Opportunity Homes

Link to Nationstar’s 6/2/16 AACC answer, affirmative defenses and counter-claim vs. Jimijack

Nationstar’s stipulations to dismiss disposed of ALL its claims

Link to 2/20/19 Nationstar’s stipulation to voluntarily dismiss all its filed claims except against Jimijack.

Link to 5/31/19 Nationstar’s stipulation to voluntarily dismiss all its filed claims against Jimijack.

Nona Tobin’s unadjudicated pleadings

Link to Nona Tobin’s unadjudicated claims vs. Sun City Anthem

Link to Nona Tobin’s unadjudicated claims vs. Jimijack unadjudicated claims

Link to Nona Tobin’s unadjudicated claims vs. Yuen K. Lee dba F. Bondurant LLC

Link to Nona Tobin’s unadjudicated claims vs. Thomas Lucas dba Opportunity Homes LLC

Link to Nona Tobin’s unheard 8/7/19 quiet title & equitable relief, unjust enrichment & abuse of process complaint

Nona Tobin’s unadjudicated district court motions

Link to 3/3/17 Nona Tobin’s unheard motion to void the sale for statutory non-compliance

Link to Nona Tobin’s unheard 4/10/19 motion for summary judgment vs. Jimijack Irrevocable Trust

Link to Nona Tobin’s unheard 4/10/19 motion for summary judgment vs. all parties

Link to 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

Link to Nona Tobin’s unheard 6/17/19 motion to intervene as an individual

Link to 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)

Link to 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 did not consider any evidence

Link to 8/11/17 order granting Opportunity Homes’s motion for summary judgment vs Nona Tobin and the Hansen Trust that was filed after order denying Opportunity Homes’s motion for summary judgment vs. Nationstar was entered on 6/22/17.

Link to 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

Link to 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

Link to 5/31/19 order denying motion to reconsider 4/18/19 order

Link to 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

Link to 9/4/19 order that denied Nona Tobin the right to appeal as an individual

Link to 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

Link to 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

Link to the 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.

Link to the 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.

Lik to 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 to the Nevada Supreme Court

79295 Gordon B. Hansen Trust vs. Jimijack, Nationstar, Sun City Anthem, Yuen K. Lee dba F. Bondurant LLC

Link to appellant Gordon B. Hansen Trust’s opening brief 12/19/19. Link to respondents’ 7/1/20 joint answering brief. and Nationstar’s joinder. Hansen Trust appeal was referred to the Nevada Court of Appeals on 8/27/20. Link to 9/10/19 Nona Tobin’s rejected individual docketing statement

82094 Nona Tobin vs. Joel & Sandra Stokes as trustees of Jimijack, Jimijack Irrevocable Trust & Joel A. Stokes, an individual

Link to appellant Nona Tobin’s 12/9/20 docketing statement. Opening brief is due 5/20/21.

82234 Nona Tobin vs. Quicken Loans LLC and/or Inc. & Brian & Deborah Chiesi

Link to appellant Nona Tobin’s 1/19/21 docketing statement. Opening brief is due 5/20/21.

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

Link to appellant Nona Tobin’s 2/03/21 docketing statement. Opening brief is due 5/20/21.