Case Detail: A-21-828840-C Nona Tobin vs. banks, debt collectors & attorneys

Back story of this David vs. Goliath fight

How did Nona Tobin lose the $500,000 house she inherited from Bruce Hansen? ”
How did Nona Tobin lose the $500,000 house she inherited from Bruce Hansen? was first published on 10/9/20 when Nona started trying (unsuccessfully) to use technology to level the playing field by naming and shaming.

“What happened after Sun City Anthem refused Nona’s 2017 offer to settle?”

“What happened after Sun City Anthem refused Nona’s 2017 offer to settle?” was published on 11/9/20 after Nona was subjected to four years of unwarranted, financially draining, and emotionally taxing litigation.

“The house that took over a life”

“The house that took over a life” was first published on SCAStrong.com on 1/14/18. Things have gotten considerably worse after three more years of grueling litigation.

Case Detail A-21-828840-C as of 4/10/21

Register of Actions as of 4/10/21 includes Red Rock’s complaint served on five defendants on 2/16/21; Nona Tobin’s 3/8/21 answer and counterclaim and crossclaim; four Tobin requests for judicial notice. On 4/9/21 Melanie Morgan filed an untimely answer for both Nationstar and Wells Fargo, but filed no counter-claims against Red Rock. Morgan did not answer Nona Tobin’s 3/8/21 cross-claim against her clients.
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.
Red Rock did not face any liability, let alone liability for an amount that exceeded the proceeds unlawfully retained. Red Rock filed this complaint for the improper purpose of obstructing justice, i.e., trying to moot appeal case 82294 and to cover up the unlawful failure to distribute the proceeds of the sale in 2014 as mandated by statute. Five defendants were named when only one, Nona Tobin as an individual, has a recorded claim for the undistributed proceeds.
2013 Nevada law governing the distribution of proceeds after an HOA foreclosure sale was NRS 116.31164(3)
NRS-116.31164-3-2013. Red Rock and/or Steven Scow unlawfully retained the proceeds for over six years of this and many other foreclosures. There is nothing in this law that allows Red Rock to collect attorney fees or costs for filing interpleader. There are also provisions in the HOA bylaws that prohibit any funds collected on behalf of Sun City Anthem from being under the proprietary control of anyone other than the HOA Board of Directors
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

Within 24 hours of service on Republic Services’ commercial agent in Carson City, an attorney in Las Vegas filed a Republic Services’ disclaimer of interest. According to the statute, Red Rock was required to distribute the sale proceeds to junior lien holders in 2014. Red Rock did not distribute the proceeds and so the three-year statute of limitations on statutory liens, Republic Services had already released its two liens in 2017. Given how very, very many times Red Rock has pulled this stunt, one would think Republic Services would have at least a little reluctant to disclaiming 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 counter-claim against Red Rock has five causes of action: 1) distribution of the proceeds to Tobin plus interest & penalties; 2) unjust enrichment/conversion; 3) Fraud; 4) Alter ego -piercing the corporate veil; 5) Racketeering.

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

  1. APN 191-13-811-052 Clark County Property Record and allegations of fraud vs. all opposing parties
  2. the sale was void for rejection of assessments.
  3. The alleged default was cured three times,
  4. SCA Board did not authorize the sale by valid corporate action
  5. Required notices were not provided, but records were falsified to cover it up
  6. SCA Board imposed ultimate sanction with NO due process 
  7. Neither BANA nor NSM ever owned the disputed DOT
  8. Examples of RRFS corrupt business practices
  9. Attorneys’ lack of candor to the tribunal
  10. the proceeds of the sale were not distributed pursuant to NRS 116.31164(3) (2013)
  11. RRFS’s fraud, oppression & unfairness
  12. attorney interference in the administration of justice
  13. lack of professional ethics and good faith
  14. Presented false evidence to cover up crime
  15. Civil Conspiracy to cover up racketeering warrants punitive damages
  16. Republic Services lien releases
  17. Nona Tobin’s standing as an individual
  18. Relevant statutes and regulations
  19. RELEVANT HOA GOVERNING DOCUMENTS PROVISIONS
  20. Administrative Complaints related to the APN 191-13-811-052 title dispute
  21. Nevada court cases related to the APN 191-13-811-052 title dispute
  22. 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
Six causes of action and claims for relief, damages and sanctions were filed against attorneys as individuals rather than against their clients.

Nona Tobin’s Requests for judicial notice

3/15/21 RFJN Clark County official property records for APN 191-13-811-052

  1. 2003 recorded claims
  2. 2004 recorded claims
  3. 2007 recorded claims
  4. 2008 recorded claims
  5. 2012 recorded claims
  6. 2013 recorded claims
  7. 2014 recorded claims
  8. 2015 recorded claims
  9. 2016 recorded claims
  10. 2017 recorded claims
  11. 2019 recorded claims
  12. 2020 recorded claims
  13. 2021 recorded claims

4/4/21 RFJN Unadjudicated claims & administrative complaints

Nona Tobin’s administrative complaints
  1. 1/28/21 NCJD complaint to the Nevada Commission on Judicial Discipline vs. Judge Joanna Kishner
  2.  “Recommendation to the Nevada Commission on Judicial Discipline
  3. 3/14/19 AG complaint vs. Nationstar & Jimijack Irrevocable Trust
  4. 11/10/20 2nd AG complaint vs Nationstar; Akerman; Wright Finley Zak; Bank of America
  5. 12/16/20 complaint to the Mortgage Lending Division vs. Nationstar; Akerman; Wright Finley Zak; Bank of America
  6. 2/14/21 complaint to the State Bar of Nevada vs. Joseph Hong
  7.  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
  1. Nationstar’s 1/11/16 A-16-730078-C complaint Nationstar vs. Opportunity Homes
  2. Nationstar’s 6/2/16 AACC answer, affirmative defenses and counter-claim vs. Jimijack
Nona Tobin’s unadjudicated pleadings in prior proceedings
  1. Summary of Nona Tobin’s unadjudicated pleadings
  2. Nona Tobin’s unadjudicated claims vs. Sun City Anthem
  3. Nona Tobin’s unadjudicated claims vs. Jimijack
  4.  Nona Tobin’s unadjudicated claims vsYuen K. Lee dba F. Bondurant LLC
  5. Nona Tobin’s unadjudicated claims vs. Thomas Lucas dba Opportunity Homes LLC
  6. Nona Tobin’s unheard 8/7/19 quiet title & equitable relief, unjust enrichment & abuse of process complaint
Nona Tobin’s unadjudicated district court motions
  1. 3/3/17 Nona Tobin’s unheard motion to void the sale for statutory non-compliance
  2. Nona Tobin’s unheard 4/10/19 motion for summary judgment vs. Jimijack Irrevocable Trust
  3. Nona Tobin’s unheard 4/10/19 motion for summary judgment vs. all parties
  4. 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
  5. Nona Tobin’s unheard 6/17/19 motion to intervene as an individual
  6. 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)
  7. 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
  1. 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.
  2. 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
  3. 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
  4. 5/31/19 order denying motion to reconsider 4/18/19 order
  5. 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
  6. 9/4/19 order that denied Nona Tobin the right to appeal as an individual
  7. 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
  8. 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
  9. 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.
  10. 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.
  11. 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

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
EXHIBIT 3: DAVID OCHOA PROFFERED FOR SUN CITY ANTHEM
EXHIBIT 4: NONA TOBIN & THE HANSEN TRUST PROFFERED EVIDENCE
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

Nationstar and Wells Fargo deceptively failed to admit that neither of them have a recorded claim for the proceeds. Nationstar and Wells Fargo failed to file a disclaimer of interest so the proceeds could go properly to Nona Tobin for the improper purpose of covering up Nationstar’s fraudulent conduct in relation to the Hansen deed of trust.
Melanie Morgan knows that the proceeds must be distributed ONLY to Nona Tobin because Wells Fargo’s liens were released on 3/30/17 and Nationstar as part of a fraudulent deal with Joel Stokes, released the lien of the Hansen deed of trust on 6/3/19.

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
Link to 29-page case summary
Register of Actions A-16-730078-C (consolidated in 2016 when Nona Tobin filed a motion to intervene)
Link to full 2-page case summary annotated
Case summary A-19-799890-C

8/7/19 Nona Tobin’s complaint

The complaint was filed on 8/7/19 by Nona Tobin, Pro Se, in order to beat the 8/14/19 five-year statute of limitations. Causes of action: Quiet title & equitable relief (against all defendants), Cancellation of instruments; Unjust enrichment (against. Red Rock, Koch & Scow, Joel Stokes & Nationstar); Abuse of process (against Joseph Hong, Melanie Morgan, and David Ochoa)

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

Tobin hired an attorney who amended the complaint to narrow the issues to three claims for relief: Quiet Title (against all defendants); Unjust Enrichment (against Brian & Debora Chiesi, Joel Stokes, Jimijack irrevocable Trust, Red Rock Financial Services & Nationstar); Declaratory Relief (as to all defendants)

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

Link to 9/6/20 order & 10/8/20 notice of entry of order 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

Order granted attorneys fes and costs pursuant to NRS 18.010(2) on the grounds that Nona Tobin’s filing this quiet title complaint was unwarranted and “was brought or maintained without reasonable ground or to harass the prevailing party.”

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

Red Rock’s motion to dismiss was filed pursuant to NRCP 12(b)(5) failure to state a claim by the legal doctrines of non-mutual claims preclusion and res judicata) and NRCP 12(b)(6) failure to join the HOA as a necessary party to protect its alleged interest in the undistributed proceeds of the 2014 HOA sale. Judge Johnson granted the joinders of all other defendants, regardless of whether or not they were parties to the prior proceedings or when they recorded adverse claims to Nona Tobin.
Link to 10-page case summary
Link to 10-page case summary

Combined case summaries annotated

Whatever happened to “equal protection under the law”?

According to Nationstar’s attorneys in 2016, Nationstar had standing to assert a quiet title claim under NRS 40.010…

Note that Nationstar is judicially estopped from claiming to be the beneficial owner of the disputed Hansen deed of trust due to its many conflicting and false claims made into the court record and in the official Clark County property record.

According to Nationstar’s attorneys in 2016, Nationstar could not be bound by Jimijack’s default judgment against B of A because Jimijack did not name Nationstar as a defendant

According to Nationstar’s attorneys in 2019, Nona Tobin’s known interest in the property should be disregarded so Nationstar and Jimijack could settle the title dispute without joining her..and without presenting a case.

Link to 4/23/19 hearing transcript where Nationstar and Jimijack settled the title dispute ex parte by excluding Nona Tobin

Link to “A simple fable: Jimijack and Nationstar weaponize settlement”

According to Nationstar’s attorneys in 2019, Nona Tobin did not have standing to assert a quiet title claim as an individual and was bound by the 6/24/19 order from a trial that excluded her.

Link to 6/24/19 trial order that granted quiet title to Jimijack vs. the Gordon B. Hansen Trust which Nationstar claims is preclusive of all Nona Tobin’s claims

Judge Kishner excused Nationstar and the HOA from the trial although neither of whom had any filed claims against Nona Tobin or the Hansen Trust, and despite the fact that the HOA’s motion for summary judgment against only the Hansen Trust’s quiet title claim was improper and unwarranted as the HOA had no interest in the title and would not have been damaged in any way if the HOA’s attorneys had simply done nothing. The effect of the court’s granting the HOA’s motion for quiet title and Nationstar’s joinder was to give the title to give the title to Plaintiff s Nationstar and Jimack without requiring them to put on a case and preventing Nona Tobin from putting on hers.

Judge Kishner compounded her errors of never ruling on Tobin’s claim that Jmiack’s deed was inadmissible and that Nationstar was lying bout owning the beneficial interest of the Hansen deed of trust, by meeting ex parte with Nationstar and Jimijack attorneys, letting them convince her that Nona Tobin’s pro se filings should be stricken from the record unheard, and by letting them “settle” non-existent claims (Jimijack never filed any claims against Nationstar), and by failing to check the settlement documents (to see that neither Jimijack nor Nationstar were parties to the “settlement agreement” that took the title from Nona Tobin without her being given an opportunity to be heard as Nationstar so eloquently demanded for itself in 2016.

Judge Kishner also excluded from the trial all documentary evidence for Joseph Hong’s misconduct, which damaged only Nona Tobin.

Judge Kishner also excluded from the trial five of the six Hansen Trust’s causes of action (equitable relief (noncompliance with HOA governing documents), civil conspiracy, fraudulent concealment, breach of contract, unjust enrichment), made on 1/31/17 CRCM vs SCA, 2/1/17 AACC vs. Jimijack (fraudulent conveyance, quiet title and equitable relief, unjust enrichment, civil conspiracy, and preliminary and permanent injunctions), and 2/1/17 CRCM vs. Yuen K. Lee dba F. Bondurant LLC (fraudulent conveyance, quiet title and equitable relief, and civil conspiracy)

Judge Kishner also excluded from the trial Nona Tobin as an individual and ALL of Nona Tobin’s individual causes of action (quiet title & equitable relief (statutory non-compliance), equitable relief (noncompliance with HOA governing documents), civil conspiracy, fraudulent concealment, breach of contract, unjust enrichment) made on 1/31/17 CRCM vs SCA, 2/1/17 AACC vs. Jimijack (fraudulent conveyance, quiet title and equitable relief, unjust enrichment, civil conspiracy, and preliminary and permanent injunctions), and 2/1/17 CRCM vs. Yuen K. Lee dba F. Bondurant LLC (fraudulent conveyance, quiet title and equitable relief, and civil conspiracy)

Link to Nona Tobin’s 8/7/19 quiet title complaint as an individual that Nationstar asserted Nona Tobin had no right to file because

Link to Red Rock’s 6/23/19 motion to dismiss Nona Tobin’s claims

Red Rock claims res judicata even though none of Nona Tobin’s claims have ever been adjudicated.

Link to Nationstar’s 6/25/19 joinder to motion to dismiss that includes Nationstar’s misstatement of the facts to make claims preclusion apply to Nona Tobin’s claims that were never heard.

A. Note that Nationstar fails to mention that Nationstar never filed any quiet title claims against Nona Tobin or against the HOA or against Red Rock or against Nona Tobin as the trustee of the Gordon B. Hansen Trust.
B. Note that Nationstar fails to mention that Nationstar and Jimijack made a fraudulent side deal excluding Nona Tobin for the corrupt purpose of obstructing judicial scrutiny of Tobin’s evidence.
On 1/10/19, the Court granted leave to amend, but not to add parties or claims which is tantamount to not granting the 11/30/18 motion to amend. Since the order was not entered, Nationstar cannot now claim “Tobin cannot now use this action to complete the efforts she abandoned in the prior action.”
Link to 3/14/19 complaint against Nationstar to the Nevada Attorney General unadjudicated and included as an exhibit to Nona Tobin’s 4/10/19 opposition to Nationstar’s motion for summary judgment against Jimijack
Link to Nona Tobin’s 4/10/19 opposition to Nationstar’s motion for summary judgment and counter-motion for summary judgment that was stricken at the 4/23/19 ex parte meeting between Nationstar, Jimijack and Judge Kishner
Link to Nona Tobin’s 4/10/19 motion for summary judgment against Jimijack that was stricken unheard at the 4/23/19 ex parte meeting between Nationstar, Jimijack and Judge Kishner
Link to Nona Tobin’s 4/10/19 motion for summary judgment against all parties that was stricken unheard at the 4/23/19 ex parte meeting between Nationstar, Jimijack and Judge Kishner

Counter-claim vs. Red Rock Financial Services

Factual allegations

  1. Plaintiff RRFS knows that all the liens recorded related to named Defendants other than Nona Tobin, i.e., Republic Services, Wells Fargo, and Nationstar have been released on 3/30/17, 8/17/04, 3/12/15, and 6/3/19, respectively.  See Exhibit 1: APN 191-13-811-052 Clark County Property Record and allegations of fraud vs. all parties
  2. The HOA sale was void as payments and tenders after 7/1/12 were rejected, misappropriated, misrepresented, and/or concealed. Default did not occur as described in the 3/12/13 Notice of default or as recited in the 8/22/14 foreclosure deed. See Exhibit 2: The sale was void for rejection of assessment payments.
  3.  The Default was cured three times, but RRFS kept pursuing the predatory path to unwarranted, unjustly profitable foreclosure. See Exhibit 3: the alleged default was cured three times.
  4. There was no valid authorization of the sale, but RRFS disclosed deceptive and falsified documents to create the misrepresentation of reality. See Exhibit 4: The HOA Board did not authorize the sale by valid corporate action.
  5. Required notices were not provided, but RRFS falsified records to cover it up. See Exhibit 5: Required notices were not provided, but it was covered up by falsified records.
  6. SCA Board imposed the ultimate sanction against the estate of the deceased homeowner, but RRFS and SCA attorneys concealed and misrepresented material facts and the law to cover it up. See Exhibit 6: The HOA Board imposed the ultimate sanction for an alleged violation of the governing documents with NO due process.
  7. Bank of America never was the beneficiary of the Hansen deed of trust, but committed mortgage servicing fraud, refused to let two fair market value sales close escrow, refused to take the title on a deed in lieu, took possession without foreclosing, and used attorney Rock K. Jung to covertly tender delinquent assessments to  circumvent the owner’s rights under the PUD Rider remedies (f) to confiscate her property without foreclosing.  See Exhibit 7: Neither Bank of America nor Nationstar ever owned the disputed Hansen deed of trust, but tried to steal the property.
  8. Many examples of RRFS’s corrupt business practices exist of keeping fraudulent books, scrubbing page numbers from ledgers, combined unrelated documents to rewrite history, scrubbing dates from emails, not documenting Board actions,  and much more. See Exhibit 8: Examples of Red Rock’s corrupt business practices. 
  9. All opposing counsels in all the litigation over the title to this one property made misrepresentations in their court filings and made oral misstatements of materials facts and law at hearings. See Exhibit 9: Attorneys’ lack of candor to the tribunal.
  10. The proceeds of the sale were not distributed in 2014 and RRFS’s complaint for interpleader in 2021 was filed in bad faith. See Exhibit 10: The proceeds of the sale were not distributed pursuant to NRS 116.31164(3) (2013)
  11. RRFS concealed the 4/27/12 debt collection contract that requires RRFS to indemnify the HOA and has been unjustly enriched thereby well over $100,000 in fees and considerably more in undistributed proceeds. RRFS did not participate in NRS 38.310 mediation in good faith. See Exhibit 11: Red Rock’s fraud, unfairness and oppression
  12. In case A-19-799890-C, Brody Wight knowingly filed a motion to dismiss Nona Tobin’s claims pursuant to NRCP (b)(5) and NRCP (b)(6) that was totally unwarranted, harassing, disruptive of the administration of justice, not supported by facts or law, and filed solely for the improper purpose of preventing discovery of the crimes of his law firm and its clients. See Exhibit 12: Attorney interference in the administration of justice.
  13. None of the opposing counsels have acted in good faith in compliance with the ethic standard of their profession. All have failed in their duty of candor to the court, wasted millions of dollars in judicial resources, and have engaged in criminal conduct to further the criminal conduct of their clients. See Exhibit 13: Lack of professional ethics and good faith.
  14. Attorneys have knowingly presented false evidence into the court record in discovery. See Exhibit 14: Presented false evidence to cover up crime.
  15. Nationstar and RRFS conspired to conceal the manner in which RRFS covertly rejected Nationstar’s $1100 offer to close the MZK sale. Civil Conspiracy. See Exhibit 15: Civil conspiracy to cover up racketeering warrants punitive damages.
  16. Exhibit 16 Republic Services lien releases
  17. Exhibit 17 Nona Tobin’s standing as an individual
  18. Exhibit 18 Relevant statutes and regulations
  19. Exhibit 19 Relevant HOA governing document provisions
  20. Exhibit 20 Administrative complaints
  21. Exhibit 21 Nevada court cases regarding the wrongful foreclosure of 2763 White Sage
  22. Exhibit 22 Nona Tobin’s 1/31/17 cross-claim vs Sun City Anthem, DOEs & ROEs excerpts: statement of facts, 5th cause of action: unjust enrichment, identification of parties

First cause of action: Interpleader

The court must find that the proceeds of the 8/15/14 must be distributed to the only claimant, Nona Tobin, immediately with interest, sanctions and penalties for failure to comply with the statutory requirement to distribute the proceeds immediately after the sale.

Red Rock did not comply with the statute

RRFS’s agent/employee Christie Marling was the “person who conducted the sale”.

NRS 116.31164(3) (2013) defines Christie Marling’s ministerial duties following the sale
RRFS 052 shows Christie Marling COMPLIED with 3(a) and sent a foreclosure deed to the purchaser.
Ombudsman’s records show that Christie marling DID NOT COMPLY with 3(b) as no foreclosure deed was sent to the Ombudsman following the unnoticed 8/15/4 sale.
RRFS 047 and RRFS 048 show that Christie Marling TRIED TO COMPLY with 3(c) by instructing Steven Scow to deposit the funds with the court for interpleader.
Steven Scow DID NOT COMPLY with 3(c) and did not deposit the funds with the court as instructed by the person who conducted the sale.

Steven Scow DID NOT COMPLY with SCA bylaws to deposit the funds in an account controlled by the SCA Board when he did not deposit the funds with the court and he did not distribute them according to the statute.

Second cause of action:

Unjust enrichment or Conversion

1. Link to HOA bylaws restriction on delegation of control over funds collected for the HOA
2. Page 1336 Resident Transaction Report 8/27/14 ledger entry $2,701.04 paid the HOA in full, but RRFS provided falsified ledgers in response to subpoena.
3. Excerpt of 10/15/14 email shows RRFS rebuffed my attempt to make a claim for the excess proceeds by saying it was deposited with the court.
4. Link to 4/27/12 RRFS debt collection contract that was concealed in discovery that contains the unenforced indemnify provision that Red Rock has unjustly profited from at the expense of Sun City Anthem homeowners.
5. Link to Red Rock’s duplicitous 6/23/20 motion to dismiss my quiet title and unjust enrichment claims per NRCP 12(b)(5) and NRCP 12(b)(6)
6. Link to Red Rock’s duplicitous 2/15/21 interpleader complaint

Third cause of action: Racketeering

  1. COUNTER-DEFENDANT RRFS AND CROSS-DEFENDANT NATIONSTAR engaged in racketeering activities as defined in NRS 207.360 and a racketeering enterprise as is defined in NRS 207.380;
  2. COUNTER-DEFENDANT RRFS AND CROSS-DEFENDANT NATIONSTAR, acting directly, and in conspiracy with one another or through their syndicate(s), participated directly in racketeering activity by engaging in at least two crimes related to racketeering;
  3. COUNTER-DEFENDANT RRFS AND CROSS-DEFENDANT NATIONSTAR’s activities have the same or similar pattern, intent, results, accomplices, victims, or methods of commission, or otherwise interrelated by distinguishing characteristics and are not isolated events;
  4. COUNTER-DEFENDANT RRFS AND CROSS-DEFENDANT NATIONSTAR acquired or maintained directly or indirectly an interest in, or control of, any enterprise, or defendants are employed by or associated with any enterprise to conduct or participate directly or indirectly in the affairs of the enterprise through a racketeering activity;
  5. COUNTER-CLAIMANT AND CROSS CLAIMANT NONA TOBIN’s injuries flow from the defendant’s violation of a predicate Nevada RICO act;
  6. NONA TOBIN’s injury was be proximately caused by the defendant’s violation of the predicate act;
  7. NONA TOBIN’s did not participate in the commission of the predicate act; and
  8. NONA TOBIN’s is entitled to institute a civil action for recovery of treble damages proximately caused by the RICO violations. NRS 207.470(1).
  9. COUNTER-DEFENDANT RRFS conspired with, aided and abetted CROSS-DEFENDANT NATIONSTAR, and many other lenders, to perpetrate a fraud on the court with a quid pro quo of Nationstar’s (and fill-in-the-blank OTHER LENDER’S NAME)’s not asserting a claim for the excess proceeds so Koch & Scow could keep whatever proceeds they wanted without fear of audit or challenge.

Prayer for relief

  1. COUNTER-CLAIMANT AND CROSS CLAIMANT NONA TOBIN repeats, realleges, and incorporates herein by this reference the allegations hereinabove inclusively as though set forth at length and in full herein. 
  2. This counterclaim has been necessitated by the COUNTER-DEFENDANT RRFS’s AND CROSS-DEFENDANT NATIONSTAR’s bad faith conduct. 
  3. Pursuant to Nevada law, COUNTER-CLAIMANT AND CROSS CLAIMANT NONA TOBIN’s may recover her attorney fees as special damages because she was required to file this suit as a result of COUNTER-DEFENDANT RRFS AND CROSS-DEFENDANT NATIONSTAR’ intentional conduct.[1] 

COUNTER-CLAIMANT AND CROSS CLAIMANT NONA TOBIN petitions the Court to declare:

  • that the disputed HOA sale is void due to fraud in the execution by Red Rock Financial Services;
  • that the disputed HOA sale did not extinguish the GBH Trust’s, nor its successor in interest’s rights to title;
  • that Nona Tobin is entitled to the $57,282 undistributed proceeds of the sale with six+ plus years interest and exemplary penalties pursuant to NRS 42.005.
  • that sanctions are appropriate vs. RRFS for its fraudulent conduct of HOA foreclosures sales;
  • that sanctions are appropriate vs. RRFS for its falsification of records to evade detection of misappropriation of funds;
  • that sanctions are appropriate vs. RRFS for its retention of proprietary control of the proceeds of the foreclosure of the subject property, and of approximately a dozen other Sun City Anthem 2014 foreclosures, when RRFS knew, or should have known that the HOA Board was prohibited by Sun City Anthems bylaws from delegating proprietary control over funds collected for the sole and exclusive benefit of the association;
  • that sanctions are appropriate vs. RRFS for its failure distribute foreclosure proceeds timely after the sales, as mandated by NRS 116.31164(3):
  • that sanctions are appropriate vs. RRFS for Koch & Scow’s unsupervised, unaudited retention of the funds of many, many HOA foreclosures allowed attorney trust fund violations to go undetected; 
  • Koch & Scow’s filed its unwarranted 6/23/20 motion to dismiss, its 8/3/20 reply in support, and its 12/3/20 motion to dismiss, knowing that all these filings contained many misrepresentations of material facts for which there was no factual support or evidence,  defied NRCP 11 (b)(3), Nevada Rules of Professional Conduct 3.3 (candor to the tribunal), 3.4 (fairness to opposing counsel), 3.5A (relations with opposing counsel), 4.1 (truthfulness in statements to others), 4.4 (respect for the rights of third persons) and ABA (1992) Standards for Imposing Lawyer Sanctions  6.1 (False statements, fraud, and misrepresentation).
  • that sanctions are appropriate vs. RRFS for its misappropriation of funds, covert rejection of assessments, falsification of records that allowed the unjust enrichment of undisclosed partners and co-conspirators;
  • that Nona Tobin is entitled to treble damages for the fraudulent confiscation of the subject property, valued on 12/27/19 at $505,000 property pursuant to NRS 207.470(1) as RRFS’s actions on the dozen 2014 unnoticed foreclosures constitute racketeering;
  • that sanctions are appropriate pursuant to NRS 18.010(2) vs. RRFS for its filing the improper interpleader action with penalties as all other named defendants’ liens have been released and Nationstar mortgage is judicially estopped from claiming it ever was the beneficial owner of the Hansen deed of trust;
  • that Nona Tobin, an individual’s, 3/28/17 deed is the sole valid title claim;
  • that Jimijack’s defective, 6/9/15 deed was inadmissible as evidence to support its title claim pursuant to NRS 111.345;
  • that the Joel Stokes-Civic Financial Services “agreement”, recorded on 5/23/19, and misrepresented to Judge Kishner on 5/21/19 as the Nationstar-Jimijack settlement was fraud on the court and sanctionable conduct pursuant to ;
  • that sanctions are appropriate vs. Nationstar and its Akerman attorneys pursuant to NRCP 11 (b)(1)(2)(3)(4) (misrepresentations in court filings), Nevada Rules of Professional Conduct 3.3 (candor to the tribunal), 3.4 (fairness to opposing counsel), 3.5A (relations with opposing counsel), 4.1 (truthfulness in statements to others), 4.4 (respect for the rights of third persons) and ABA (1992) Standards for Imposing Lawyer Sanctions  6.1 (False statements, fraud, and misrepresentation).
  •  To declare that Joel Stokes’ deed, recorded on 5/1/19, was void as Jimijack had no interest to convey and that this transfer prior to the 6/5/19 trial was for the corrupt purpose of deceiving the court into allowing Joel Stokes and Nationstar to perpetrate a fraud on the court;
  • That Nona Tobin is entitled to recoup treble damages pursuant to NRS 207.470 (1) and (4);
  •  That Nona Tobin is entitled to is entitled to recoup damages equivalent to five years of rental income from Jimijack;
  • that Nationstar Mortgage LLC’s (Herein “NSM” or “Nationstar”) claims to own the beneficial interest of the disputed Western Thrift Deed of Trust (Herein “DOT”) are false and sanctionable under NRS 205.395, NRS 205.377, NRS 207.400 and that Nona Tobin is entitled to treble damages by their misconduct pursuant to NRS 207.470;
  • that all instruments, encumbrances and assignments, and expungements of lis pendens that were improperly and/or unlawfully notarized, executed or recorded to create false claims, or were done for the improper purpose of abrogating Tobin’s rights during the pendency of litigation, and/or prior to the adjudication of Plaintiff’s claims in this instant action, are cancelled and declared without legal force and effect; and
  • that attorneys pay Tobin’s attorney fees and costs as a sanction pursuant to  NRCP 11(b)(1)(3) and/or NRS 18.010(2)

[1] Sandy Valley Assocs. v. Sky Ranch Estates Owners Ass’n, 117 Nev. 948, 958, 35 P.3d 964, 970 (2001), citing American Fed. Musicians v. Reno’s Riverside, 86 Nev. 695, 475 P.2d 220 (1970).

Cause of Action: Conversion

  1. According to Jay Young, Nevada Law Blog:

In Nevada, the elements for a claim of conversion are:

  1. A distinct and intentional act of dominion by one which is wrongfully exerted over the property of another;
  2. Act committed in denial of, or inconsistent with the rightful owner’s use and enjoyment of the property;
  3. Act committed in derogation, exclusion, or defiance of the owner’s rights or titled in the property; and
  4. Causation and damages

M.C. Multi-Family Development, L.L.C. v. Crestdale Assoc., Ltd., 193 P.3d 536, 543 (Nev., 2008); Evans v. Dean Witter Reynolds, 5 P.3d 1043 (Nev. 2000); Bader v. Cerri, 96 Nev. 352, 609 P.2d 314 (1980); Wantz v. Redfield, 74 Nev. 196 (1958); Boylan v. Huguet, 8 Nev. 345 (1873).

Cause of Action: Defamation

Plaintiff repeats, realleges, and incorporates herein by this reference the allegations hereinabove inclusively as though set forth at length and in full herein. 

Plaintiff is a homeowner in good standing of Sun City Anthem since 2/20/04.

Defendants, and each of them, made at least one false statement of fact to a third party that interferes with the Plaintiff’s quiet enjoyment of her property, her good name in the community, and her rights as a Sun City Anthem homeowner (each a “Defamatory Statement”). 

Each Defamatory Statement constitutes a non-privileged publication to a third party.  Each Defamatory Statement was made with malice.  Plaintiff suffered special damages due to each Defamatory Statement.  As a direct, proximate, and foreseeable result of Defendants’ acts, Plaintiff has been damaged in excess of $15,000, and in an amount to be determined at the time of trial. 

Defendants’ acts were committed with fraud, oppression, and/or malice, entitling Plaintiff to punitive damages pursuant to NRS 42.005 in an amount to be determined at the time of trial. 

As a direct, proximate, and foreseeable result of the Defendants’ acts, it has become necessary for Plaintiff to secure the services of an attorney, and Plaintiff is entitled to recover fees and costs incurred herein as damages.

Link to published 2017-2020 quarterly litigation reports

Civil complaint against attorneys

Causes of Action: Abuse of process, civil conspiracy, fraud, and racketeering

Link to PDF of 3/22/21 third-party complaint into A-21-828840-C & exhibits

Exhibit 1: Cause of action: Fraud

Exhibit 2: Cause of action: Abuse of process

Exhibit 3: Civil damages due to Racketeering

Exhibit 4: Cause of action: Conspiracy

Exhibit 5: Alleged facts

Exhibit 6: What does it take to get disbarred in Nevada?

Exhibit 7: 1st complaint to the Nevada Attorney General

Exhibit 8: 2nd complaint to the Nevada Attorney General

Exhibit 9: Why Nationstar & its attorneys must be sanctioned & pay punitive damages

Exhibit 10: All declarations under penalty of perjury support Nona Tobin’s claims

When all statements under oath support Nona Tobin, why does she keep losing?

Exhibit 11: What is the PUD Rider?

Exhibit 12: A Duel to the Death

Exhibit 13: We can learn a lot from this Spanish Trail HOA case

Exhibit 14: Complaints to the State Bar of Nevada Ethics & Discpline Panel vs. Brittany Wood

Exhibit 15: Complaint against Melanie Morgan

Exhibit 16: Complaint to the Mortgage Lending Division

Exhibit 17: Complaint vs. Brittany Wood

Exhibit : 2020 court hearings Part 1

Exhibit 19: Complaints to law enforcement

Exhibit 20: Harassment or bullying an HOA homeowner is a crime

Exhibit 21: How the crooks steal HOA houses

Exhibit 22: Implicated Nevada law

Exhibit 23: Interpleader complaint was filed with an ulterior motive

Exhibit 24: Joseph Hong: pay Nona Tobin treble damages for stealing her house and be disbarred

Exhibit 25: Judicial Jiu-Jitsu is fraud on the court

Exhibit 26: Nationstar Mortgage’s fraud

Exhibit 27: Nevada Commission on Judicial Discipline Complaint

Exhibit 28: Nevada Rules of Civil Procedure

Exhibit 29: Implicated Nevada Rules of Professional Conduct

Excerpts related to attorney misconduct in this situation as well as a link to the full Nevada rules for professional conduct. Here is a link to the ABA Standards for Imposing Lawyer Sanctions which also should weigh heavily in the Court’s decision to appropriate level of discipline to impose.

Exhibit 30: Nona Tobin’s Request for Judicial Notice of the property record

Exhibit 31: Recommendation to the Nevada Commission on Judicial Discipline

Exhibit 32: Complaints to the Nevada Attorney General

Exhibit 33: What is Lis Pendens?

Exhibit 34: Why Alternative Dispute Resolution

Cause of Action: Misappropriation of money

Plaintiff Nona Tobin repeats, re-alleges, and incorporates herein by this reference the allegations hereinabove inclusively as though set forth at length and in full herein. 

Defendants, and each of them, misappropriated or otherwise improperly took possession of monies which belonged to or should have gone to Plaintiff. 

As a direct, proximate, and foreseeable result of Defendants’ acts, Plaintiff has been damaged in excess of $15,000 and in an amount to be determined at the time of trial. 

Defendants’ acts were committed with fraud, oppression, and/or malice, entitling Plaintiff to punitive damages pursuant to NRS 42.005 in an amount to be determined at the time of trial. 

As a direct, proximate, and foreseeable result of the Defendants’ acts, it has become necessary for Plaintiff to secure the services of an attorney, and Plaintiff is entitled to recover fees and costs incurred herein as damages.

Cause of Action: Civil Conspiracy

Plaintiff repeats, realleges, and incorporates herein by this reference the allegations hereinabove inclusively as though set forth at length and in full herein. 

Defendants collectively constitute a combination of two or more persons.  

Defendants acted in concert by agreement, understanding, or a “meeting of the minds” regarding the objective and the means of pursuing it, whether explicit or by tacit agreement (the “Scheme”). 

Defendants, and each of them, intended to and did accomplish an unlawful objective for the purpose of harming Plaintiff Nona Tobin through the Scheme. 

The Scheme harmed Plaintiff Nona Tobin 

As a direct, proximate, and foreseeable result of the Scheme, Plaintiff has been damaged in excess of $15,000 and in an amount to be determined at the time of trial. 

Defendants’ acts were committed with fraud, oppression, and/or malice, entitling Plaintiff Nona Tobin to punitive damages pursuant to NRS 42.005 in an amount to be determined at the time of trial. 

As a direct, proximate, and foreseeable result of the Defendants’ acts, it has become necessary for Nona Tobin to secure the services of an attorney, and Nona Tobin is entitled to recover fees and costs incurred herein as damages.

Cause of Action: RICO Damages pursuant to NRS 207.470 Racketeering

The elements of a civil claim for damages caused by racketeering are:

1. Defendants, and each of them, engaged in conduct which constitutes a pattern of racketeering activity pursuant to NRS 207.360, including (9) taking property from another under circumstances not amounting to robbery, (18) Grand larceny; (29) Perjury or subornation of perjury; (30) Offering false evidence; (35) Any violation of NRS 205.377;

2. Defendants, and each of them, engaged in conduct which constitutes a pattern of racketeering activity in violation of NRS 207.470;

3. Defendants, and each of them, committed at least two separate crimes relating to racketeering constituting a pattern of racketeering activity. (the “Predicate Acts”);

4. Defendants’ crimes are interrelated by distinguishing characteristics and are not isolated incidents but are a part of a pattern of criminal activity;

5. The Defendants, and each of them, violated NRS 207.400;

6. Plaintiff Nona Tobin has suffered damages;

7. Plaintiff Nona Tobin is entitled to treble damages against Defendants, and each of them. NRS 207.470(1);

8. Plaintiff Nona Tobin is entitled to an award of punitive damages; and

9. Plaintiff Nona Tobin is entitled to an award of attorney fees and costs as damages. NRS 207.470(1).

A partial list of the Counter-Defendants’, Cross-defendants’ and third-party defendants’ Predicate Acts

Nationstar LLC and/or Nationstar LLC dba Mr. Cooper recorded false claims on 12/1/14, 1/22/15, 8/17/15, 1/13/16, 6/7/16,  3/8/19 rescind and 3/8/19 assign, and 6/3/19.

Red Rock Financial Services recorded false claims on 12/14/12, 3/12/13, 4/3/13, 4/8/13, and executed the foreclosure deed Thomas Lucas recorded on 8/22/14.

Joseph Hong’s clients recorded false claims on 6/9/15, 6/9/15, 12/1/15, 5/1/19, 5/23/19, 5/28/19, 7/24/19, 12/3/19, 12/27/19, and 12/27/19 and aided and abetted false claims to be recorded on 6/3/19, 6/4/19, 7/10/19, 7/17/1912/27/19, 2/6/20, 2/6/20,  and 12/4/20.

Attorneys for Wright, Finley, Zak, aided and abetted mortgage servicing fraud of both Bank of America and Nationstar Mortgage by filing into these quiet title civil actions statements known to be false and disclosing false evidence Edgar Smith (NV bar #5506) on 1/11/16, 4/12/16 DECL, 4/12/16, 5/10/16, 6/2/16, 6/3/16, 6/10/16, 3/27/17 DECL , 3/27/17, 11/9/17, 2/9/18, (Dana Johnson Nitz NV Bar #0050, Michael Kelly NV Bar #10101).

Attorneys for Akerman LLP (Melanie Morgan NV Bar #8215, Karen Whelan NV Bar #10466, Donna Wittig NV Bar #11015). 5/15/18, 2/7/19, Thera Cooper NV Bar #13468, 2/12/19, 2/12/192/20/19, 2/21/19, 2/21/19, 2/27/19, 2/28/19, 2/28/19, 3/7/19, 3/12/19, 3/12/19, 3/18/19, 3/21/19, 3/26/19 RTRAN, 4/12/19, 4/15/19 (SAO signed 4/10/19), 4/19/19,  4/23/19, 4/23/19 RTRAN, 4/25/19 RTRAN, 5/3/19, 5/21/19 RTRAN, 5/29/19 RTRAN, 5/31/19, 6/24/19, 6/24/19, 6/25/19, 7/1/19, 7/22/19.

Joseph Hong (NV Bar #5995) filed written false statements, filed frivolous unsupported harassing pleadings, knowingly made false verbal statements, made fraudulent misrepresentations of material facts, concealed/failed to disclose material facts, conspired with others, received proceeds, on these dates, 6/9/15 DEED, 6/16/15, 6/8/16, 8/12/15, 10/16/15, 8/30/16, 9/29/16 RTRAN, 12/5/16, 12/20/16 RTRAN, 3/13/17, 3/13/17, 3/13/17, 12/5/18,  3/25/19, 3/26/19 RTRAN, 4/15/19, 4/22/19, 4/23/19 minutes,  4/23/19 RTRAN, 4/23/19 RTRAN annotated, 4/25/19 RTRAN, 5/1/19 DEED, 5/3/19, 5/21/19, 5/23/19 Agreement, 5/24/19, 5/29/19 video, 5/29/19 RTRAN, 6/3/19 RTRAN, 6/3/19 video, 6/5/19, 6/5/19 video, 6/5/19 RTRAN, 6/5/19 video, 6/6/19 RTRAN, 6/24/19, 6/28/19, 8/7/19, 8/13/19, 9/3/19 RTRAN, 9/3/19 video, 6/25/20, 7/1/20,  8/3/20 annotated,, 8/11/20 video, 8/11/20 RTRAN, 10/8/20, 10/8/20 annotated, 10/16/20 OST, 10/16/20 NEO, 10/29/20 RTRAN, 10/29/20 video, 11/3/20 video, 11/3/20 RTRAN.

Detailed allegations against defendants are delineated in complaints to the Nevada Attorney General on 3/14/19 and 11/10/20.

Detailed allegations against defendants are delineated in complaints to the Nevada State Bar on 2/14/21 and on 2/16/21.

Detailed allegations against multiple defendants are delineated in these publications

Specific allegations related to false claims recorded by multiple defendants in the Clark County Official property records are in this publication

Detailed allegations against Brittany Wood are delineated in these publications

Detailed allegations against Melanie Morgan are delineated in these publications

Detailed allegations against Nationstar are delineated in these publications

This fraud on the court publication has nine videos that show exactly how the attorneys tricked the court into letting Nationstar and Joel Stokes steal Nona Tobin’s house without ever putting on a case, meeting their Plaintiffs’ burden of proof, or refuting Nona Tobin’s claims against them.

Some allegations against Steven Scow & Brody Wight are delineated in these publications

Court records that evidence fraud on the court Joseph Hong are partially found here

Documentary evidence of abuse of process, fraud on the court, conspiracy, and racketeering are in linked exhibits to the Nevada attorney General & to the Mortgage Lending Division

Specific allegations related to false claims recorded by multiple defendants in the Clark County Official property records are in this publication

A fable to illustrate Joseph Hong’s & Melanie Morgan’s fraud on the court is in this publication

This publication of the Nevada Rules of Civil Procedure will be updated to highlight relevant rules related to proposed sanctions and proposed civil court reform

Nona Tobin’s Cross-claims vs. Nationstar and Wells Fargo and counter-claims vs. Red Rock Financial Services and motions for attorney sanctions in Nevada district court case A-21-828840-C are found in this publication

Detailed allegations vs. Joseph Hong are in these publications

Relevant Nevada case law

NRS 207.470; Stoddart v. Miller, 2008 WL 6070835 (Nev. 2008 ); 

Siragusa v. Brown, 114 Nev. 1384, 971 P.2d 801 (1999); 

Gordon v. Eighth Judicial Dist. Ct., 12 Nev. 216, 231, 913 P.2d 240, 250-51 (1996); 

Cummings v. Charter Hosp. of Las Vegas, Inc., 111 Nev. 639, 896 P.2d 1137 (1995); 

Allum v. Valley Bank of Nevada, 109 Nev. 280, 849 P.2d 297 (1993); 

Hale v. Burkhardt, 104 Nev. 632, 634, 764 P.2d 866, 867 (1988).