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

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.

Cause of Action: Abuse of Process

The Elements of Abuse of Process apply to all defendants in all related cases

Interpleader complaint was an abuse of process because Defendant Steven Scow named parties who don’t have a claim and because it was filed to obstruct the administration of justice in other cases that were improperly filed, the wrong parties were intentionally named and the correct ones intentionally omitted.

The attorneys in all the related cases have engaged in a massive fraud on the court, involving presenting false evidence,

1. Filing of a lawsuit made with ulterior purpose other than to resolve dispute

Link to “Interpleader Complaint was filed with an ulterior motive

This interpleader complaint was filed for the corrupt purpose of continuing to obstruct a fair, evidence-based adjudication of Nona Tobin’s claims.

Links to NV Supreme Court cases 82294, 82234, and 82094

The defendants, jointly in concerted action and/or conspiracy, and each one separately,are utilizing this untimely, unwarranted, and harassing interpleader complaint in the corrupt attempt to moot the appeals of their non-meritorious claims in cases A-15-720032-C and A-19-799890-C.

Defendants improperly utilized this and the multiple related civil actions intended to the quiet title following a disputed 2014 HOA foreclosure. Their corrupt purpose was to get the court to bless their clients’ theft of Nona Tobin’s property, and the attorneys of those engaged in racketeering, conspired to cover it up.

Civil actions have been used to steal from Nona Tobin

  1. Attorneys have presented false evidence, withheld evidence, falsified documents to cover up FirstService Residential dba Red Rock Financial’s predatory debt collection that led to the secret foreclosure sale.
  2. Attorneys have presented false evidence, withheld evidence, falsified documents, to cover up Steven Scow’s, and other conspirators’ misappropriation of the proceeds o of many secretly-conducted sales.
  3. Joseph Hong and Melanie Morgan conspired to engineer an ex parte meeting with Judge Kishner in order to derail Nona Tobin’s case.
  4. Nationstar recording false claims to the title of the subject property to abuse the quiet title litigation process to get a court-sanctioned theft of Nona Tobin’s property.
  5. Joseph Hong conspired with others to conceal that Jimijack’s void deed had no legal capacity to hold or transfer title.
  6. Brittany Wood conspired with others not having an admissible deed and then fraudulently conveying it to one of the trustees as an individual.
  7. Joseph Hong’s and Melanie Morgan’s negotiating a fraudulent deal to steal Nona Tobin’s property that was represented to the court as a Nationstar-Jimijack settlement of all claims, but was actually a contract between non-parties to the litigation.
  8. Brittany Wood misrepresenting the court record, the facts and the law, in order to evade detection that her clients’ had knowingly received Tobin’s fraudulently conveyed property.

2. Wilfull act in the use of legal process not proper in the regular conduct of the proceeding

Steven Scow named five defendants in the interpleader complaint when he knew that four of those defendants had already recorded releases of their claims.

Link to Nona Tobin’s 3/15/21 Request for Judicial Notice of the Clark county Recorder’s Office records for APN 191-13-811-052.

Steven Scow’s allegations in the complaint were false and were for the corrupt purpose of evading detection that he misappropriated the proceeds of this 8/15/14 foreclosure sale and a dozen other Sun City Anthem foreclosures that were secretly, and without legal authority, conducted by Red Rock Financial Services in 2014.

Steven Scow has unlawfully retained the proceeds from multiple HOA foreclosures in an unauthorized, unaudited attorney trust account.

Link to “HOA debt collectors yield an unlawful amount of power
Link to Sun City Anthem bylaws 3.20/3.18 (annotated) prohibition of the delegation of certain Board duties and the Board’s loss of control of funds collected for the benefit of the HOA
Link to “SCA board secretly sold a dozen houses in 2014
Link to “We can learn a lot from this Spanish Trail HOA case

3. Damages as a direct result of the abuse

Actual damages to Nona Tobin currently exceed $700,000 and counting because attorneys unilaterally rejected her 2017 offer to settle at no cost without approval of the HOA Board. Their motive was to cover up the fraudulent acts of Red Rock and other HOA agents and attorneys.

Links to NV Supreme Court cases 82294, 82234, and 82094 that the co-conspirator defendants are attempting to moot by this unwarranted and harassing interpleader complaint.

Steven Scow filed the interpleader action more than six years after he failed to distribute the $57,282.32 excess proceeds from the 8/15/14 sale

Nevada law required the proceeds to be distributed after the sale

The HOA foreclosure sale was conducted on 8/15/14, and the 2013 statutes applied.

Link to NRS 116.3116-NRS 116.31168 (2013) – the applicable 2013 NRS provisions governing HOA foreclosures

Links to SCA 223-224 and RRFS 047-048 show Steven Scow was instructed to interplead the proceeds on 8/28/14.

Mortgage servicing fraud is many big bank’s business model

In this case, however, Nationstar’s mortgage servicing fraud normal tactics weren’t available so it chose to use co-conspirator attorneys, to abuse the quiet title litigation process.
Link to 12/7/20 National settlement of all Attorneys Generals’ mortgage servicing complaint vs. Nationstar
Link to 2012 National mortgage settlement with Bank of America
Link to 2012 National mortgage settlement with Wells Fargo

Nona Tobin Declaration Under Penalty of Perjury

I, Nona Tobin, under penalty of perjury, state as follows:

I have personal knowledge of the facts stated herein, except for those facts stated to be based upon information and belief. If called to do so, I would truthfully and competently testify to the facts stated herein.

I am submitting the documentary evidence based on my personal knowledge, research, analysis, and/or experience.

I was forced into this litigation because Sun City Anthem attorney David Ochoa unilaterally obstructed my access to SCA CC&Rs XVI: Limits on Litigation alternative dispute resolution

See my 3/22/17 offer to settle at no cost to me or to the HOA that David Ochoa rejected, upon information and belief, based on his own imaginary authority or through consultation with HOA community managers, Sandy Seddon and/or Lori Martin.

My involvement with the courts in Nevada has 100% been a thus-far futile attempt to regain title to a house that was wrongly foreclosed and secretly sold by Red Rock Financial Services on 8/15/14, three months after I had approved a sale to the high bidder on auction.com.

Upon information and belief, the extreme abuse to which I have been subjected is only understandable if the opposing counsels are aiding and abetting their clients’ criminal actions, covering up their clients’ misdeed, and/or for their own unjust enrichment.

I have made the following videos and posted them on You-tube in an effort to simplify and publish the massive amount of evidence I have to support my claims that heretofore these attorneys have successfully suppressed and blocked from judicial scrutiny.

VIDEO 1:20-minute VIDEOHow did Nona Tobin lose the $500,000 house she inherited from Bruce Hansen?

4:52-minute VIDEO “How lenders cheat owners out of their houses

Over the last five years, no judge has looked at any evidence in district court cases A-15-720032-C, A-16-730078-C, or A-19-798990-C

7:39-minute VIDEO  “Complaint to the Nevada Commission on Judicial Discipline vs. Judge Kishner

2:08-minute VIDEO Is justice blind or is it just blinded by power or pals?

1:44-minute VIDEO “Please Judge Johnson

3:50-minute VIDEO “What evidence supports Nona Tobin’s claims?” – Craig Leidy declaration

1:56-minute VIDEO “All declarations under penalty of perjury support Nona Tobin

When all statements under oath support Nona Tobin, why does she keep losing?” 3-page blogpost with links to all declarations made under penalty of perjury.

Over the last five years, every opposing counsel lied to the court.

presented false evidence, concealed and misrepresented material facts, and obstructed a fair adjudication of my claims on their merits. 

2:48-minute VIDEO “Who started it?

5:53-minute VIDEO “Joseph Hong’s big ex parte lies

1:41-minute VIDEO “Plaintiffs did not meet their burden of proof

6:33-minute VIDEO “Nationstar lied about being owed $389,000

1:22-minute VIDEO “Joseph Hong dupes Judge Johnson

1:33-minute VIDEO “Judicial Jiu-Jitsu is fraud on the court

3:09-minute VIDEO “Nationstar kept changing its story to cover up the lie

2:05-minute VIDEO “Failure of Nevada civil courts to address white collar crime

17:53-minute VIDEO “Specific evidence of fraud against Nationstar

2:46-minute VIDEO “How Nationstar & Jimijack tricked the court into excluding all evidence

1:37-minute VIDEO “Nevada state courts are rigged

3:58-minute VIDEO “Remember Joseph Hong?”

3:36-minute VIDEO Why did Quicken secure a house that was already mortgaged?

2:24-minute VIDEO What does it take to get disbarred in Nevada?

2:59-minute VIDEO “Nationstar plays the IOU trick to steal from Nona Tobin

1:52-minute VIDEO “What kind of legal entity is Jimijack Irrevocable Trust?”

1:01-minute VIDEO “What is Jimijack Irrevocable Trust?”

4:52-minute VIDEO “How lenders cheat owners out of their houses

6:18-minute VIDEO “Nationstar and Joel Stokes stole my $500,000 house

0:50-minute VIDEO “10 reasons why to sanction Joseph Hong

7:39-minute VIDEO  “Complaint to the Nevada Commission on Judicial Discipline vs. Judge Kishner

1:01-minute VIDEO “A Simple Fable: Nationstar’s & Jimijack’s duel to the death

Actual damages to me personally

The consequences of this successful fraud perpetrated primarily by attorneys:

  1. The title to a $500,000 house was taken from me by a fraudulently conducted-unnoticed foreclosure sale,
  2. Nationstar stole from me the $389,000 outstanding Western Thrift & Loan debt of deceased borrower Gordon Hansen that I did not owe to anyone and was not owed to Nationstar by anyone,
  3. Joel and Sandra Stokes kept $100,000+ in over five years of rental profits that belong to me,
  4. Red Rock attorneys Koch & Scow retained $60,000 that they refused to distribute to me in 2014 and has now accrued plus six years of interest and costs to pursue my claim against massive obstruction
  5. I have been forced to expend tens of thousands of dollars on litigation costs and thousands of hours of personal time to attempt to recover what was stolen from me.

2:38-minute VIDEO “What happened after Sun City Anthem refused Nona Tobin’s 2017 offer to settle?

I declare under penalty of perjury under the laws of the State of Nevada that the foregoing is true and correct.

Dated this 21st day of March 2021,

Complaint vs. Brittany Wood

Link to 2020 court hearings Part 1
Link to 2/16/21 online complaint receipt to the Nevada Bar vs. Brittany Wood
Link to Complaint OBC21-0187 vs. Brittany Wood

Office of Bar Counsel stated this complaint must be handled by a judge

Link to 3/4/21 rejection letter

Implicated Nevada Rules of Professional Conduct

NRPC 3.1

Rule 3.1.  Meritorious Claims and Contentions.  A lawyer shall not bring or defend a proceeding, or assert or controvert an issue therein, unless there is a basis in law and fact for doing so that is not frivolous, which includes a good faith argument for an extension, modification or reversal of existing law.

Brittany Wood filed these unwarranted, meritless motions, joinders, and requests into A-19-799890-C to unfairly get Nona Tobin’s claims dismissed with prejudice for no proper purpose as to her clients had a simple remedy of making a title insurance claim.

7/6/20 JMOT Quicken Chiesi    

7/6/20 RFJN Quicken Chiesi       

 7/6/20 RFJN pages 1-4 is the exhibit list of documents in the Chiesi/Quicken request for judicial notice

8/3/20 RPLY Chiesi Quicken

Chiesi/Quicken wrongly prevailed by 12/3/20 NODP notice of dismissal with prejudice   that expunged three lis pendens to cover up that her clients were not bona fide purchasers nor innocent third parties

Link to NRS 111.180

NRS 111.180  Bona fide purchaser: Conveyance not deemed fraudulent in favor of bona fide purchaser unless subsequent purchaser had actual knowledge, constructive notice or reasonable cause to know of fraud.

      1.  Any purchaser who purchases an estate or interest in any real property in good faith and for valuable consideration and who does not have actual knowledge, constructive notice of, or reasonable cause to know that there exists a defect in, or adverse rights, title or interest to, the real property is a bona fide purchaser.

      2.  No conveyance of an estate or interest in real property, or charge upon real property, shall be deemed fraudulent in favor of a bona fide purchaser unless it appears that the subsequent purchaser in such conveyance, or person to be benefited by such charge, had actual knowledge, constructive notice or reasonable cause to know of the fraud intended.

Link to NRS 14.017

NRS 14.017  Notice of pendency of actions affecting real property: Transferability of property after withdrawal or cancellation.

      1.  Upon the withdrawal of a notice of the pendency of an action affecting real property, or upon the recordation of a certified copy of a court order for the cancellation of a notice of the pendency of such an action with the recorder of the county in which the notice was recorded, each person who thereafter acquires an interest in the property as a purchaser, transferee, mortgagee or other encumbrancer for a valuable consideration, except a party to the action who is not designated by a fictitious name at the time of the withdrawal or order of cancellation, shall be deemed to be without knowledge of the action or of any matter, claim or allegation contained therein, irrespective of whether the person has or at any time had actual knowledge of the action or of any matter, claim or allegation contained therein.

      2.  The purpose of this section is to provide for the absolute and complete transferability of real property after the withdrawal or cancellation of a notice of the pendency of an action affecting the property.

      (Added to NRS by 1987, 637)

NRS 14.017

Brittany Wood knows that no claims in prior proceedings were fairly adjudicated

NSM and Jimijack prevailed without adjudication

Nationstar claims and dispositions (260 pages of filed documents – 1/11/16 COMP, 6/2/16 AACC, 3/25/19 RCCM, 2/20/19 NTSO, 3/12/19 ANEO, and 5/31/19 SODW)

Nationstar prevailed without proof (29 pages links/screenshots)

Nationstar’s evidence was never examined (7 pages linked analysis of 3/12/19 4th supplemental list of disclosures)

Brittany Wood would also have seen, if she had looked, that nobody’s claims were adjudicated fairly in the prior proceedings, i.e., Nationstar never put on a case, never went to trial and prevailed despite dismissing all its claims without adjudication.

Jimijack claims dispositions (21 pages filed documents )

Tobin claims dispositions TOC (9 pages links/screenshots)

Tobin vs. Jimijack (59 pages filed documents 2/1/17 AACC, 3/13/17 RCCM, 6/24/19 NEFF)

Tobin vs. Lee (45 pages filed documents 2/1/17 CRCM, 3/13/17 XCAN, 6/24/19 NEFF)

Ex parte meeting with Judge Kishner resulted in Nona Tobin’s dispositive motions not being heard

STRICKEN SUA SPONTE BY BENCH ORDERS AT 4/23/19 EX PARTE HEARING

  1. 4/9/19 Tobin/Hansen Trust Notice of completion of mediation
  2. 4/9/19Tobin Notice of appearance to return to Pro Se status
  3. 4/10/19 Tobin Opposition to Nationstar’s motion for summary judgment against Jimijack and countermotion for summary judgment
  4. 4/12/19 19 Tobin notice of appearance to return to Pro Se status as an individual (duplicate filed in error)
  5. 4/12/19 Tobin/Hansen Trust Notice of completion of mediation (duplicate filed in error)
  6. 4/12/19 Tobin OPPC vs Nationstar and Jimijack (duplicate filed in error)
  7. 4/17/19 Tobin reply to support joinder to Nationstar motion for summary judgment

4/23/19 bench orders were not formalized until 11/22/19 order was entered five months after the trial I was excluded from:

Because she is not a party to the case, all documents filed with this Court by Nona Tobin as an individual, are rogue documents and are stricken from the record. This includes both the Motion to Dismiss and Motion for New Trial (and all oppositions or replies) and the Notice of Lis Pendens.

Page 4, paragraph 3, 11/22/19 post-trial order that formalized Judge Kishner’s 4/23/19 ex parte bench orders to strike Nona Tobin’s pro se filings from the record

Judge Kishner also refused to hear or consider Nona Tobin’s post-trial Pro Se motions that were stricken by granting improper motions by Joseph Hong (8/7/19 RESP/MSTR/MAFC) for counter- defendants and David Ochoa for cross- defendant HOA (8/8/19 RESP/JMOT) at the 9/3/19 hearing

  1. 7/22/19 MNTR motion for a new trial per NRCP 54(b) and NRCP 59(a)(1)(A)(B)(C)(F)
  2. 7/29/19 MTD Tobin Pro Se motion to dismiss Judge Kishner’s order granting quiet title to Jimijack for lack of jurisdiction per NRS 38.310(2)
  3. 8/7/19 NOLP 39-page Notice of Lis Pendens of case not in Judge Kishner’s court expunged from the property record by Judge Kishner granting the motion to strike by the HOA that had no adverse claim to Tobin for the title
  4. 8/26/19 FFCO Tobin Pro Se proposed findings of fact and order to grant Tobin motion to dismiss for lack of jurisdiction
  5. 8/8/19 LISP 7-page recorded Lis Pendens was expunged by 11/22/19 order although to do so was outside of Judge Kishner’s jurisdiction

Brittany Wood knows that her co-conspirators prevailed by deceit

Brittany Wood knows that the Nationstar-Jimijack settlement was fraudulent

Rule 3.4 Fairness to opposing party

Rule 3.4.  Fairness to Opposing Party and Counsel.  A lawyer shall not:       (a) Unlawfully obstruct another party’s access to evidence or unlawfully alter, destroy or conceal a document or other material having potential evidentiary value.

Brittany Wood did not explain how her clients would have been prejudiced if Nona Tobin’s claims had been heard on their merits, and yet she took aggressive actions, including gross misrepresentations of the property record, the court record, and the law and ensure that ALL Nona Tobin’s claims, even those to which her clients held no interest, were dismissed with prejudice and ALL her evidence suppressed.

Brittany Wood suppressed the preliminary title report and proof of title insurance

Link to 2/7/20 emails of Nona Tobin’s frustrated attempts to get the preliminary title report.

Wood misrepresented the property record to obscure her clients’ wrongdoing at Nona Tobin’s expense

Link to RFJN Clark County official property record for APN: 191-13-811-052

Wood concealed all property records related to the fraudulent actions dispute between Nona Tobin accused Nationstar and Joel Stokes

She deliberately excluded from the 7/6/20 Request for Judicial Notice ALL of the assignments related to the Hansen deed of trust that are germane to Tobin’s case against Nationstar and Joel Stokes.

4/22/04 Hansen deed of trust assignments are all disputed and none were included in Wood’s request for judicial notice

4/12/12 ASSIGN MERS to BANA by BANA

9/9/14 ASSIGN BANA to Wells Fargo by BANA

12/1/14 ASSIGN BANA to Nationstar by Nationstar

3/8/19 RESCIND 12/1/14 BANA to Nationstar by Nationstar

3/8/19 ASSIGN Wells Fargo to Nationstar by Nationstar

6/3/19 RECONVEY Hansen DOT to Joel Stokes – not to Nona Tobin, the personal representative of the borrower’s estate – by Nationstar

Brittany Wood knew that Jimijack’s deed was void

6/9/15 DEED Jimijack defective VOID deed was in Wood’s Exhibit 7 even though Brittany Wood knew that Jimijack’s deed had no legal capacity to hold or transfer title was inadmissible per NRS 111.345 and that all subsequent transfers were also void

Link to 1/17/17 Tobin DECL declaration re Jimijack’s defective deed

Brittany Wood knew that Jimijack’s 5/1/19 transfer of title was void as Jimijack had no valid interest to convey

5/1/19 DEED fraudulent conveyance of title from Jimijack to Joel Stokes five weeks bfore the trial to evade detection by Judge Kishner that both the Hansen Trust’s 8/27/08 deed or Nona Tobin’s 3/28/17 deed were superior to Jimijack’s deed for which no notary record exists.

Jimijack to Joel Stokes deed was recorded five weeks before the trial and without Judge Kishner ever admitting it into evidence despite NRS 111.345, but it is in Wood’s Exhibit 15.

Brittany Wood knowingly misrepresented Nona Tobin’s deed as”a wild deed outside the chain of title.”

Wood deliberately damage Nona Tobin, and obstructed her case from being heard, by misrepresent the 3/28/17 recorded deed, as an individual, to falsely represent to the court that this deed was inadequate to give Nona Tobin standing to pursue an NRS 40.010 claim.

Why then falsely claim that I had recorded a wild deed? (7/6/20 JMOT, page 6)

Nona’s authority to close the Gordon B. Hansen Trust and execute a deed to transfer its sole asset to the sole remaining beneficiary has been uncontradicted in the Clark County official property record since 2017.

Brittany Wood advocated vigorously for the preposterous argument that Nona was in privity with herself as trustee of a trust that was closed in 2017 as if there was only one element to claims preclusion and not four.

Brittany Wood assiduously ignored Jimijack’s obviously defective deed because she knew that the Chiesi deed is the fruit of the poison Jimijack deed tree.

Brittany Wood condoned the covert transfer of Jimijack’s defective deed to non-party Joel A. Stokes before the trial solely because she knew that Jimijack’s deed was void and that all subsequent transfers were void.

Jimijack’s 6/9/15 deed is void. Joel Stokes’ 5/1/19 deed is void. Wood’s clients’ 12/27/19 deed is also void

12/27/19 DEED Joel A. Stokes to Brian and Debora Chiesi

Implicated Statutes Fraudulent Conveyances

NRS 205.330  Fraudulent conveyances.  Every person who shall be a party to any fraudulent conveyance of any lands, tenements or hereditaments, goods or chattels, or any right or interest issuing out of the same, or to any bond, suit, judgment or execution, contract or conveyance, had, made or contrived with intent to deceive and defraud others, or to defeat, hinder or delay creditors or others of their just debts, damages or demands; or who, being a party as aforesaid, at any time shall wittingly and willingly put in use, avow, maintain, justify or defend the same, or any of them, as true and done, had, or made in good faith, or upon good consideration, or shall alien, assign or sell any of the lands, tenements, hereditaments, goods, chattels or other things before mentioned, conveyed to him or her as aforesaid, or any part thereof, is guilty of a gross misdemeanor.

NRS 205.360  Knowingly receiving fraudulent conveyance.  Every person who shall receive any property or conveyance thereof from another, knowing that the same is transferred or delivered in violation of, or with the intent to violate, any provision of NRS 205.345205.350 and 205.355, shall be guilty of a misdemeanor.

NRS 111.175  Conveyances made to defraud prior or subsequent purchasers are void.  Every conveyance of any estate, or interest in lands, or the rents and profits of lands, and every charge upon lands, or upon the rents and profits thereof, made and created with the intent to defraud prior or subsequent purchasers for a valuable consideration of the same lands, rents or profits, as against such purchasers, shall be void.

Berge v. Fredericks, 95 Nev. 183, 186 (Nev. 1979) (“However, a party claiming title to the land by a subsequent conveyance must show that the purchase was made in good faith, for a valuable consideration; and that the conveyance of the legal title was received before notice of any equities of the prior grantee.”)

“In cases of this kind it is seldom, if ever, possible to prove fraudulent intent by direct evidence, hence it is necessary to resort to circumstantial evidence. Badges of fraud are infinite in number and form. 27 C.J. 483, 822.” S.G. R. Bank v. Milisich, 48 Nev. 373, 376-77 (Nev. 1925)

Badges of fraud

Link to Stay Clear of Fraudulent Transfer Badges

Excerpt from Dec 17, 2018 Post by AssetProtectionAttorneys

A transfer is considered fraudulent if made with actual intent to hinder, delay, or defraud any creditor of the debtor. There’s no bright-line rule here. A judge looks for indicia or “badges” of fraudulent intent. A judge has broad discretion in determining whether the presence of one or more badges indicates a transfer was fraudulent.

Webinar Rebroadcast: Avoiding the Badges of Fraudulent Transfers

Furthermore, the standard of proof that must be met to indicate fraudulent intent is not the “beyond a shadow of a reasonable doubt” standard of criminal trials. But rather it is the less rigorous “preponderance of evidence” standard of civil litigation. The potential badges you should avoid include:

1. The transfer or obligation to an insider:

This may, or may not, be a factor in determining whether there was a fraudulent transfer. For example, it’s common business practice for someone to transfer personal property to a business they control (such as an LLC, LP, or a closely held corporation) in order to capitalize it. Such a transfer, if done while creditor seas are calm, will almost certainly not be considered fraudulent, especially if the transferor receives an interest in the company equivalent to their capital contribution. On the other hand, transferring real estate to one’s uncle the week before a lawsuit commences will likely be considered fraudulent.

2. The debtor retained possession or control of the property transferred after the transfer:

This may or may not be a factor in a fraudulent transfer case. For example, although a lien is a transfer of equity, mortgaged real estate typically remains in the owner’s possession as a matter of standard business practice. In contrast, placing one’s home in an international trust and then continuing to live in it rent-free is more likely to be seen as a fraudulent transfer.

3. The transfer or obligation was concealed:

See the comment for badge of fraud (7) below.

4. Before the transfer was made or obligation was incurred, the debtor had been sued or threatened with suit:

Some transfers (such as a gift to an insider) are very vulnerable to a fraudulent transfer ruling if they occur after a creditor threat arises. At the same time, no judge would expect you to stop your normal business activities once you’ve been sued, especially considering that a lawsuit may drag out for years. Of course, some business activities may involve transfers of assets.

Consequently, if you are facing a lawsuit, it’s important to transfer property so there is a plausible reason for the transfer, besides trying to protect assets. For example, by taking money and investing it in an LLC, you can protect the money while honestly claiming that you were only engaging in a business venture, instead of trying to defeat a creditor. At the same time, your claim of having a valid business purpose may be insufficient if other badges point to the fact that you transferred the asset to hinder, delay, or defraud your creditors.

7. The debtor removed or concealed assets:

Oftentimes, there’s a good reason for financial privacy, besides trying to defeat a creditor. Depending on your reasons, it may not be safe to conceal assets while the creditor seas are calm. However, this is usually not a good idea once one is threatened by creditors. Remember: everything can and will usually be revealed in court, and privacy is more for lawsuit prevention than anything else. Above all, remember that no plan should rely exclusively on secrecy and that improper (but not all) financial privacy measures are usually considered a badge of fraud.

Above all, remember a judge must determine whether a particular transfer was undertaken to cheat a creditor. If there’s not a plausible economic reason for a transfer, and if the transfer is not a part of “business as usual”, then it might not stand up if challenged in court. Such transfers will almost always carry at least one badge of fraud.

Brittany Wood ignored all the lis pendens

She did not include any of the lis pendens in the RFJN that show both that her clients recorded claims adverse to mine while lis pendens were on record, but also the Joel and Sandra Stokes released a lis pendens that wasn’t theirs.

Lis Pendens exhibit (76 pages) shows all the recorded and released lis pendens that Brittany Wood failed to acknowledge when she got Judge Johnson to expunge Tobin’s lis pendens as if they had never existed.

The only purpose for this order was to cover-up criminal actions, and Brittany Wood knows it.

More implicated professional ethics standards

TRANSACTIONS WITH PERSONS OTHER THAN CLIENTS

      Rule 4.1.  Truthfulness in Statements to Others.  In the course of representing a client a lawyer shall not knowingly:

      (a) Make a false statement of material fact or law to a third person; or

      (b) Fail to disclose a material fact to a third person when disclosure is necessary to avoid assisting a criminal or fraudulent act by a client, unless disclosure is prohibited by Rule 1.6.

      Rule 4.4.  Respect for Rights of Third Persons.

      (a) In representing a client, a lawyer shall not use means that have no substantial purpose other than to embarrass, delay, or burden a third person, or use methods of obtaining evidence that violate the legal rights of such a person.

MAINTAINING THE INTEGRITY OF THE PROFESSION
      Rule 8.3.  Reporting Professional Misconduct.

      (a) A lawyer who knows that another lawyer has committed a violation of the Rules of Professional Conduct that raises a substantial question as to that lawyer’s honesty, trustworthiness or fitness as a lawyer in other respects, shall inform the appropriate professional authority.

      Rule 8.4.  Misconduct.  It is professional misconduct for a lawyer to:

      (a) Violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another;

      (b) Commit a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness or fitness as a lawyer in other respects;

      (c) Engage in conduct involving dishonesty, fraud, deceit or misrepresentation;

      (d) Engage in conduct that is prejudicial to the administration of justice;

      (f) Knowingly assist a judge or judicial officer in conduct that is a violation of applicable rules of judicial conduct or other law.

Nationstar Mortgage’s Fraud

What is the dispute with Nationstar?

The dispute is over a $436,000 Western Thrift & Loan Deed of Trust (DOT) executed by Gordon Hansen on 7/15/04. Nationstar serviced the loan beginning on 12/1/13 on behalf of an investor NSM refused to identify.

On 12/1/14, Nationstar recorded a claim that Nationstar was owed the $389,000 balance that remained outstanding after the borrowerʼs death.

Link to Nationstar’s 12/1/14 claim
Link to Nationstar’s 3/8/19 rescission of its 12/1/14 claim

That Nationstar rescinded its provably false, opportunistic claim didn’t stop Nationstar from stealing a house for a debt it was not owed. 

Laws implicated when considering appropriate sanctions for Nationstar and its attorneys

BANK FRAUD/RACKETEERING/RECORDING FALSE CLAIMS

  1. NRS 205.330  Fraudulent conveyances.  
  2. NRS 205.372  Mortgage lending fraud; penalties; civil action.
  3. NRS 205.377  Multiple transactions involving fraud or deceit in course of enterprise or occupation; penalty.
  4. NRS 205.380  Obtaining money, property, rent or labor by false pretenses.
  5. NRS 205.395  False representation concerning title; penalties; civil action.
  6.  NRS 205.405  Falsifying accounts.  
  7. Racketeering
  8. NRS 207.360       “Crime related to racketeering” defined.
  9. NRS 207.400       Unlawful acts; penalties.
  10. NRS 207.470       actions for damages resulting from racketeering.
  11. NRS 207.480  Order of court upon determination of civil liability.  
  12. NRS 207.520           Limitation of actions.

CONFISCATION OF PROPERTY WITHOUT FORECLOSING

  1. NRS 40.050  Mortgage not deemed conveyance.  
  2. PUD Rider F. Remedies

Attorney sanctions

NRCP 11

(b) Representations to the Court. By presenting to the court a pleading, written motion, or other paper — whether by signing, filing, submitting, or later advocating it — an attorney or unrepresented party certifies that to the best of the person’s knowledge, information, and belief, formed after an inquiry reasonable under the circumstances:

(1) it is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation;

(2) the claims, defenses, and other legal contentions are warranted by existing law or by a nonfrivolous argument for extending, modifying, or reversing existing law or for establishing new law;

(3) the factual contentions have evidentiary support or, if specifically so identified, will likely have evidentiary support after a reasonable opportunity for further investigation or discovery; and

(4) the denials of factual contentions are warranted on the evidence or, if specifically so identified, are reasonably based on belief or a lack of information.

Link to Nevada Rules of Professional Conduct

No bank foreclosure was ever initiated on the Hansen deed of trust. Nationstar just stole it.

Neither servicing bank, (Nationstar succeeded Bank of America as servicing on 12/1/13) foreclosed on the Hansen DOT even though it was in default after Hansen died on 1/14/12.

Had Nationstar been the beneficiary of the DOT, it would have foreclosed or collected the debt by allowing the property to be sold at fair market value. NSM did not record a notice of default on the Hansen DOT.

Nationstar did not allow the property to be sold to MZK for $367,500 on 5/8/14. Nationstar did not complain when RRFS rejected its 5/28/14 super-priority offer of $1100 to close the MZK escrow.

Nationstar allowed the property to be sold for $63,100 while a $358,800 was pending lender approval .

Then, three months after the HOA foreclosed to collect $2,000 in delinquent HOA dues, NSM claimed that Bank of America gave NSM the Hansen DOT on 10/23/14. 

Nationstar recorded and filed false claims and dismissed all its claims without adjudication

Link to Plaintiff Nationstar’s 1/11/16 complaint

Link to Nationstar’s 2/20/19 stipulation to dismiss its claims
Link to Nationstar’s 4/12/16 motion to substitute as real party in interest, set aside default and intervene

Link to Nationstar’s only other filed claims: 6/2/16 AACC claims against Jimijack

Link to Counter-claimant Nationstar’s 5/31/19 stipulation to dismiss its 6/2/16 claims

Nationstar did not file any claims against Nona Tobin or against the Hansen Trust

Nationstar never refuted any of the claims Nona Tobin asserted against Nationstar, but got away with it by lying to the court

Link to 4/10/19 Nona Tobin opposition to Nationstar’s motion for summary judgment vs Jimijack and motions for summary judgment that was stricken from the record unheard due to Nationstar’s attorney Melanie Morgan’s ex parte misrepresentations to Judge Kishner
Link to 4/17/19 Nona Tobin reply in support of joinder to Nationstar’s motion for summary judgment vs Jimijack and motions for summary judgment that was stricken from the record unheard due to Nationstar’s attorney Melanie Morgan’s ex parte misrepresentations to Judge Kishner
Link to 7/22/19 Nona Tobin motion for a new trial pursuant to NRCP (b) and NRCP 59(a)(1)(A)(B)(C)(F) that was stricken from the record unheard due to ALL opposing counsels’ misrepresentations to Judge Kishner
Link to 7/29/19 Nona Tobin motion to dismiss Judge Kishner’s orders for lack of jurisdiction for Nationstar’s and Jimijack’s noncompliance with NRS 38.310 that was stricken from the record unheard due to ALL opposing counsels’ misrepresentations to Judge Kishner
Link to unheard 4/24/19 MVAC & MSJ Nona Tobin motion to vacate Judge Kishner’s 4/18/19 order that granted Nationstar’s limited joinder to the HOA’s unwarranted motion for summary judgment pursuant to NRCP 60(b)(3) fraud on the court and motion for summary judgment vs. all parties that languishes on the record unheard due to ALL opposing counsels’ misrepresentations to Judge Kishner about Nona Tobin’s right to represent herself.

Nationstar prevailed despite ALL declarations under penalty of perjury support Nona Tobin and not Nationstar, by tricking the court into ignoring all the evidence, such as…

EXHIBITS TO 5/23/19 TOBIN RPLY TO
SCA 5/2/19 OPPM TO TOBIN MOTION TO RECONSIDER AND
JIMIJACK’S 5/3/19 JOINDER TO SCA AND

 NSM’S 5/3/19 JOINDER TO SCA OPPM

Exhibit “1”; April 20, 2019 Tobin declaration
Exhibit “2”May 11, 2018 and May 13, 2019 Leidy declaration
Exhibit “3” May 20, 2019 Proudfit declaration
Exhibit “4″ Resident Transaction Reports for 2763 White Sage 2664 Olivia Heights
Exhibit “5” No valid Board authorization for sale
Exhibit “6” Proposed Findings of Fact
Exhibit “7” Authenticated OMBUDSMAN NOS records for 17 foreclosures
Exhibit “8” 2nd NOS for two sales but not for 2763
Exhibit “9” March 22, 2019 Tobin DECL opposing NSM MSJ vs. Jimijack
Exhibit “10” April 12, 2019 MSJ v. Jimijack

No affidavits support Nationstar’s claims, but so what?

In its 3/27/17 OMSJ, Nationstar claimed that on 12/1/14 Wells Fargo had given NSM the DOT. This was supported by a duplicitous declaration regarding business records.

Link to 3/8/19 Nationstar rescission of its 12/1/14 claim that Bank of America assigned its interest to Nationstar

Link to 3/8/19 Nationstar claim Wells Fargo assigned its interest to Nationstar

In February 2019, Nationstar refused to produce any documents in response to Tobinʼs RFDs and interrogatories to prove any of its claims.

On 3/8/19, Nationstar recorded that it rescinded its 12/1/14 claim that it got its interest from Bank of America, and then two hours later recorded that it had Wells Fargoʼs undisclosed power of attorney to give Nationstar the authority to assign Wells Fargoʼs non-existent interest to Nationstar. 

Nationstar produced no proof that it owned the Hansen DOT during two lawsuits over the validity of the HOA sale.

All the evidence Nationstar entered into the record actually proved the opposite, but it was never subjected to judicial scrutiny Nationstar.

The real owner of the Hansen DOT would have supported Tobinʼs efforts to void the sale so the DOT would not have survived as it the sale had never happened.

Tobin and Nationstar were initially aligned to get the court to void the HOA sale until Nationstar learned that it would be impossible to foreclose on Tobin since Tobin had put it into the record that she had documents that could prove NATIONSTAR did not have the standing to foreclose.

Nationstarʼs covert deal with Joel Stokes was solely to prevent the Court from conducting an evidentiary hearing that would have exposed the inconvenient truth that neither Nationstar nor Stokes could prove their claims.

Nationstar was excused from trial by saying all claims had been resolved by Nationstar-Jimiack settlement.

Link to Nationstar-Jimijack “settlement which was really a $355,000 deal between Civic Financial services and Joel Stokes

The HOA wrongly foreclosed, but not without Nationstarʼs assistance.

The banks could have stopped the HOA from foreclosing by recording a Notice of Default (NRS 116.31162(6)).

The HOA sale should have been cancelled when BANAʼs agent tendered $825 on 5/9/13 to cure the nine months that were then delinquent.

The HOA sale would have been avoided if the serving banks had not prevented four escrows from closing as escrows instructions were to pay the HOA whatever it demanded.

The HOA sale would have been avoided if Nationstar had not rejected the 5/8/14 $367,500 www.auction.com sale to MZK Properties.

Nationstar, the servicing bank that is supposed to be a fiduciary, acting on behalf of the investor, turned a blind eye to an 8/15/14 HOA sale for 18% of the $367,500 www.auction.com sale price that Nationstar had just rejected.

NATIONSTAR does not hold the original Hansen promissory note.

NSM 258-259 is a COPY of the Hansen promissory note that Nationstar entered into the record to trick the Court.

NSM does not have Hansenʼs original note, but NSM tried to conceal that fact by disclosing a COPY in NSM 258

NRS 52.235 “Original required. To prove the content of a writing, recording or photograph, the original writing, recording or photograph is required, except as otherwise provided in this title.”


NSM 260 shows no endorsement of Hansenʼs note to Nationstar or to ANY of the lenderʼs NSM claims assigned the note to Nationstar. 
3/27/17 NSM filed a DECL that misrepresents its servicing bank record to deceive the court that NSM had no proof it owned the DOT 

All Nationstar’s and Bank of America’s recorded actions affecting the Hansen deed of trust are fraudulent

All Nationstar’s disclosures in discovery were deceptive and fraudulent

Link to 12/26/18 Nona Tobin’s statement of claims vs Nationstar
Link to 2/9/18 Nationstar Individual Case Conference Report and initial disclosures
Link to 2/7/19 Nationstar 1st supplemental disclosures
Link to 2/12/19 Nationstar 2nd supplemental disclosures
Link to 2/27/19 Nationstar 3rd supplemental disclosures
Link to 3/12/19 Nationstar 4th supplemental disclosures (served two weeks after discovery ended on 2/28/19)

Nationstar refused to produce any documents requested in discovery

Link to 2/21/19 Nationstar response to Nona Tobin’s request for documents
Link to 2/21/19 Nationstar response to Nona Tobin’s interrogatories
Link to 2/28/19 Nationstar 1st supplemental response to Nona Tobin’s request for documents
Link to 2/28/19 Nationstar 1st supplemental response to Nona Tobin’s interrogatories

Wells Fargo did not assign anything to Nationstar.

Page 7 is Morgan’s totally deceptive ploy to obfuscate the fact that Nationstar has no valid claim to be the beneficiary.

Servicing banks (those that handle the paperwork on behalf of the “beneficiary” who is the investor to whom the debt is actually owed).

The dispute with Nationstar is not because Nationstar wrongly foreclosed on the Hansen deed of trust.

The dispute is caused by:

  1. Both BANA & Nationstar obstructing multiple fair market value, arms-length sales, approved by the Hansen Estate.
  2. Nationstar’s letting the HOA foreclose without notice for 18% of the $367,500 www.auction.com sale that Nationstar had just rejected, and then
  3. After the Hansen DOT was extinguished by the HOA foreclosure, Nationstar lied on the record about being owed the $389,000 outstanding balance on Hansenʼs DOT.
  4. According to NRS 107.28, (2.) A trustee under a deed of trust must not be the beneficiary of the deed of trust for the purposes of exercising the power of sale pursuant to NRS 107.080, but Nationstar claimed to be both the beneficiary and the trustee – when it was neither – and reconveyed the property to Joel Stokes on 6/3/19 to steal the house from Nona Tobin
  5. The Clark County Recorderʼs Office Property Record shows NSM began recording conflicting claims on 12/1/14, more than three months after the HOA sale.
  6. Nationstar lied in its 1/11/16 complaint to say that some unspecified entity had assigned its interest to Nationstar on 2/4/11
  7. BANA & NSM recorded 11 claims regarding the Hansen DOT, but neither ever recorded a Notice of Default, the mandatory condition precedent to the trusteeʼs executing the power of sale on behalf of the beneficiary.
  8. No bank has the right to confiscate a property without foreclosing by following the notice and due process steps defined in NRS 107.080, as amneded by AB 284 (21011), Nevada’s anti-foreclosure fraud law.
Link to Nationstar’s former attorney Robin Wright’s white paper on the affidavit requirements of AB 284 (2011)
Link to ANTI-FORECLOSURE FRAUD LAW AB 284 (2011) and legislative digest

2nd complaint to the Nevada Attorney General & exhibits

Links to exhibits to 2nd complaint to the Nevada Attorney General

  1. 12/1/14 Assignment    Nationstar – no power of attorney – executed B of A to Nationstar assignment of the 7/22/04 Hansen deed of trust
  2. NSM 258-260 Nationstar disclosed it did not have the original Hansen promissory note, and the copy of the note it had was not endorsed to Nationstar
  3. 2/20/19 SODWOP      Nationstar dropped all its quiet title claims against all parties except Jimijack (1/11/16 COMP in A-16-730078-C) without adjudication or any judicial scrutiny of evidence.
  4. 2/2819 RESP Pg 6      Nationstar admitted in response to interrogatories that it was not the beneficiary of the Hansen deed of trust; it was just the servicing bank for non-party Wells Fargo who has never claimed to be the beneficiary of the Hansen deed of trust. On page 7, the verification only included that Nationstar was the servicer and was signed by a previously unknown person of unknown authority.
  5. 3/8/19 Rescission        Nationstar – no power of attorney – rescinded 12/1/14 B of A to Nationstar assignment of the 7/22/04 Hansen deed of trust which means that Nationstar had no recorded claim to give it standing to be in either cases A-15-720032-C or A-16-730078-C and is judicially estopped from claiming that it was the owner of the Hansen deed of trust during all relevant times or ever.
  6. 3/8/19 Assignment      Nationstar – no power of attorney – executed Wells Fargo to Nationstar assignment of the 7/22/04 Hansen deed of trust
  7. 3/14/19 AG 2-2019     Complaint to the AG that was allegedly served on Melanie Morgan
  8. 3/18/19 NITD Nationstar three-day notice to take default against Jimijack since Jimijack did not answer the 6/2/16 AACC
  9. 3/21/19 MSJ   Nationstar filed an MSJ against Jimijack and not against Nona Tobin, the HOA or the Gordon B Hansen Trust
  10. 4/10/19 OPP/MSJ       Tobin opposition to Nationstar’s MSJ as Nationstar did not own the beneficial interest of the Hansen deed of trust; and the HOA sale was void in its entirety so foreclosure would have to have been against Tobin for any lender; plus Jimijack’s deed was void per NRS 111.345.
  11. 4/9/19 NRS 38.310(2) Notice of completion of mediation by Tobin/Hansen Trust when neither Jimijack nor Nationstar had complied with NRS 38.310 so the court lacked jurisdiction to grant them relief sought.
  12. 4/12/19 NS      Jimijack (who didn’t have a valid deed never filed any claims against Nationstar or against Tobin or the Hansen Trust) prevailed in the quiet title case by “settling” out of court with Nationstar in a fraudulent deal that excluded Tobin and the Hansen Trust. Judge Kishner never examined any evidence to support their claims (Judge Kishner held 42 hearings, but never examined any evidence.)
  13. 4/17/19 TOC exhibits 600 pages of evidence to support Tobin’s claims that were stricken from the record unheard by bench orders at the 4/23/19 ex-parte hearing.
  14. 4/19/19 RESP Nationstar convinced the court that it was ok for Nationstar and Jimijack to settle the quiet title dispute without the court examining any evidence because Nationstar and Tobin/ Hansen trust weren’t really opposing parties.
  15. 4/23/19 NWM Nationstar dropped its motion for summary judgment against Jimijack without Jimijack filing an opposition (that Judge Kishner required to be filed by 4/26/19 on her 4/12/19 order continuing the hearing to 5/7/19and convinced Judge Kishner that was the end of the case because she had granted the HOA’s motion for summary judgment (based on no evidence) and Nationstar’s limited joinder (based on no evidence and explicitly contrary to the Hansen deed of trust PUD rider Remedies (f) (NSM 160) that prohibits the use of tender of delinquent HOA assessments as a de facto foreclosure.
  16. 4/23/19 Transcript      Nationstar & Jimijack’s attorneys, Melanie Morgan & Joseph Hong met with Judge Kishner ex-parte after serving notice that the hearing was continued on 4/15/19 (SAO) and 4/22/19 (NTSO) in order to get Nona’s pro se motions and notices stricken unheard from the record to make a fraudulent “settlement”.
  17. 5/23/19 DOT annotated          Neither Nationstar nor Jimijack are parties to $355,000 deed of trust executed & recorded on 5/23/19 by nonparties Joel A Stokes & Civic Financial Services
  18. 4/23/19 video 
  19. 4/23/19 minutes         
  20. 5/1/19 DEED  Joel & Sandra Stokes as trustees of Jimijack dumped Jimijack’s deed by transferring the title into Joel’s name as an individual. Judge Kishner never ruled on Jimijack’s deed that Nona Tobin claimed was inadmissible per NRS 111.345 in her 2/1/17 AACC vs Jimijack and in two declarations under penalty of perjury.
  21. 5/21/19 Transcript      Nationstar attorneys characterize as a settlement agreement between parties Jimijack & Nationstar that excluded parties Nona Tobin & the Gordon B. Hansen Trust from the title fight without the court examining any evidence including not examining the alleged settlement documents.
  22. 5/31/19 NESO Nationstar stipulates that it drops its remaining quiet title claim against Jimijack with prejudice so they both win without the judge ever looking at the evidence or hearing Nona Tobin’s claims against Nationstar & Jimijack.
  23. 6/3/19 Reconvey         Nationstar dba Mr. Cooper falsely claimed to be both the beneficiary and the trustee of the Hansen deed of trust and reconveyed without legal authority the property to Joel A Stokes two days before the quiet title trial (A-15-720032-C) that allegedly was held to determine the title rights between the Gordon B. Hansen Trust and the Jimijack Irrevocable Trust.
  24. Supreme Court case 79295     Online case management system – see how opposing parties were successful in getting me removed as a party by saying I was not aggrieved. See orders SC 19-37846 and SC 20-016346.
  25. Judicial Jiu-jitsu          Youtube channel contains closed-caption videos of all the A-15-720032-C court hearings from 2016-2019 and all the A-19-798990-C court hearings held in 2020 as well as brief videos explaining the trickery employed by the opposing attorneys to suppress Nona Tobin’s evidence and obstruct her access to a fair adjudication of her claims on their merits by an impartial tribunal.

11/10/20  NV AG complaint

12/4/20 rejection of the complaint by the Nevada Attorney General

1st complaint to the Nevada Attorney General & exhibits

Links to Exhibits to 3/14/19 complaint to the NV Attorney General

2011               Certified fraud examiner Amicus curiae MA Supreme Court

7/15/2004      Western Thrift Deed of Trust

7/15/2004      COPY of GBH note NSM 258-260

5/14/2008      10 SCA bylaws 3.20/3.18abefgi prohibits BOD delegation

3/11/2011      2011 anti-foreclosure fraud law AB 284 

10/1/2011      NV 2011 Legislative Digest re AB 284 changes

2/1/2012        2012 National Mortgage Settlement

4/12/2012      Recorded DOT assign to BANA

8/8/2012        6 Sparkman RPA $310K

8/10/2012      Tobin counter to require lender to pay seller costs

8/10/2012      7 BANA short sale addendum

8/11/2012      8 Tobin re lender is seller

9/17/2012      9 SCA MSJ exhibit 3 re intent to lien SCA628

9/20/2012      5 Hearing Notice Sanction 4 Delinquent Assessments

10/3/2012      4 Tobin letter 2 SCA w/ 8/17/12 chk 143 + death cert

1/27/2013      BANA confusion over DOT – misc docs

6/5/2013        HUD-1 draft showing $3055.47 due to HOA out of escrow

6/19/2013      Proudfit 2 Ticor: BANA rejected buyer

12/31/2013    Mortgage transfer disclosure requirements

7/1/2014        Leidy-Tobin emails 7/24/14 through 10/24/14

7/22/2014      11 SCA 280-280 BOD denial of fee waiver request

8/21/2014      RRFS trust account check $57,282.32 to CC District court

9/9/2014        BANA recorded 8/21/14 assignment to Wells Fargo

9/25/2014      2 Res Trans Rpt 1336-7 GBH 2 Jimijack

12/1/2014      NS recorded 10/23/14 assignment to itself as BANA’s “attorney-in-fact”

3/12/2015      WF recorded substitution trustee reconvey 2nd DOT 2 GBH

4/1/2015        Thomas Baynard CA bar discipline

6/9/2015        Recorded OpHomes 2 F.Bondurant 6/4/15 quit claim

6/9/2015        3 Quit claim to Jimijack -Yuen Lee signed as T Lucas

1/13/2016      NS Lis Pendens re A-730078-C

4/1/2016        Unrecorded WF power of attorney NSM 270-272

5/9/2016        Residential Transaction Report – 2763 White Sage

6/7/2016        NS Lis Pendens re A-720032-C

9/18/2016      Tobin letter to R-J editor  “”HOAs, foreclosures, and property rights” 

12/28/2016    Corwin notary communications

1/3/2017        Debra Batesel journal entries re 6/4/15 quit claim & RPA

3/28/2017      Recorded GBH Trust quit claim 2 Tobin

3/28/2017      Recorded Hansen Disclaimer of Interest NSM 212-217

11/5/2018      Irma Mendez affidavit re Joel Just

2/5/2019        SCA MSJ against Tobin

2/5/2019        SCAMSJ Ex5-10/8/12 receipt + false claim of 9/20 notice

2/5/2019        SCAMSJ Ex12-notices with proofs of service

2/12/2019      Joinder to the SCA motion,

2/12/2019      NS Ltd joinder 2 SCA MSJ

2/20/2019      Gmail – compare NS disclosure with my paid off note

2/20/2019      Gmail – another nail in Nationstar’s coffin

2/25/2019      NS unrecorded rescinded 10/23/14 assignment-refiled NSM 404-408

2/25/2019      NS unrecorded refile of 10/23/14 as WF attorney in fact

2/27/2019      “HOA debt collectors wield an unlawful level of power”

2/27/2019      TOC 2 Tobin disclosures

2/27/2019      Tobin 1st sup + BHHS + RRFS

3/1/2019        Hearing minutes Spanish trail A-14-710161

3/1/2019        CA SOS letter re notary complaint

3/5/2019        opposition to the SCA MSJ

3/10/2019      Tobin draft DECL OPPC NS ex 1-10

3/12/2019      CA notary violations on 4/12/12 DOT 2 BANA misc docs

8/27/2008      1 Deed GBH 2 GBH Trust

3/8/2019        Recorded rescission of 10/23/14 assignment MSN 409-411

1/17/2017       Backup for notary subpoenas- not issued

                       CA notary laws

NV Attorney General’s 3/26/19 response

Recommendation to the Nevada Commision on Judicial Discipline

Postpone formal charges vs. Judge Kishner

Link to PDF of 3/10/21 email to NCJD requesting postponement of formal charges

Address the need for state civil court reform

Follow the advice of the Pew Charitable Trusts’ study:

How Debt Collectors Are Transforming the Business of State Courts

Lawsuit trends highlight need to modernize civil legal systems
Link to PDF of PEW study on debt collectors taking over state courts