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.
The Elements of fraud apply to all the defendants being named in case A-21-828840-C that were opposing counsels to Nona Tobin in Nevada district court cases related to a dispute over the title of 2763 White Sage that was sold at an HOA foreclosure sale in 2014, i.e., in cases A-21-828840-C, A-19-799890-C, A-16-73-0078-C, and A-15-720032-C.
The elements of the cause of action of Fraud on the Court:
1. Defendant makes a false representation as to a past or existing fact.
2. With knowledge or belief by defendant that representation is false or that defendant lacks sufficient basis of information to make the representation;
3. Defendant intended to induce the Court to act in reliance on the representation;
4. Justifiable reliance upon the representation by the Court;
5. Causation and damages to plaintiff Nona Tobin as a result of the Court’s relying on misrepresentation; and
6. Must be proved by clear and convincing evidence and be pled with specificity.
Relevant Nevada court cases
NEVADA JURY INSTRUCTIONS 9.01;
Jordan v. State ex rel. Dep’t of Motor Vehicles & Pub. Safety, 121 Nev. 44, 75, 110 P.3d 30, 51 (2005);
J.A. Jones Constr. Co. v. Lehrer McGovern Bovis, Inc., 120 Nev. 277, 89 P.3d 1009 (2004);
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
The defendants, jointly in concerted action and/or conspiracy, and each one separately,are utilizing this untimely, unwarranted, and harassing interpleader complaint in the corrupt attempt to moot the appeals of their non-meritorious claims in cases A-15-720032-C and A-19-799890-C.
Defendants improperly utilized this and the multiple related civil actions intended to the quiet title following a disputed 2014 HOA foreclosure. Their corrupt purpose was to get the court to bless their clients’ theft of Nona Tobin’s property, and the attorneys of those engaged in racketeering, conspired to cover it up.
Civil actions have been used to steal from Nona Tobin
Attorneys have presented false evidence, withheld evidence, falsified documents to cover up FirstService Residential dba Red Rock Financial’s predatory debt collection that led to the secret foreclosure sale.
Attorneys have presented false evidence, withheld evidence, falsified documents, to cover up Steven Scow’s, and other conspirators’ misappropriation of the proceeds o of many secretly-conducted sales.
Joseph Hong and Melanie Morgan conspired to engineer an ex parte meeting with Judge Kishner in order to derail Nona Tobin’s case.
Nationstar recording false claims to the title of the subject property to abuse the quiet title litigation process to get a court-sanctioned theft of Nona Tobin’s property.
Joseph Hong conspired with others to conceal that Jimijack’s void deed had no legal capacity to hold or transfer title.
Brittany Wood conspired with others not having an admissible deed and then fraudulently conveying it to one of the trustees as an individual.
Joseph Hong’s and Melanie Morgan’s negotiating a fraudulent deal to steal Nona Tobin’s property that was represented to the court as a Nationstar-Jimijack settlement of all claims, but was actually a contract between non-parties to the litigation.
Brittany Wood misrepresenting the court record, the facts and the law, in order to evade detection that her clients’ had knowingly received Tobin’s fraudulently conveyed property.
2. Wilfull act in the use of legal process not proper in the regular conduct of the proceeding
Steven Scow named five defendants in the interpleader complaint when he knew that four of those defendants had already recorded releases of their claims.
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.
I, Nona Tobin under penalty of perjury, states as follows: I have personal knowledge of the facts stated herein, except for those facts stated to be upon information and belief. If called to do so, I would truthfully and competently testify to the facts stated herein, except those facts stated to be based upon information and belief. I make this declaration in support of a third-party complaint in case A-21-828840-C.
Upon information and belief, Melanie Morgan conspired with Joseph Hong to make a covert deal, characterized it fraudulently as a Nationstar-Jimijack agreement that settled all parties’ claims in order to steal 2763 White Sage from me without adjudication. See 4/23/19 transcript, 4/25/19 transcript, and 5/21/19 transcript.
See 5/23/19 AGREE annotated recorded document (instrument number 201905230003531) that was allegedly the Jimijack-Nationstar deal but was actually a $355,000 payment to Joel Stokes by Civic Finacial Services, masquerading as a deed of trust securing a property no court had ruled Joel Stokes owned.
Melanie Morgan conspired with Joseph Hong to serve notice that the 4/23/19 hearing on Nationstar’s motion for summary judgment vs. Jimijack was continued to 5/7/19, but Hong and Morgan somehow knew to go to the “hearing” anyway to make egregious misrepresentations of the facts, my standing as an individual party and the law to the Judge Kishner. Their duplicity was successful. My pro se motions for summary judgment against Jimijack, and against Nationstar and other cross-defendants were stricken unheard. See 4/23/19 minutes, transcript and VIDEO. See 963-page EX PARTE STRICKEN exhibit of the unduplicated motions, oppositions and documentary evidence that was stricken by bench order at the 4/23/19 ex parte hearing allegedly because I filed them as a pro se before my attorney had filed a motion to withdraw, but actually because Judge Kishner acted on Melanie Morgan’s and Joseph Hong’s lies.
Upon information and belief, Melanie Morgan and other attorneys from Akerman and Wright Finley Zak filed multiple documents that included the false claim that Nationstar was the beneficial owner of the disputed Hansen deed of trust and had authority without any basis in fact or law to release the lien of the Hansen deed of trust on 6/3/19, two days before trial, substitute trustee and reconvey the property to Joel Stokes rather than to the estate of the deceased borrower. See 6/3/19 annotated SUB/RECONVEY that was recorded as instrument 201906030001599. See NSM 001-063 RECORDED FRAUD exhibit.
Melanie Morgan and/or Donna Wittig, of Akerman LLP for Nationstar Mortgage LLC and/or dba Mr. Cooper conspired with, and/or acted in concert with, Joseph Hong for Joel A. Stokes, Joel & Sandra Stokes as trustees for Jimijack Irrevocable Trust, and Jimijack Irrevocable Trust; Brittany Wood of Maurice Wood for Brian and Debora Chiesi and (maybe) for Quicken Loans LLC and/or Inc.; and with David Ochoa of Lipson Neilson for Sun City Anthem and/or with Brody Wight and/or Steven Scow for Red Rock Financial Services, a partnership (EIN 88-058132) for, upon information and belief, the corrupt purpose of uniformly concealing and misrepresenting material facts to the court in the same manner.
Their actions to gang up on me resulted in the obstruction of any possible fair adjudication of my claims and have prevented ANY judicial scrutiny of the evidence I possess that would be fatal to their clients’ cases.
Akerman Attorneys know, or have access to information that they reasonably should know, that Nationstar’s false and conflicting filed and recorded claims judicially estopped Nationstar from claiming to own now, or to ever have owned, the disputed Hansen deed of trust. See 1/11/16 complaint, 6/2/16 AACC counter-claim vs. Jimijack, 12/1/14 recorded claim, 3/8/19 recission of the 12/1/14 claim, 3/8/19 assignment, 2/28/19 response to #7 interrogatory, 6/3/19 reconveyance.
Upon information and belief, Steven Scow has conspired with attorneys from Akerman LLP, Wright, Finley, Zak LLP to conceal Nationstar’s criminal acts of recording false claims to title (NRS 205.377, NRS 207.360) while they conealed Red rock’s rejection of SCA 302, and support them in their fraudulent claims with the quid pro quo being that Koch & Scow gets to keep more of the undistributed proceeds for keeping the devil’s bargain with Nationstar and other lenders. “210116 We can learn a lot from this Spanish Trail HOA case”
Akerman attorneys know that the disclosures served into A-15-720032-C contain false evidence and that the responses to my interrogatories and requests for documents were duplicitous.
Akerman attorneys know that Nationstar was not complaint with NRS 38.310 and therefore Judge Kishner did not have jurisdiction pursuant to NRS 38.310(2) to provide either Akerman’s or Hong’s clients their requested relief, but Melanie Morgan pursuaded Judge Kishner that she had to strike my 4/9/19 NTOC notice of completion of mediation from the record unheard since I was the only one, in both my capacities to complete mediation.
Judge Kishner persisted in the delusion that I wasn’t a party and so she refused to hear my 7/26/19 NOTC.
Brody Wight knowingly filed a motion to dismiss that was not supported by facts or law to cover up the crimes of his law firm and its clients.
Akerman and Wright Finley Zak attorneys know that Red Rock Financial Services conducted an unfair, unnoticed and fraudulent sale and provided false evidence (RRFS 001-425) that was further falsified by Sun City Anthem attorneys David Ochoa and/or Adam Clarkson and/or John Aylor in SCA 176-643) to cover it up.
All attorneys for Nationstar, for Sun City Anthem, Red Rock Financial Services, and their financially-conflicted errors & omissions insurance policy carrier, concealed or withheld documents , falsified evidence, filed court documents rife with deception, for the corrupt purpose of evading detection of the true facts of how the disputed HOA sale was conducted, where the money came from and where the money went. See A-19-799890-C complaint that was dismissed unheard by Judge Susan Johnson of the grounds of res judicata by 12/3/20 order of dismissal with prejudice. See “TOC TOBIN 4 APPEALS 12-pages” to understand how successful their conspiracy has been in obstructing ALL judicial scrutiny of the evidence
Akerman and Wright Finley Zak attorneys for Nationstar know that Nationstar negotiator Veronica Duran’s 5/28/14 Equator message to Craig Leidy saying she was authorized to offer $1100 to the HOA to close the 5/14/14 www.auction.com $367,500 sale to MZK Properties was disclosed as (SCA 302) but did not acknowledge it.
Melanie Morgan, and the other Akerman attorneys, knew that the Equator records that they refused to provide in discovery, and that Forrest Barbee, Berkshire Hathaway broker under contract with me from 2/20/14 to 10/31/14, helped them conceal, would have been additional proof that in 2014 servicing bank Nationstar refused to identify the beneficiary, refused to close escrow on the 5/8/14 auction.com sale to MZK properties.
Melanie Morgan, and the other Akerman attorneys, knew that Nationstar didn’t begin lying about being owed the $389,000 balance on the Hansen deed of trust until 12/1/14, over three months after the sale, and that if the HOA sale was valid to extinguish the interest of the estate of the deceased borrower, that it also extinguished the deed of trust. Nevertheless, she persisted in fabricating standing for Nationstar that did not exist in fact or in law.
Akerman and Wright Finley Zak attorneys concealed all of the Equator records and other mortgage-servicing and broker files to which I am entitled and which I requested in discovery that would have shown the exact nature of Nationstar’s agents, employees, and/or attorneys’ communications with Red Rock about the HOA sale, and how the $1100 Nationstar offer was rejected. (2/21/19 RESP to RFDs) See also NSM’s 2/21/19 RESP 2 ROGs.
Akerman and Wright Finley Zak attorneys concealed the $1100 offer from Nationstar rejected by Red Rock and mysteriously never claimed it as a justification for voiding the sale.
Akerman and Wright Finley Zak attorneys knowingly and repeatedly made the false claim that Red Rock’s 5/9/13 covert rejection of $825 tendered by Bank of America’s attorney, Rock K. Jung, then an attorney with Miles, Bauer, Bergstrom & Winters, LLP, but currently with Wright, Finley, Zak, LLP, was grounds for voiding the sale only insofar as protecting the security interest Nationstar was pretending to own, but was not grounds for protecting the ownership interest of the deceased borrower. See
SCA attorney Ochoa claimed in his 8/9/19 AFFD for attorney fees (page 35 of 53) that he prepared RFDs, ROGs, and RFAs for NSM on 8/8/18, but no SCA to NSM RFDs, ROGs, or RFAs were served on the parties, and no NSM RESP to SCA ROGs, RFDs, or RFAs were ever served through the NVefile system.
SCA concealed in discovery the requested board minutes where the HOA sale was approved, because there are no minutes of any meeting at which the sale was approved. SCA lied about the minutes being contained in SCA 644-654 in its 2/26/19 RESP to RFDs (page 7, response 7), line 10). See also 2/28/19 RESP ROGs
SCA 315 claims that the sale was approved as item R-05-120513 at the 12/5/13 HOA Board meeting is false and deliberately deceptive.
I declare under penalty of perjury under the laws of the State of Nevada that the foregoing is true and correct.
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.
NRS 111.180Bona 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.
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.
4/23/19 bench orders were not formalized until 11/22/19 order was entered five months after the trial I was excluded from:
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
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
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
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
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
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 205.345, 205.350 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)
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.
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.
Hong repeatedly violated his duty of candor to the court by concealing material facts, most notably that his client didn’t have an admissible deed and the alleged settlement was not between any parties;,
Hong made many false statements in his pleadings, motions, oppositions and oral arguments in order to cheat to win;
Hong served notice that the 4/23/19 hearing was continued to 5/7/19 and then conspired with Melanie Morgan to meet ex parte on 4/23/19 with Judge Kishner anyway;
Relying on Hong’s and Morgan’s misrepresentations, Judge Kishner bench ordered many of Nona Tobin’s pro se filings and 963 pages of her evidence stricken from the record unheard, including meritorious motions for summary judgment vs. Hong’s and Morgan’s clients
Completely through the misconduct of Hong and his co-conspirators, ALL of Nona Tobin’s evidence entered into the court record since 7/29/16 has been suppressed.
Completely through the misconduct of Hong and his co-conspirators, NO Nevada judge in ANY of these four district court cases (A-15-720032-C, A-16-730078-C, A-19-799890-C, A-21-828840-C) or these four Nevada Supreme Court cases (79295, 82094, 82234, 82294), has looked at the evidence.
Hong and his co-conspirators obstructed a fair adjudication of Nona Tobin’s claims by an impartial tribunal,
Hong and his co-conspirators made a fraudulent side deal to steal Nona Tobin’s $500,000 house, $100,000+ in 6+ years of lost rent, and over $100,000 in other actual damages to Nona Tobin.
ABA Standard 6.1 (False statements, fraud, and misrepresentation) and 6.11 Disparment is appropriate when:
Hong , with the intent to deceive the court, made many false statements, submitted false documents, improperly withheld material information, caused serious injury to Nona Tobin and had a serious impact n multiple legal proceedings.
Hong caused serious injury to Nona Tobin, lied to the court repeatedly to steal Nona Tobin’s house and cover his tracks. The specific dates and documentary evidence will be published by 3/21/21.
Disbarment is appropriate. The specific dates and documentary evidence will be published by 3/21/21.
6.2 (Abuse of the Legal Process),
ABA Standard 6.21 Disbarment for violating a court rule to seriously interfere with a legal proceeding
ABA Standard 6.3 Improper Communications with Individuals in the Legal System
6.31 Disbarment is generally appropriate when
8.0 (Prior discipline Orders),
8.1(b) (Disbarment is generally appropriate when a lawyer