Black letter Nevada law: Statute of Frauds

NRS Chapter 111 Conveyances; Statute of Frauds

NRS 111.105  Conveyances by deed.  

Conveyances of lands, or of any estate or interest therein, may be made by deed, signed by the person from whom the estate or interest is intended to pass, being of lawful age, or by the person’s lawful agent or attorney, and acknowledged or proved, and recorded, as directed in this chapter.

NRS 111.120
NRS 111.120  Conditions necessary before proof by subscribing witness can be taken.  

No proof by a subscribing witness shall be taken unless the witness shall be personally known to the person taking the proof to be the person whose name is subscribed to the conveyance as witness thereto, or shall be proved to be such by the oath or affirmation of a credible witness.

NRS 111.120
NRS 111.125 Proof required from subscribing witnesses. 

No certificate of proof shall be granted unless subscribing witnesses shall prove: 1. That the person whose name is subscribed thereto as a party is the person described in, and who executed the same. 2. That such person executed the conveyance. 3. That such witness subscribed his name thereto as a witness thereof.

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.

NRS 111.175
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.

NRS 111.180
NRS 111.240  Acknowledgment of conveyances.  

Every conveyance in writing whereby any real property is conveyed or may be affected must be acknowledged or proved and certified in the manner provided in this chapter and in NRS 240.161 to 240.169, inclusive.

NRS 111.240
NRS 111.320  Filing of conveyances or other instruments is notice to all persons: Effect on subsequent purchasers and mortgagees.  

Every such conveyance or instrument of writing, acknowledged or proved and certified, and recorded in the manner prescribed in this chapter or in NRS 105.010 to 105.080, inclusive, must from the time of filing the same with the Secretary of State or recorder for record, impart notice to all persons of the contents thereof; and subsequent purchasers and mortgagees shall be deemed to purchase and take with notice.

NRS 111.320
 NRS 111.325  Unrecorded conveyances void as against subsequent bona fide purchaser for value when conveyance recorded.  

Every conveyance of real property within this State hereafter made, which shall not be recorded as provided in this chapter, shall be void as against any subsequent purchaser, in good faith and for a valuable consideration, of the same real property, or any portion thereof, where his or her own conveyance shall be first duly recorded.

NRS 111.325
NRS 111.340  Certificate of acknowledgment and record may be rebutted.  

Neither the certificate of the acknowledgment nor of the proof of any conveyance or instrument, nor the record, nor the transcript of the record, of such conveyance or instrument, shall be conclusive, but the same may be rebutted.

NRS 111.340
 NRS 111.345  Proof taken upon oath of incompetent witness: Instrument not admissible until established by competent proof.  

If the party contesting the proof of any conveyance or instrument shall make it appear that any such proof was taken upon the oath of an incompetent witness, neither such conveyance or instrument, nor the record thereof, shall be received in evidence, until established by other competent proof.

NRS 111.345

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.

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

Complaint to the State Bar of Nevada Ethics & Discipline Panel vs. Brittany Wood

Immediate rejection without consideration

NV Bar Receipts of online complaints

2/14/21 complaint vs. Joseph Hong (Reference OBC21-0181)
2/16/21 complaint vs. Brittany Wood (Reference OBC21-0187)

“WHY DID QUICKEN SECURE A LOAN WITH A HOUSE THAT WAS ALREADY MORTGAGED?

“PLEASE, JUDGE JOHNSON, WON’T YOU AT LEAST LOOK AT THE EVIDENCE?”

How lenders cheat owners out of their houses

Is justice blind or just blinded by power and pals?”

NONA TOBIN’S 3/15/21 REQUEST FOR JUDICIAL NOTICE

LINK TO PDF OF 3/15/21 FILED RFJN
Exhibits 1-13 are all recorded claims recorded from 2003 to the present, organized by instrument number and year:
  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

EXHIBIT 1 2003

200307310004442DEED/ HANSEN, H & W DISCLOSED AS NSM 113-116
200307310004443POWER OF ATTORNEY/ HANSEN DISCLOSED AS NSM 117-120 NOTABLE BECAUSE IT IS THE ONLY POWER OF ATTORNEY IN THE WHOLE RECORD
200307310004444DEED OF TRUST/ $310,600 CITY 1ST MORT TO
HANSEN, H & W
200309100000588DEED OF TRUST/ 7/31/03 ASSIGN
200311200004030DEED OF TRUST/ WF 2ND $55K

EXHIBIT 2 2004

200406110005547 DEED/ DIVORCE TO G HANSEN DISCLOSED AS NSM 141-144

200407220003507 DEED OF TRUST/ G HANSEN $436K WESTERN THRIFT DISCLOSED AS NSM 145-161

NSM 160 IS THE PUD RIDER REMEDIES SECTION F. THAT PROHIBITS LENDERS FROM TRANSFORMING THE PAYMENT OF DELINQUENT HOA DUES INTO A DE FACTO FORECLOSURE WITHOUT DUE PROCESS.

200408170002284 RECONVEYANCE/ 11/20/03 WF 2 G HANSEN

200408310007563 SUBSTITUTION/ RECONVEYANCE 7/31/03 $310,600 PIF

200409010007297 HOMESTEAD/ G HANSEN DISCLOSED AS NSM 162

EXHIBIT 3 2007

200705100001127DEED OF TRUST/ 5/10/07 2ND OPEN-ENDED DOT $31,600 TO G HANSEN.

THIS WAS WELLS FARGO’S ONLY RECORDED LIEN RELATED TO GORDON B. HANSEN, AN UNMARRIED MAN.

NOT DISCLOSED BY NATIONSTAR OR BY RED ROCK FINANCIAL SERVICES.

EXHIBIT 4 2008

200808270003627DEED/ 8/27/08 GORDON HANSEN TO GORDON B HANSEN TRUST, DATED 8/22/08.

GORDON B. HANSEN WAS THE TRUSTEE UNTIL HIS DEATH ON 1/14/12 AT WHICH TIME

NONA TOBIN BECAME THE SOLE SUCCESSOR TRUSTEE, & WAS A 50% CO-BENEFICIARY WITH STEVE HANSEN
UNTIL STEVE DISCLAIMED HIS INTEREST ON 3/27/17.

EXHIBIT 5 2012

201212140001338LIEN/ RED ROCK RECORDED ON 12/14/12
RED ROCK UNAUTHORIZED DEMAND FOR $925.76.

DISCLOSED AS NSM 169

DISPUTED BECAUSE
LIEN WAS RECORDED WITH NO NOTICE
WHEN ONLY $275 ASSESSMENTS FOR 10/1/12-12/31/12 WERE DELINQUENT.

ONLY A $25 LATE FEE WAS AUTHORIZED.
RED ROCK ADDED $625.76 UNEARNED, UNLAWFUL FEES.

LIEN WAS PREDATORY.
PROPERTY WAS IN SPARKMAN ESCROW FROM 8/10/12.

TICOR TITLE HAD INSTRUCTIONS TO PAY THE HOA IN FULL AT CLOSE OF ESCROW.

SEE RRFS 401 P/O REQUEST RED ROCK RECEIVED ONE DAY BEFORE LIEN WAS RECORD.

EXHIBIT 6 2013

201303120000847HOA 3/12/13 NOTICE OF $2,475.35 DEFAULT

DISCLOSED AS NSM 170.

DISPUTED BECAUSE DEFAULT NOTICE
1. INACCURATELY DESCRIBES THE DEFAULT;
2. THE AMOUNT OWED IS WRONG;
3. THERE WERE PAYMENTS AFTER 7/1/12
(SEE RRFS 402 AND SCA 618), AND
4. 3/12/13 NOTICE OF DEFAULT WAS RESCINDED AND SO IT HAD NO LEGAL EXISTENCE;
5. RED ROCK RECITED THE RESCINDED NOTICE OF DEFAULT ON THE 8/22/14 FORECLOSURE DEED.
2013040300015694/3/13 RESCISSION HOA 3/12/13 NOTICE OF $2,475.35 DEFAULT

DISCLOSED AS NSM 171.

DISPUTED BECAUSE RED ROCK CHARGED UNAUTHORIZED FEES FOR RECORDING AND RESCINDING THE 3/12/13 NOTICE OF DEFAULT BASED ON ITS OWN ERRORS.

SEE SCA 415-416 ANNOTATED AND RRFS 218-219
201304080001087HOA 4/8/13 NOTICE OF $2,752.66 DEFAULT

DISCLOSED AS NSM 172

HOA 4/8/13 NOTICE OF DEFAULT
DISPUTED BECAUSE:
1. IT INACCURATELY DESCRIBES THE DEFAULT;
2. THE AMOUNT IS WRONG;
3. THERE WERE PAYMENTS AFTER 7/1/12;
(SEE RRFS 402 AND SCA 618);
4. THE 8/22/14 FORECLOSURE DEED DID NOT RECITE IT;
5. RED ROCK KNEW NO COLLECTION ACTION WAS NECESSARY BECAUSE IT WAS IN ESCROW.
6. RED ROCK COVERTLY REJECTED THE BANK’S TENDER OF $825 WHEN $825 OF ASSESSMENTS WERE DELINQUENT.

RED ROCK HAD RESPONDED TO TWO REQUESTS FOR PAY OFF FIGURES FROM TICOR TITLE, 12/13/12 (THE DAY BEFORE RED ROCK RECORDED THE RIDICULOUS LIEN & ON 1/13/16, A WEEK AFTER RED ROCK NOTIFIED THE OWNER ON 1/3/13 THAT A LIEN HAD BEEN RECORDED ON 12/14/12..

SEE RRFS 401 P/O REQUEST RED ROCK RECEIVED ONE DAY BEFORE LIEN WAS RECORD.

SEE RRFS 369-375 1/16/13 PAY OFF DEMAND TO TICOR TITLE FOR $1,451.75.

TICOR TITLE HAD INSTRUCTIONS TO PAY THE HOA IN FULL AT CLOSE OF ESCROW.

4/8/13 RED ROCK RECEIVED PAY-OFF REQUEST FROM MILES BAUER, BANK OF AMERICA’S (BANA’S) AGENT,

SEE RRFS 367-368 RED ROCK’S 2/5/13 “COURTESY NOTICE” TO OWNER THAT DOES NOT SPECIFY WHAT IS OWED, JUST THREATENS TO ADD $825 TO THE UNKNOWN BALANCE IF RED ROCK IS NOT PAID WHATEVER IT DEMANDS IN 10 DAYS.

BY 4/8/13. RED ROCK COVERTLY REJECTED BANA’S AGENT’S 5/8/13 CHECK FOR $825
SEE RRFS 312-326 FOR MILES BAUER PAY OFF REQUEST.

$825 WAS DUE AND OWING FOR THE NINE MONTHS OF ASSESSMENTS DUE FOR 10/1/12-6/30/13 QUARTERS.
SCA 415

RED ROCK RESPONDED TO A THIRD TICOR TITLE REQUEST FOR PAY OFF FIGURES ON 5/29/13.
SEE RRFS 305-311 FOR RED ROCK’S DEMAND FOR $3,055.47 .


ON 6/4/13, TICOR TITLE ESCROW PREPARED A HUD-1 TO PAY THE HOA $3,055.47 AS RED ROCK DEMANDED.
SEE HUD-1 LINE 1309, PAGE 2

BANK OF AMERICACOMMITTED MORTGAGE SERVICING FRAUD WHEN IT REJECTED THE MAZZEO’S $395,000 OFFER THAT WOULD HAVE ET THE HOA / RED ROCK BE PAID $3,055.47 AT CLOSE OF ESCROW AFTER BANK OF AMERICA’S AGENT COVERTLY TENDERED $825 TO RED ROCK TO CIRCUMVENT THE PUD RIDER IN ORDER TO SCREW THE OWNER OUT OF HER PROPERTY.

SINCE THE BANK WOULDN’T ALLOW THE PROPERTY TO BE SOLD AT FAIR MARKET VALUE, THE HOA DID NOT GET ANY OF THE $3,055.47 RED ROCK DEMANDED ON 5/29/13.

SINCE RED ROCK COVERTLY REJECTED BANA’S 5/8/13 COVERT TENDER OF $825, THE EXISTING ACTUAL DEFAULT OF $825 WAS UNFAIRLY NOT CURED, AND RED ROCK CONTINUED TO ADD FEES TO CREATE A DEFAULT THAT DID NOT EXIST.
201309230001369LIEN $264.49 REPUBLIC SERVICES

DISCLOSED AS RRFS 185.

RED ROCK CONCEALED THE 3/30/17 LIEN RELEASE.

EXHIBIT 7 2014

201402120001527NOTICE OF 3/7/14 HOA SALE $5,081.45 DEMANDED AS OF 2/11/14 DISCLOSED AS NSM 173-174 DISPUTED BECAUSE THE 3/7/14 SALE WAS CANCELLED AT BECAUSE NONA TOBIN HAD ON 3/4/14 ACCEPTED A $340,000 CASH OFFER. ON 3/28/14, RED ROCK RESPONDED TO A 3/18/14 REQUEST FOR PAYOFF FIGURES FROM CHCAGO TITLE, BUT CONCEALED THEIR 3/28/14 DEMAND FOR $4,962.64 AND CONCEALED THE 3/6/14 PRELIMINARY TITLE REPORT. ON 4/18/14, NATIONSTAR REJECTED THE $340,000 CASH OFFER AND REQUIRED THE PROPERTY BE POSTED ON AUCTION.COM FROM 5/4/14-5/8/14. ON 5/8/14, NONA TOBIN ACCEPTED THE $367,500 HIGH BID BY MZK PROPERTIES, LLC. ON 6/2/14, THE NRED OMBUDSMAN STAFF RECORDED THAT ON 5/15/14 THE OMBUDSMAN RECEIVED NOTICE THAT THE 2/12/14 NOTICE OF SALE WAS CANCELLED AND THE 5/15/14 TRUSTEE SALE WAS CANCELLED AND “THE OWNER RETAINED” RED ROCK PRODUCED (SCA 302 AND RRFS )AN EQUATOR MESSAGE
201405060004357LIEN $253.50 REPUBLIC SERVICES

DISCLOSED AS RRFS 070
201408220002548DEED HOA FORECLOSURE TO OPPORTUNTY HOMES LLC

DISCLOSED AS NSM 175-177

$63,100 SALE PRICE
AFTER NATIONSTAR REJECTED
$340,000 CASH OFFER SIGNED BY NONA TOBIN ON 3/4/14 AND

NATIONSTAR REJECTED $367,500 AUCTION.COM HIGH BID ACCEPTED BY TOBIN ON 5/8/14

NATIONSTAR IGNORED NONA TOBIN ‘S HAVING A $358,800 OFFER IN HAND PENDING LENDER APPROVAL SINCE 7/26/14.

NATIONSTAR FRAUDULENTLY ASSERTED
IN ITS 2/12/19 LIMITED JOINDER AND
ITS 3/21/19 MOTION FOR SUMMARY JUDGMENT VS. JIMIJACK THAT THE HOA SALE WAS
VOID, AS TO NATIONSTAR’S SECURITY INSTRUMENT (7/22/04 HANSEN DEED OF TRUST),
DUE TO RED ROCK’S COVERT REJECTION OF THE 5/9/13 $825 MILES BAUER TENDER, EVEN THOUGH
NATIONSTAR WAS NOT BANK OF AMERICA’S SUCCESSOR IN INTEREST.

NATIONSTAR IGNORED NSM 160, PUD RIDER REMEDIES CONTRACT PROVISION,
TO FRAUDULENTLY CLAIM THAT
THE SALE WAS VALID TO EXTINGUISH THE OWNER’S TITLE  RIGHTS.

NATIONSTAR CONCEALED IN DISCOVERY (SCA 302 AND RRFS 119) THAT WAS A 5/28/14 EQUATOR MESSAGE FROM NATIONSTAR TO CRAIG LEIDY OFFERING $1,100 TO CLOSE THE 5/8/14 AUCTION.COM ESCROW.

KOCH & SCOW AND SCA PRODUCED FALSIFIED DOCUMENTS THAT SHOWED THEIR CONSPIRACY TO CONCEAL RED ROCK’S FRAUDULENT MISREPRESENTATION OF THE 5/28/14 OFFER.
SEE SCA 277 ANNOTATED AND RRFS 095.


MORE OF RED ROCK’S FALSIFICATION OF THE RECORD WILL BE PRODUCED IN A SEPARATE REQUEST FOR JUDICIAL NOTICE TO SUPPORT THE MOTION FOR SANCTIONS AGAINST COUNTER-DEFENDANT  RED ROCK, AGAINST CROSS-DEFENDANT NATIONSTAR, AND AGAINST THIRD PARTIES TO BE NAMED IN THIRD PARTY COMPLAINTS TO BE FILED BY 3/19/21 INTO CASE A-21-82840-C.
201409090000974DEED OF TRUST 9/9/14 ASSIGN OF
7/22/04 HANSEN DOT FROM BANA 2 WELLS FARGO
BY BANA

DISCLOSED AS NSM 178-179
SO NATIONSTAR KNEW BANA HAD NO INTEREST IN THE 7/22/04 DOT TO ASSIGN AFTER 9/9/14.
201412010000518DEED OF TRUST 12/1/14 ASSIGNMENT OF THE
7/22/04 HANSEN DEED OF TRUST
FROM BANA 2 NATIONSTAR
BY NATIONSTAR.  

DISCLOSED AS NSM 180-181
EVEN THOUGH IT IS OBVIOUS FROM NSM 178-179 THAT NATIONSTAR KNEW THAT BANA HAD NO INTEREST TO ASSIGN TO NATIONSTAR AFTER 9/9/14.

NATIONSTAR KNEW IT WAS CAUGHT RECORDING FALSE CLAIMS TO TITLE DURING DISCOVERY BY THE LACK OF CANDOR IN NATIONSTAR’S RESPONSES TO TOBIN’S  INTERROGATORIES AND REQUESTS FOR PRODUCTION.

ON 3/8/19, NATIONSTAR RESCINDED THIS BOGUS ASSIGNMENT,
REMOVING ANY POSSIBLE CLAIM THAT NATIONSTAR WAS THE SUCCESSOR IN INTEREST TO BANA AS THE BENEFICIARY OF THE 7/22/04 HANSEN DEED OF TRUST.  

NEVERTHELESS, ON 6/3/19, NATIONSTAR FRAUDULENTLY RECONVEYED
THE 7/22/04 HANSEN DEED OF TRUST
TO JOEL STOKES, NOT TO NONA TOBIN,
AS PART OF THE NATIONSTAR’S AND STOKES’ SCHEME TO DEFRAUD THE COURT INTO APPROVING THE STEALING OF THE PROPERTY FROM THE  ESTATE OF THE DECEASED BORROWER.

EXHIBIT 8 2015

201501220001850REQUEST FOR NOTICE OF LIENS OR NS 116 OR NRS 107 DEFAULTS BY NATIONSTAR DISCLOSED AS NSM 182
201502230000608RPTT 2/23/15 REFUND TO THOMAS LUCAS “PROOF OF NOTIFICATION OF HOA FORECLOSURE PROVIDED” DISCLOSED AS NSM 183-185 THIS IS SIGNIFICANT BECAUSE THOMAS LUCAS COULDN’T PROVIDE PROOF OF NOTICE OF A FORECLOSURE SALE ON 8/22//14 WHEN HE RECORDED THE FORECLOSURE DEED. WHAT PROOF LUCAS PRODUCED TO GET A TAX REFUND WAS CONCEALED BY ALL PARTIES IN DISCOVERY. RED ROCK DID NOT PUBLISH ANY NOTICE OF THE 8/15/14 FORECLOSURE SALE.
201503120002285SUBSTITUTION/ 3/12/15 RECONVEYANCE OF WELLS FARGO 5/10/07 2ND HANSEN $31,600 OPEN ENDED DOT CONCEALED BY NATIONSTAR AND RED ROCK.
201506090001537DEED 6/9/15 JIMIJACK DEED IS VOID PER NRS 111.345 DISCLOSED AS NSM 186-188 SO IT IS INEXPLICABLE WHY NATIONSTAR DID NOT NAME JIMIJACK AS A DEFENDANT WHEN IT FILED ITS 1/11/16 QUIET TITLE COMPLAINT VS. OPPORTUNITY HOMES LLC WHO HAD NO RECORDED CLAIM TO PROTECT VS. JIMIJACK OR F. BONDURANT LLC
201506090001545DEED OP HOMES TO F. BONDURANT LLC FOR $1.00 DISCLOSED AS NSM 189-191 NATIONSTAR DID NOT NAME F. BONDURANT LLC AS A DEFENDANT WHEN IT FILED ITS 1/11/16 QUIET TITLE COMPLAINT VS. OPPORTUNITY HOMES
201508170001056SUBSTITUTION/ TRUSTEE ON 7/22/04 HANSEN DOT FROM ORIGINAL 7/22/04 TRUSTEE JOAN H ANDERSON TO AMER EE SERVICING SOLUTIONS
BY NATIONSTAR WITH NO POWER OF ATTORNEY.

DISCLOSED AS NSM  192-194

ON 6/3/19 NATIONSTAR IGNORED THIS 8/17/15 CHANGE OF TRUSTEE
WHEN MR. COOPER SUBSTITUTED TRUSTEE JOAN H. ANDERSON A SECOND TIME
TO CLAIM THAT MR. COOPER WAS THE TRUSTEE
AND THE BENEFICIARY
OF THE 7/22/04 HANSEN DEED OF TRUST
WITH THE POWER TO RECONVEY THE PROPERTY
TO JOEL STOKES INSTEAD OF TO THE HANSEN ESTATE.
20151201000340212/1/15 JUDGMENT/ 10/23/15 BANA DEFAULT

ON 12/1/15 JOSEPH HONG RECORDED THE 10/23/15 ORDER OF DEFAULT FOR WHICH
NO NOTICE OF ENTRY OF ORDER  WAS EVER FILED.

BANA DEFAULTED BECAUSE BANA HAD NO RECORDED INTEREST AFTER 9/9/14.

ON 6/16/15 JOSEPH HONG SUED BANA,
BUT DID NOT FILE ANY CLAIMS VS. WELLS FARGO
THAT HAD BANA’S RECORDED INTEREST AS OF 9/9/14.

ON 6/16/15 JOSEPH HONG DID NOT NAME NATIONSTAR AS A DEFENDANT DESPITE ITS 12/1/14 RECORDED CLAIM.

NRS 40.110 PROHIBITS A COURT FROM ENTERING A JUDGMENT BY DEFAULT FOR QUIET TITLE.

JOSEPH HONG NEVER FILED ANY CLAIMS VS. NATIONSTAR, FOR QUIET TITLE
AT ANY TIME BETWEEN 2015 AND THE PRESENT
ON BEHALF OF ANY OF HIS CLIENTS.

JOSEPH HONG NEVER REFUTED WITH EVIDENCE
ANY CLAIMS FILED AGAINST ANY OF HIS CLIENTS.

HONG FRAUDULENTLY CONVINCED THE COURT THAT HIS CLIENT, NON-PARTY JOEL STOKES’ BOGUS OUT OF COURT “SETTLEMENT” OF NON-EXISTENT CLAIMS AGAINST NATIONSTAR QUALIFIED AS A SETTLEMENT OF NONA TOBIN’S QUIET TITLE CLAIMS.

EXHIBIT 9 2016

201601130001051LIS PENDENS 1/13/16 RE A-16-730078-C BY NATIONSTAR
201605230001416CERTIFICATE OF INCUMBENCY NONA TOBIN AS SUCCESSOR TRUSTEE OF HANSEN TRUST
201605230001417REQUEST FOR NOTICE “OF ANY LIEN, SALE, TRANSFER, DEFAULT OR ANY OTHER ACTION AFFECTING THIS PROPERTY” BY NONA TOBIN
201606070001450LIS PENDENS 6/7/16 RE A-15-720032-C BY NATIONSTAR

EXHIBIT 10 2017

201703280001452DEED 3/28/17 HANSEN TRUST TO NONA TOBIN, AN INDIVIDUAL, PAGES 2 AND 4 REFERENCE THE CLOSURE OF THE HANSEN TRUST, WHEN ITS SOLE ASSET WAS TRANSFERRED TO THE SOLE BENEFICIARY. DISCLOSED AS NSM 208-211
2017033000038593/30/17 LIEN/ RELEASE 9/23/13 REPUBLIC SERVICES. NOT INCUDED IN THE RED ROCK FORECLOSURE FILE PRODUCED BY KOCH & SCOW IN RESPONSE TO NONA TOBIN’S 2/4/19 SUBPOENA.
2017033000038603/30/17 LIEN/ RELEASE 5/6/14 REPUBLIC SERVICES . NOT INCUDED IN THE RED ROCK FORECLOSURE FILE PRODUCED BY KOCH & SCOW IN RESPONSE TO NONA TOBIN’S 2/4/19 SUBPOENA.
201703310003071INTEREST DISCLAIMER OF STEVE HANSEN, FILED INTO A-15-720032-C ON 3/28/17, WHICH LEFT NONA TOBIN, AN INDIVIDUAL, AS THE SOLE MEMBER AND BENEFICARY OF THE GORDON B. HANSEN TRUST DISCLOSED AS NSM
201703310003072INTEREST DISCLAIMER OF THOMAS LUCAS & OPPORTUNITY HOMES LLC DISCLOSED AS NSM
201703310003073INTEREST DISCLAIMER YUEN K. LEE & F. BONDURANT LLC DISCLOSED AS NSM

EXHIBIT 11 2019

201903080002789DEED OF TRUST/ 3/8/19 RESCISSION OF 12/1/14 ASSIGNMENT OF 7/22/04 HANSEN DOT FROM BANA TO NATIONSTAR BY NATIONSTAR DISCLOSED AS NSM 409-411 ON 3/12/19, TWO WEEKS AFTER THE END OF DISCOVER.
201903080002790DEED OF TRUST/ 3/8/19 ASSIGNMENT OF 7/22/04 HANSEN DOT FROM WELLS FARGO TO NATIONSTAR BY NATIONSTAR FROM BANA TO NATIONSTAR BY NATIONSTAR DISCLOSED AS NSM 412-413 ON 3/12/19, TWO WEEKS AFTER THE END OF DISCOVER.
201905010003348DEED VOID 5/1/19 TRANSFER OF JIMIJACK’S VOID 6/9/15 DEED TO JOEL A. STOKES, AN INDIVIDUAL, BY JOEL & SANDRA STOKES AS TRUSTEES OF JIMIJACK IRREVOCABLE TRUST
201905060001022LIS PENDENS 5/6/19 4/30/19 NOLP RE A-720032C BY NONA TOBIN AN INDIVIDUAL & AS TRUSTEE OF GORDON HANSEN TRUST, DATED 8/22/08
201905230003531DEED OF TRUST/ AGREEMENT WITHOUT PARTIES JIMIJACK OR NATIONSTAR AS SIGNERS 5/23/19 $355,000 CIVIC FINANCIAL SERVICES LOAN TO JOEL A. STOKES, AN INDIVIDUAL
201905280002843LIS PENDENS/ ROLP 5/28/19 JOEL & SANDRA STOKES RELEASED NATIONSTAR’S 6/7/16 LIS PENDENS AS IF THEY OWNED IT
201906030001599SUBSTITUTION/ 6/3/19 RECONVEYANCE OF 7/22/19 HANSEN DOT TO JOEL A STOKES BY NATIONSTAR DID NOT RECONVEY TO THE ESTATE OF THE BORROWER
201906040000772DEED OF TRUST 6/4/19 ASSIGNMENT OF JOEL STOKES 5/23/19 DOT CIVIC FINANCIAL SERVICES TO HMC ASSETS.
201907100002352LIS PENDENS/ 7/ROLP RELEASE OF NATIONSTAR’S 1/13/16 LIS PENDENS RE A-16-730078-C BY NATIONSTAR
201907170002971DEED OF TRUST 7/17/19 ASSIGNMENT OF JOEL A STOKES- CIVIC FINANCIAL SERVICES STOKES 5/23/19 DOT FROM HMC ASSETS TO MORGAN STANLEY
201907240003355JUDGMENT ON 7/24/19, ONE DAY AFTER NOTICE OF APPEAL 79295 WAS SERVED, JOSEPH HONG RECORDED 6/24/19 ORDER FROM 6/5/19 QUIET TITLE TRIAL OF GORDON B. HANSEN TRUST VS JIMIJACK & VS. YUEN K LEE DBA F. BONDURANT LLC. 6/24/19 ORDER EXPUNGED 5/6/19 LIS PENDENS RECORDED BY NONA TOBIN, AS AN INDIVIDUAL AND AS TRUSTEE OF HANSEN TRUST
201908080002097LIS PENDENS 8/8/19 (7 PAGES) RECORDED BY NONA TOBIN WAS RELATED TO DEPT. 22 CASE A-19-799890-C AND TWO APPEALS INTO 79295 BY NONA TOBIN IN BOTH HER CAPACITIES.

8/8/19 LIS PENDENS WAS EXPUNGED BY 12/3/20 ORDER,
RECORDED ON 12/4/20, BY BRITTANY WOOD,
AS IF NONA TOBIN HAD NEVER RECORDED IT,
AND THEREFORE AS IF WOOD’S CLIENTS,
BRIAN & DEBORA CHIESI AND QUICKEN LOANS, INC AND/OR LLC,
HAD NOT RECORDED THEIR 12/27/19 CLAIMS WHILE NONA TOBIN’S LIS PENDENS WAS ON RECORD.

CURRENTLY UNDER APPEAL IN CASE 82294.
201908140003083LIS PENDENS (7 PAGES) 8/14/19 RECORDED BY NONA TOBIN RE APPEALS 79295 BY NONA TOBIN & HANSEN TRUST
8/14/19 LIS PENDENS WAS EXPUNGED BY 12/3/20 ORDER,
RECORDED ON 12/4/20, BY BRITTANY WOOD,
AS IF NONA TOBIN HAD NEVER RECORDED IT,
AND THEREFORE AS IF WOOD’S CLIENTS,
BRIAN & DEBORA CHIESI AND QUICKEN LOANS, INC AND/OR LLC,
HAD NOT RECORDED THEIR 12/27/19 CLAIMS WHILE NONA TOBIN’S LIS PENDENS WAS ON RECORD.

CURRENTLY UNDER APPEAL IN CASE 82294.
201908140003084LIS PENDENS (39 PAGES)
8/14/19 RE A-19-799890-C
BY NONA TOBIN, AN INDIVIDUAL, INCLUDED COMPLAINT FILED ON 8/13/19 INTO A-19-799890-C

8/14/19 LIS PENDENS (39-PAGES) WAS EXPUNGED BY 12/3/20 ORDER,
RECORDED ON 12/4/20, BY BRITTANY WOOD,
AS IF NONA TOBIN HAD NEVER RECORDED IT,
AND THEREFORE AS IF WOOD’S CLIENTS,
BRIAN & DEBORA CHIESI AND QUICKEN LOANS, INC AND/OR LLC,
HAD NOT RECORDED THEIR 12/27/19 CLAIMS WHILE NONA TOBIN’S LIS PENDENS WAS ON RECORD.

CURRENTLY UNDER APPEAL IN CASE 82294.
201912030003152NOTICE 11/22/19 ORDER; EXPUNGE 8/8/19 TOBIN & HANSEN TRUST LIS PENDENS
201912270001344DEED 12/27/19 VOID SANDRA STOKES TO JOEL STOKES
201912270001345DEED 12/27/19 VOID JOEL A. STOKES TO BRIAN & DEBORA CHIESI
201912270001346DEED OF TRUST 12/27/19 $353,500 QUICKEN LOANS INC TO BRIAN & DEBORA CHIESI

EXHIBIT 12 2020

202002060000198SUBSTITUTION/ TRUSTEE ON 5/23/19 STOKES-CIVIC FINANCIAL SERVICES $355,000 DOT
202002060000199RECONVEYANCE OF 5/23/19 STOKES-CIVIC FINANCIAL SERVICES $355,000 DOT
202012040001097ORDER OF DISMISSAL WITH PREJUDICE NONA TOBIN’S A-19-799890-C COMPLAINT & “LIS PENDENS RECORDED … AS INSTRUMENT NUMBERS 201908080002097, 201908140003083, AND 201908140003084 ARE HEREBY CANCELLED AND EXPUNGED. SAID CANCELLATION HAS THE SAME EFFECT AS AN EXPUNGEMENT OF THE ORIGINAL NOTICE.”

EXHIBIT 13 2021

202102050000240SUBSTITUTION / RECONVEYANCE OF QUICKEN LOANS INC 12/27/19 $353,500 DOT TO CHIESI BY QUICKEN LOANS LLC
202102120001549DEED OF TRUST 2/12/21 RECORDED QUICKEN LOANS LLC 12/28/20 $353,320 DOT TO CHIESI BY QUICKEN LOANS LLC

10 Reasons why to sanction Joseph Hong

1. Lied to the court

2. Sued the wrong party

3. Met the judge ex parte

4/23/19 HEARING AFTER JUDGE KISHNER CALLED MELANIE MORGAN TO SHOW UP

4. Concealed material facts

5/23/19 Stokes $355,000 deed of trust was misrepresented as Jimijack-Nationstar settlement of all claims

5. Concealed conflicts

Ownership interest in F. Bondurant LLC

6. Dumped defective deed

Fraudulent conveyance

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.

      [1911 C&P § 430; RL § 6695; NCL § 10382] — (NRS A 1967, 502)

NRS 205.330
Jimijack’s deed was inadmissible per NRS 111.345
Concealed from Judge Kishner the 5/1/19 deed from Jimijack to Joel Stokes recorded before the 6/5/19 quiet title trial to determine if Jimijack had a title claim that was superior to Nona Tobin’s title.

7. Covered up crimes

Civil Conspiracy with Melanie Morgan to make a fraudulent side deal to obstruct Nona Tobin’s access to a fair, evidence-based adjudication of her claims.
Covered up the many false claims recorded to title

Joel & Sandra Stokes and or Joseph Hong and/or Robert Goldsmith recorded false claims on 6/9/15, 6/9/15, 12/1/15, 5/1/19, 5/23/19, 5/28/19, 7/24/19, 12/3/19, 12/27/19, and 12/27/19 and aided and abetted false claims to be recorded on 6/3/19, 6/4/19, 7/10/19, 7/17/1912/27/19, 2/6/20, 2/6/20,  and 12/4/20, 2/5/21, and 2/12/21.

Fraudulent Misrepresentation

Joseph Hong (NV Bar #5995) filed written false statements, filed frivolous unsupported harassing pleadings, knowingly made false verbal statements, made fraudulent misrepresentations of material facts, concealed/failed to disclose material facts, conspired with others, received proceeds, on these dates, 6/9/15 DEED, 6/16/15, 8/12/15, 10/16/15, 6/14/16, 8/30/16, 9/29/16 RTRAN, 12/5/16, 12/20/16 RTRAN, 3/13/17, 3/13/17, 3/13/17, 12/5/18,  3/25/19, 3/26/19 RTRAN, 4/15/19, 4/22/19, 4/23/19 minutes,  4/23/19 RTRAN, 4/23/19 RTRAN annotated, 4/25/19 RTRAN, 5/1/19 DEED, 5/3/19, 5/21/19, 5/23/19 Agreement, 5/24/19, 5/29/19 video, 5/29/19 RTRAN, 6/3/19 RTRAN, 6/3/19 video, 6/5/19, 6/5/19 video, 6/5/19 RTRAN, 6/5/19 video, 6/6/19 RTRAN, 6/24/19, 6/28/19, 8/7/19, 8/13/19, 9/3/19 RTRAN, 9/3/19 video, 6/25/20, 7/1/20,  8/3/20 annotated,, 8/11/20 video, 8/11/20 RTRAN, 10/8/20, 10/8/20 annotated, 10/16/20 OST, 10/16/20 NEO, 10/29/20 RTRAN, 10/29/20 video, 11/3/20 video, 11/3/20 RTRAN

8. Abused innocent parties

Hong’s combined court filings from 2016-2020 were all in opposition to Nona Tobin’s claims being heard. All were unwarranted, abusive, and obstructed the administration of justice by suppressing evidence and lying to the court.

9. Burden of proof not met

10. Prior pattern of deceit

Fraudulent conveyance to defraud others is a crime

It’s a crime to knowingly receive a fraudulent transfer

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.

      [1911 C&P § 438; RL § 6703; NCL § 10390]

NRS 205.360

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.

      [1911 C&P § 430; RL § 6695; NCL § 10382] — (NRS A 1967, 502)

NRS 205.330
Jimijack’s deed was inadmissible per NRS 111.345
Judge Kishner didn’t know about the 5/1/19 deed to Joel Stokes before the quiet title trial to determine if Jimijack had a title claim that was superior to Nona Tobin’s title.

Nationstar had no right to reconvey the Hansen deed of trust to Joel Stokes instead of to the estate of the deceased borrower

Request for Judicial Notice: 2003-2021 Property Record

All recorded claims by yearCLAIMS BY INSTRUMENT NUMBER, YEAR AND TYPE

2003 Recorded documents
200307310004442 DEED/ HANSEN, H & W 200307310004443 POWER OF ATTORNEY/ HANSEN 200307310004444 DEED OF TRUST/ $310,600 CITY 1ST MORT HANSEN, H & W 200309100000588 DEED OF TRUST/ 7/31/03 ASSIGN 200311200004030 DEED OF TRUST/ WF 2ND $55K
2004 Recorded documents200406110005547 DEED/ DIVORCE TO G HANSEN 200407220003507 DEED OF TRUST/ G HANSEN $436K WESTERN THRIFT 200408170002284 RECONVEYANCE/ 11/20/03 WF 2 G HANSEN 200408310007563 SUBSTITUTION/ RECONVEYANCE 7/31/03 $310,600 PIF 200409010007297 HOMESTEAD/ G HANSEN
2007 Recorded documents  200705100001127 DEED OF TRUST/ WF 2ND $31,600 G HANSEN
2008 Recorded documents  200808270003627 DEED/ 8/27/08 G HANSEN TO GORDON B HANSEN TRUST, DATED 8/22/08
2012 Recorded documents  201212140001338 LIEN/ HOA $925.76
2013 Recorded documents201303120000847 HOA 3/12/13 NOTICE OF $2,475.35 DEFAULT 201304030001569 RESCISSION HOA 3/12/13 NOTICE OF $2,475.35 DEFAULT 201304080001087 HOA 4/8/13 NOTICE OF $2,752.66 DEFAULT 201309230001369 LIEN $264.49 REPUBLIC SERVICES
2014 Recorded documents201402120001527 NOTICE OF 3/7/14 HOA SALE $5,081.45 201405060004357 LIEN $253.50 REPUBLIC SERVICES 201408220002548 DEED HOA FORECLOSURE TO OPPORTUNTY HOMES LLC $63,100 201409090000974 DEED OF TRUST 9/9/14 ASSIGN OF 7/22/04 HANSEN DOT FROM BANA 2 WELLS FARGO BY BANA 201412010000518 DEED OF TRUST 12/1/14 ASSIGN OF 7/22/04 HANSEN DOT FROM BANA 2 NATIONSTAR BY NATIONSTAR
2015 Recorded documents201501220001850 REQUEST FOR NOTICE OF LIENS OR NS 116 OR NRS 107 DEFAULTS BY NATIONSTAR 201502230000608 RPTT REFUND TO THOMAS LUCAS “PROOF OF NOTIFICATION OF HOA FORECLOSURE PROVIDED” 201503120002285 SUBSTITUTION/ 3/12/15 RECONVEYANCE OF WELLS FARGO 5/10/07 2ND HANSEN $31,600 OPEN ENDED DOT 201506090001537 DEED 6/9/15 JIMIJACK DEED IS VOID PER NRS 111.345 201506090001545 DEED OP HOMES TO F. BONDURANT LLC FOR $1.00 201508170001056 SUBSTITUTION/ TRUSTEE ON 7/22/04 HANSEN DOT FROM JOAN H ANDERSON TO AMER EE SERVCING SOLUTIONS BY NATIONSTAR 201512010003402 12/1/15 JUDGMENT/ 10/23/15 BANA DEFAULT
2016 Recorded documents201601130001051 LIS PENDENS 1/13/16 RE A-16-730078-C BY NATIONSTAR 201605230001416 CERTIFICATE OF INCUMBENCY NONA TOBIN AS SUCCESSOR TRUSTEE OF HANSEN TRUST 201605230001417 REQUEST FOR NOTICE “OF ANY LIEN, SALE, TRANSFER, DEFAULT OR ANY OTHER ACTION AFFECTING THIS PROPERTY” BY NONA TOBIN 201606070001450 LIS PENDENS 6/7/16 RE A-15-720032-C BY NATIONSTAR
2017 Recorded documents201703280001452 DEED 3/28/17 HANSEN TRUST TO NONA TOBIN, AN INDIVIDUAL, CLOSE THE HANSEN TRUST 201703300003859 3/30/17 LIEN/ RELEASE 9/23/13 REPUBLIC SERVICES 201703300003860 3/30/17 LIEN/ RELEASE 5/6/14 REPUBLIC SERVICES 201703310003071 INTEREST DISCLAIMER OF STEVE HANSEN 201703310003072 INTEREST DISCLAIMER OF THOMAS LUCAS & OPPORTUNITY HOMES LLC 201703310003073 INTEREST DISCLAIMER YUEN K. LEE & F. BONDURANT LLC
2019 Recorded documents201903080002789 DEED OF TRUST/ 3/8/19 RESCISSION OF 12/1/14 ASSIGNMENT OF 7/22/04 HANSEN DOT FROM BANA TO NATIONSTAR BY NATIONSTAR 201903080002790 DEED OF TRUST/ 3/8/19 ASSIGNMENT OF 7/22/04 HANSEN DOT FROM WELLS FARGO TO NATIONSTAR BY NATIONSTAR 201905010003348 DEED VOID 5/1/19 TRANSFER OF JIMIJACK 6/9/15 DEED TO JOEL A. STOKES, AN INDIVIDUAL 201905060001022 LIS PENDENS 5/6/19 4/30/19 NOLP RE A-720032C BY TOBIN & HANSEN TRUST 201905230003531 DEED OF TRUST/ AGREEMENT 5/23/19 $355,000 CIVIC FINANCIAL SERVICES TO JOEL A. STOKES 201905280002843 LIS PENDENS/ 5/28/19 JOEL & SANDRA STOKES RELEASED NATIONSTAR’S 6/7/16 LIS PENDENS AS IF THEY OWNED IT 201906030001599 SUBSTITUTION/ 6/3/19 RECONVEYANCE OF 7/22/19 HANSEN DOT TO JOEL A STOKES BY NATIONSTAR 201906040000772 DEED OF TRUST 6/4/19 ASSIGNMENT OF STOKES 5/23/19 DOT CIVIC FINANCIAL SERVIECES TO HMC ASSETS 201907100002352 LIS PENDENS/ RELEASE OF NATIONSTAR’S 1/13/16 LIS PENDENS RE A-730078-C BY NATIONSTAR 201907170002971 DEED OF TRUST 7/17/19 ASSIGNMENT OF STOKES 5/23/19 DOT HMC ASSETS TO MORGAN STANLEY 201907240003355 JUDGMENT 7/24/19 RECORD OF 6/24/19 ORDER A-720032-C 201908080002097 LIS PENDENS 8/8/19 RE A-19-79980-C AND APPEAL 79295 BY TOBIN & HANSEN TRUST 201908140003083 LIS PENDENS 8/14/19 RE APPEAL 79295 BY NONA TOBIN & HANSEN TRUST 201908140003084 LIS PENDENS 8/14/19 RE A-19-79980-C BY NONA TOBIN 201912030003152 NOTICE 11/22/19 ORDER; EXPUNGE 8/8/19 TOBIN & HANSEN TRUST LIS PENDENS 201912270001344 DEED 12/27/19 VOID SANDRA STOKES TO JOEL STOKES 201912270001345 DEED 12/27/19 VOID JOEL A. STOKES TO BRIAN & DEBORA CHIESI 201912270001346 DEED OF TRUST 12/27/19 $353,500 QUICKEN LOANS INC TO BRIAN & DEBORA CHIESI
2020 Recorded documents202002060000198 SUBSTITUTION/ TRUSTEE ON 5/23/19 STOKES-CIVIC FINANCIAL SERVICES $355,000 DOT 202002060000199 RECONVEYANCE OF 5/23/19 STOKES-CIVIC FINANCIAL SERVICES $355,000 DOT 202012040001097 ORDER OF DISMISSAL WITH PREJUDICE NONA TOBIN’S A-19-799890-C COMPLAINT & “LIS PENDENS RECORDED …AS INSTRUMENT NUMBERS 201908080002097, 201908140003083, AND 201908140003084 ARE HEREBY CANCELLED AND EXPUNGED. SAID CANCELLATION HAS THE SAME EFFECT AS AN EXPUNGEMENT OF THE ORIGINAL NOTICE.”
2021 Recorded documents202102050000240 SUBSTITUTION / RECONVEYANCE OF QUICKEN LOANS INC 12/27/19 $353,500 DOT TO CHIESI BY QUICKEN LOANS LLC 202102120001549 DEED OF TRUST 12/28/20 QUICKEN LOANS LLC $353,320 DOT TO CHIESI BY QUICKEN LOANS LLC