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.
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.
Implicated Attorney Joseph Hong (SBN 5995) initiated the quiet title action by suing the wrong bank.
Joseph Hong violated NRPC 3.1 by filing the original 6/16/15 quiet title claim against Bank of America (BANA) on behalf of Joel & Sandra Stokes as trustees for Jimijack Irrevocable Trust, supporting it with a fraudulently notarized, fatally defective deed, recorded on 6/9/15, that was void, inadmissible as evidence of title (NRS 111.345) and legally insufficient for holding or transferring title.
Hong knew the title claim was meritless because
1) Jimijack Irrevocable Trust actually took possession of the property as the second owner, nine months earlier on 9/25/14, according to the HOA’s ownership records, concealed and doctored in discovery, (RTR Pg. 1337),
2) the defendant BANA was disinterested as it had assigned its interest in the 1st deed of trust to Wells Fargo on 9/9/14.
Hong never filed any title claim against Wells Fargo who had the 9/9/14 recorded title claim until after the end of discovery in the 1st action.
Hong never filed a quiet title claim against Nationstar who held a recorded adverse, albeit worthless, claim to be the beneficiary from 12/1/14 to 3/8/19.
Hong never was required to produce any evidence of title for his clients despite
NRS 40.110 Court to hear case; must not enter judgment by default; effect of final judgment.
1. When the summons has been served as provided in NRS 40.100 and the time for answering has expired, the court shall proceed to hear the case as in other cases and shall have jurisdiction to examine into and determine the legality of plaintiff’s title and of the title and claim of all the defendants and of all unknown persons, and to that end must not enter any judgment by default, but must in all cases require evidence of plaintiff’s title and possession and receive such legal evidence as may be offered respecting the claims and title of any of the defendants and must thereafter direct judgment to be entered in accordance with the evidence and the law. The court, before proceeding to hear the case, must require proof to be made that the summons has been served and posted as hereinbefore directed and that the required notice of pendency of action has been filed.
2. The judgment after it has become final shall be conclusive against all the persons named in the summons and complaint who have been served personally, or by publication, and against all unknown persons as stated in the complaint and summons who have been served by publication, but shall not be conclusive against the State of Nevada or the United States. The judgment shall have the effect of a judgment in rem except as against the State of Nevada and the United States; and the judgment shall not bind or be conclusive against any person claiming any recorded estate, title, right, possession or lien in or to the property under the plaintiff or the plaintiff’s predecessors in interest, which claim, lien, estate, title, right or possession has arisen or been created by the plaintiff or the plaintiff’s predecessor in interest within 10 years prior to the filing of the complaint.
Hong never recorded a lis pendens nor a summons to the interested parties despite
NRS 14.010 Notice of pendency of actions affecting real property: Recording.
NRS 14.015 Notice of pendency of actions affecting real property: Hearing; cancellation; bond.
NRS 14.017 Notice of pendency of actions affecting real property: Transferability of property after withdrawal or cancellation.
Hong got BANA’s default by serving the wrong corporate address.
Hong filed no notice of entry of the default judgment against BANA.
Hong never filed any other claim and never answered any claims against any of his clients. They just collected rent without paying a mortgage for four years and then covertly transferred the deed before the trial and paid Akerman $355,000 to record a lien release to give the property free and clear to Joel Stokes by both Joel Stokes and Nationstar getting to skipp the trial and Nona Tobin as an individual and my evidence being barred from going to trial.
Hong filed no claims against me in either of my capacities, and he completely fabricated the story that I had not filed claims as an individual in the first action to cover up that he had orchestrated that ex parte hearing in order to get my pro se MSJ and evidence stricken by unappealable bench order so the court would not see that neither his clients nor Nationstar had any evidence of title. Red Rock and the HOA were glad to help them because Red Rock and the HOA knew that the HOA sale had not been properly approved by the HOA Board at an open meeting of the Board because Red Rock and the HOA attorneys and managers had been misinforming the HOA Board about what their requirements were for