| Doc. No. | Uninvestigated Ethics Complaints to the State Bar of Nevada |
| 22-08189 | 2/23/22 Verified Bar Complaint Vs. Melanie Morgan, Akerman LLP Morgan aided and abetted Nationstar to collect on a debt it was not owed from Tobin who did not owe it by misrepresentation, concealing and suppression of evidence, stipulated dismissal of claims without adjudication, unfair removal of Tobin as an Individual party on false pretenses, fraudulent side deal with non-party Joel Stokes, misrepresented as the Nationstar-Jimijack settlement & improper Ex Parte communications with 1st judge Pages 4045-4154 |
| 22-08190 | 2/28/22 Wright Finley Zak LLP Verified Bar Complaint WFZ filed Nationstar’s original meritless & conflicting claims to be the beneficiary owed the debt from the deed of trust extinguished by the 8/1/14 sale, the lie that caused six years of litigation that aided and abetted Nationstar to abuse the HOA quiet litigation process to collect a debt it was not owed from Tobin who did not owe it without foreclosure and disregarding the PUD Rider Remedies (F) provision that prohibits any lender from using the payment of delinquent HIA assessments as a de facto foreclosure Pages 4155-4259 |
| 22-08191 | 3/1/22 Steven Scow, Koch & Scow, LLC Part 1 Verified Bar Complaint Scow produced Red Rock’s false evidence in response to Tobin’s Subpoena. It was the hearsay evidence that provided the total support for the HOA’s meritless MSJ that became the “law of the case” and stopped all judicial scrutiny of any verified evidence in the remainder of the 1st action and in both subsequent actions Pages 4260-4354 |
| 22-08192 | Steven Scow Part 2 Verified Bar Complaint Exhibits B-F Red Rock instructed Scow to remit checks for excess proceeds to court but Scow retained millions in proceeds from all Sun City Anthem foreclosures and from all Red Rock foreclosures in multiple other HOAs by disregarding Red Rock’s instructions and NRS 116.31164(3)(c)(2013) statutory mandate that required distribution of all proceeds in 2014. Scow covered up how Red Rock was unjustly enriched by selling directly to investors without conducting public auctions, by not indemnifying the HOA according to contract terms, and by misrepresenting the open meeting law to inattentive or unsophisticated HOA Boards. Pages 4355- 4438 |
| 22-08194 | Steven Scow Part 3 Verified Bar Complaint Exhibits F -H-5 The false evidence Scow gave to the HOA and in response to subpoena covered up that: 1) Red Rock covertly sold the property after rejecting assessments that cured the default three times; 2) the HOA Board did not authorize the sale by valid corporate action; 3) Required notices were not provided, but records were falsified to fake that they had been sent. Pages 4439-4603 |
| 22-08195 | 3/6/22 Verified Bar Complaint vs. David Ochoa & Adam Clarkson Sun City Anthem attorneys Exhibits A-D Attorneys deprived Tobin of ADR, then obstructed her litigation and appeal litigation. They misrepresented the false evidence from Red Rock as the HOA’s official records and concealed the HOA’s actual verified records that were inculpatory t Red Rock and of probative value to Tobin’s case. Pages 4604 – 4733 |
| 22-08196 22-08198 | 3/6/22 Verified Bar Complaint vs. David Ochoa & Adam Clarkson Exhibits E, E-1, E-2, 3-3 F Shows how HOA MSJ was meritless for more reasons than because SCA had no standing to file it, i.e., the supporting exhibits include falsified documents produced by Red Rock and conceal the HOA’s real records indicating that Ochoa & Clarkson are working for Red Rock, not for the HOA. Pages 4734 – 4847 |
| 22-08199 | 3/6/22 Verified Bar Complaint vs. David Ochoa & Adam Clarkson Exhibits G shows exactly how documents were doctored or just deceptive. G-1 & G-2 show the attorneys advised the HOA Board to act in a manner that did not comply with HOA meeting laws. G-3 shows that SCA Board was told that it was legally required to keep confidential from all SCA owners when Red Rock was intending to sell an SCA property. G-4 shows that in one year, Red Rock secretly sold a dozen houses to investors for less than 20% of their value, and the HOA has no records that any of them were foreclosed or sold under the HOA’s statutory authority or that any amount of money was collected. G-5 shows that no valid Board action approved any of the sales. H shows more disputed facts that were in the HOA’s motion for summary judgment; H-1 shows a comparison with a case in a different HOA with different lenders but many of the same attorneys Pages 4848 – 5046 |
| 22-08162 | 9/4/17 Verified Bar Complaint Adam Clarkson & 9/12/17 Bar Rejection Had the State Bar not ignored Tobin’s 1st Bar Complaint against Adam Clarkson for bullying, harassment, representing the interests of the HOA manager against the interests of the HOA, misrepresenting the law to the HOA Board regarding open meeting and notice requirements, years of litigation could have been averted. Pages 242-279 |
| 22-08163 | 2/14/21 Joseph Hong And 2/16/21 Brittany Wood Verified Bar Complaints & 3/4/21 Bar Counsel’s Rejection pending Tobin’s submission of a court order with written findings of attorney misconduct. Hong conspired with Melanie Morgan to obstruct the 1st action because neither of their clients had evidence to support their title claims and the way to win was to get rid of Tobin by whatever means. They negotiated a fraudulent side deal, misrepresented it to the court, orchestrated an ex parte meeting with the judge, recorded multiple false claims to title to aid and abet their clients’ fraudulent reconveyance of the property to defraud Tobin. They lied to the district courts and the courts of appeal about Tobin’s standing as an individual to prevent her claims from being heard and to obstruct judicial scrutiny of her verified evidence. Brittany Wood conspired with Joseph Hong and others to cover up that her clients were not bona fide purchasers, but knowingly received the last fraudulent transfer while there were three of Tobin’s lis pendens on record. Wood made multiple intentional misrepresentations of material fact to obstruct Tobin’s claims from being heard on their merits because, if they were fairly heard, her clients would lose both their investment, whatever it was, and the property, because chances are, the title insurance wouldn’t have paid. Pages 280-460 |
