Civil complaint against attorneys

Causes of Action: Abuse of process, civil conspiracy, fraud, and racketeering

Link to PDF of 3/22/21 third-party complaint into A-21-828840-C & exhibits

Exhibit 1: Cause of action: Fraud

Exhibit 2: Cause of action: Abuse of process

Exhibit 3: Civil damages due to Racketeering

Exhibit 4: Cause of action: Conspiracy

Exhibit 5: Alleged facts

Exhibit 6: What does it take to get disbarred in Nevada?

Exhibit 7: 1st complaint to the Nevada Attorney General

Exhibit 8: 2nd complaint to the Nevada Attorney General

Exhibit 9: Why Nationstar & its attorneys must be sanctioned & pay punitive damages

Exhibit 10: All declarations under penalty of perjury support Nona Tobin’s claims

When all statements under oath support Nona Tobin, why does she keep losing?

Exhibit 11: What is the PUD Rider?

Exhibit 12: A Duel to the Death

Exhibit 13: We can learn a lot from this Spanish Trail HOA case

Exhibit 14: Complaints to the State Bar of Nevada Ethics & Discpline Panel vs. Brittany Wood

Exhibit 15: Complaint against Melanie Morgan

Exhibit 16: Complaint to the Mortgage Lending Division

Exhibit 17: Complaint vs. Brittany Wood

Exhibit : 2020 court hearings Part 1

Exhibit 19: Complaints to law enforcement

Exhibit 20: Harassment or bullying an HOA homeowner is a crime

Exhibit 21: How the crooks steal HOA houses

Exhibit 22: Implicated Nevada law

Exhibit 23: Interpleader complaint was filed with an ulterior motive

Exhibit 24: Joseph Hong: pay Nona Tobin treble damages for stealing her house and be disbarred

Exhibit 25: Judicial Jiu-Jitsu is fraud on the court

Exhibit 26: Nationstar Mortgage’s fraud

Exhibit 27: Nevada Commission on Judicial Discipline Complaint

Exhibit 28: Nevada Rules of Civil Procedure

Exhibit 29: Implicated Nevada Rules of Professional Conduct

Excerpts related to attorney misconduct in this situation as well as a link to the full Nevada rules for professional conduct. Here is a link to the ABA Standards for Imposing Lawyer Sanctions which also should weigh heavily in the Court’s decision to appropriate level of discipline to impose.

Exhibit 30: Nona Tobin’s Request for Judicial Notice of the property record

Exhibit 31: Recommendation to the Nevada Commission on Judicial Discipline

Exhibit 32: Complaints to the Nevada Attorney General

Exhibit 33: What is Lis Pendens?

Exhibit 34: Why Alternative Dispute Resolution

Interpleader Complaint was filed with an ulterior motive

2/3/21 Red Rock Financial Services Interpleader Complaint electronically issued without notice to defendants

Case was assigned to Judge Kishner Dept 31

Judge Kishner immediately recused herself “in order to avoid the appearance of impartiality

link to 2/9/21 minutes
There was no electronic service of the recusal as Steven Scow did not put any defendants’ service contacts into Odessey

2/9/21 Department reassignment from Judge Kishner (Dept. 31) to Judge Jessica K. Peterson (Dept. 8) occurred without notice

There was no electronic service of the notice of departmental reassignment as Steven Scow did not put any defendants’ service contacts into Odessey.
Link to 2/9/21 NODR notice of department reassignment

Service on Nona Tobin, as an individual

link to affidavit of service on Nona Tobin, an individual
Serving Nona Tobin as an individual was necessary because Nona Tobin, as an individual, has THE ONLY recorded claim for the proceeds.
Link to Nona Tobin’s 3/28/17 deed, as an individual,

Service on Nona Tobin, as a trustee

Unnecessary because Steven scow knows the Hansen Trust was closed in 2017.

link to affidavit of service on Nona Tobin, as trustee
Nona Tobin, as the trustee of the Gordon B. Hansen Trust, dated 8/22/08, does not have a competing claim with herself as an individual. The Hansen Trust was closed in 2017 when the title was transferred to Nona Tobin, an individual, as the sole beneficiary.
Page 2 of Nona Tobin’s 3/28/17 deed shows that the Hansen Trust has been closed

Service on Wells Fargo

Service was unnecessary as Wells Fargo released its 5/10/07 lien on 3/12/15

Link to Wells Fargo’s 3/12/15 Substitution and Reconveyance
Wells Fargo’s Registered agent Corporation Service Company, was served in Carson City, 112 North Curry Strret, 89703
link to affidavit of service on Wells Fargo

Obviously, Wells Fargo will not file a claim for the excess proceeds.

Service on Nationstar

Unnecessary because Nationstar (albeit for a corrupt intent and with no legal authority) released the lien of the disputed Hansen deed of trust on 6/3/19

Link to the 6/3/19 release of the lien of the Hansen deed of trust

Obviously, Nationstar will not file a claim for the excess proceeds.

Nationstar’s Registered agent Corporation Service Company, was served in Carson City, 112 North Curry Strret, 89703
Link to affidavit of service on Nationstar

Service on Republic Services

Service on Republic Services was unnecessary because its liens were released in 2017.

Republic Services was served on 2/16/21 at 12:23 PM via the Danielle Nakicommercial agent CT Corporation System, 701 S. Carson St., Ste. 200, Carson City 89701
link to affidavit of service on Republic Services

Amazing 24-hour turn-around made possible by Red Rock’s failure to distribute funds before statutory liens were released.

Disclaimer of interest was filed on 2/17/21 at 12:23 PM by Republic Silver State Disposal, Inc. d/b/a Republic Services
Link to disclaimer of interest by Republic Services
Link to Republic Services 3/30/17 lien release instrument 20170330003859
Link to Republic Services 3/30/17 lien release instrument 20170330003860
Obviously, Republic Services will not file a claim for the excess proceeds.

Steven Scow knew filing for interpleader more than six years late when only one person had a recorded claim was unwarranted.