Nona Tobin’s answer to Red Rock Financial Services

On 3/8/21 Nona Tobin filed an answer and counter-claim when Red Rock sued her over the money they stole from her in 2014. This blog contains the answer and links to the exhibits.

Nona’s answer

  1. Answering the allegations contained in paragraph 2. See Exhibit 17.
  2. Answering the allegations contained in paragraphs 3 of the Complaint, Nona Tobin, admits that Wells Fargo is a national banking association doing business in Clark County, but denies that Plaintiff acted in good faith when it named Wells Fargo as a defendant.
  3. Nona Tobin denies the allegation that Wells Fargo was properly named as a defendant by allowing the documents to speak for themselves.  See Exhibit 1 and Exhibit 18.
  4. Answering the allegations contained in paragraphs 4 of the Complaint, Nona Tobin, admits that Defendant Republic Services, Inc. is a Nevada corporation doing business in Clark County, but denies that Plaintiff acted in good faith when it named Republic Services, Inc as a defendant, and denies the allegations by allowing the documents to speak for themselves. See Exhibit 1 and Exhibit 16.
  5. Answering the allegations contained in paragraphs 5 of the Complaint, Nona Tobin admits Nationstar Mortgage LLC was incorporated in Delaware and during all relevant times was doing business in Clark County, NV under NV Business ID: NV20101844335, but denies that Plaintiff acted in good faith when it named Nationstar Mortgage LLC as a defendant.
  6. Nona Tobin denies RRFS’s allegation that Nationstar LLC has any standing to assert a claim in this interpleader action for any portion of the proceeds by allowing the documents to speak for themselves. See Exhibit 1 and Exhibit 20.
  7. Answering the allegations contained in paragraph 10, quoted here below,  Nona Tobin denies the allegations contained therein as they grossly misrepresent the facts and the duties owed. See Exhibits 8, 10, 12, 13, 14, 15, 16, 17.

In connection with the foreclosure sale, the Association was paid the money it was owed, and RRFS was paid its fees and costs incurred in collecting the debt as allowed by contract and Nevada law.

After paying these costs, RRFS was left with funds of $57,282.32. RRFS has no further direct interest in such funds.

These funds have been deposited into counsel’s attorney-client trust account and $3,500 has been withheld as costs, expenses, and fees to commence this action.

The remainder of such funds will be deposited with the Court until such time and place as directed by this Court.

Red Rock’s law suit against Nona Tobin & others, page 3, paragraph 10

Exhibits to Nona’s answer are linked here

  1. APN 191-13-811-052 Clark County Property Record and allegations of fraud vs. all opposing parties
  2. the sale was void for rejection of assessments.
  3. The alleged default was cured three times,
  4. SCA Board did not authorize the sale by valid corporate action
  5. Required notices were not provided, but records were falsified to cover it up
  6. SCA Board imposed ultimate sanction with NO due process 
  7. Neither BANA nor NSM ever owned the disputed DOT
  8. Examples of RRFS corrupt business practices
  9. Attorneys’ lack of candor to the tribunal
  10. the proceeds of the sale were not distributed pursuant to NRS 116.31164(3) (2013)
  11. RRFS’s fraud, oppression & unfairness
  12. attorney interference in the administration of justice
  13. lack of professional ethics and good faith
  14. Presented false evidence to cover up crime
  15. Civil Conspiracy to cover up racketeering warrants punitive damages
  16. Republic Services lien releases
  17. Nona Tobin’s standing as an individual
  18. Relevant statutes and regulations
  19. RELEVANT HOA GOVERNING DOCUMENTS PROVISIONS
  20. Administrative Complaints related to the APN 191-13-811-052 title dispute
  21. Nevada court cases related to the APN 191-13-811-052 title dispute
  22. Excerpts of 1/31/17 cross-claim vs. HOA and its agents