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 7: 1st complaint to the Nevada Attorney General
Exhibit 8: 2nd complaint to the Nevada Attorney General
Exhibit 11: What is the PUD Rider?
Exhibit 12: A Duel to the Death
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 25: Judicial Jiu-Jitsu is fraud on the court
Exhibit 26: Nationstar Mortgage’s fraud
Exhibit 28: Nevada Rules of Civil Procedure
Exhibit 29: Implicated Nevada Rules of Professional Conduct
Exhibit 32: Complaints to the Nevada Attorney General
Exhibit 33: What is Lis Pendens?
Exhibit 34: Why Alternative Dispute Resolution
Plaintiff repeats, realleges, and incorporates herein by this reference the allegations hereinabove inclusively as though set forth at length and in full herein.
Defendants collectively constitute a combination of two or more persons.
Defendants acted in concert by agreement, understanding, or a “meeting of the minds” regarding the objective and the means of pursuing it, whether explicit or by tacit agreement (the “Scheme”).
Defendants, and each of them, intended to and did accomplish an unlawful objective for the purpose of harming Plaintiff Nona Tobin through the Scheme.
The Scheme harmed Plaintiff Nona Tobin
As a direct, proximate, and foreseeable result of the Scheme, Plaintiff has been damaged in excess of $15,000 and in an amount to be determined at the time of trial.
Defendants’ acts were committed with fraud, oppression, and/or malice, entitling Plaintiff Nona Tobin to punitive damages pursuant to NRS 42.005 in an amount to be determined at the time of trial.
As a direct, proximate, and foreseeable result of the Defendants’ acts, it has become necessary for Nona Tobin to secure the services of an attorney, and Nona Tobin is entitled to recover fees and costs incurred herein as damages.