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

Cause of Action: Civil Conspiracy

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.