Complaint Against Melanie Morgan

I, Nona Tobin under penalty of perjury, states as follows: I have personal knowledge of the facts stated herein, except for those facts stated to be upon information and belief. If called to do so, I would truthfully and competently testify to the facts stated herein, except those facts stated to be based upon information and belief. I make this declaration in support of a third-party complaint in case A-21-828840-C.

  1. Upon information and belief, Melanie Morgan conspired with Joseph Hong to make a covert deal, characterized it fraudulently as a Nationstar-Jimijack agreement that settled all parties’ claims in order to steal 2763 White Sage from me without adjudication. See 4/23/19 transcript, 4/25/19 transcript, and 5/21/19 transcript.
  2. See 5/23/19 AGREE annotated recorded document (instrument number 201905230003531) that was allegedly the Jimijack-Nationstar deal but was actually a $355,000 payment to Joel Stokes by Civic Finacial Services, masquerading as a deed of trust securing a property no court had ruled Joel Stokes owned.
  3. Melanie Morgan conspired with Joseph Hong to serve notice that the 4/23/19 hearing on Nationstar’s motion for summary judgment vs. Jimijack was continued to 5/7/19, but Hong and Morgan somehow knew to go to the “hearing” anyway to make egregious misrepresentations of the facts, my standing as an individual party and the law to the Judge Kishner.  Their duplicity was successful. My pro se motions for summary judgment against Jimijack, and against Nationstar and other cross-defendants were stricken unheard. See 4/23/19 minutes, transcript and VIDEO. See 963-page EX PARTE STRICKEN exhibit of the unduplicated motions, oppositions and documentary evidence that was stricken by bench order at the 4/23/19 ex parte hearing allegedly because I filed them as a pro se before my attorney had filed a motion to withdraw, but actually because Judge Kishner acted on Melanie Morgan’s and Joseph Hong’s lies.
  4. Upon information and belief, Melanie Morgan and other attorneys from Akerman and Wright Finley Zak filed multiple documents that included the false claim that Nationstar was the beneficial owner of the disputed Hansen deed of trust and had authority without any basis in fact or law to release the lien of the Hansen deed of trust on 6/3/19, two days before trial, substitute trustee and reconvey the property to Joel Stokes rather than to the estate of the deceased borrower. See 6/3/19 annotated SUB/RECONVEY that was recorded as instrument 201906030001599. See NSM 001-063 RECORDED FRAUD exhibit.
  5. Melanie Morgan and/or Donna Wittig, of Akerman LLP for Nationstar Mortgage LLC and/or dba Mr. Cooper conspired with, and/or acted in concert with, Joseph Hong for Joel A. Stokes, Joel & Sandra Stokes as trustees for Jimijack Irrevocable Trust, and Jimijack Irrevocable Trust; Brittany Wood of Maurice Wood for Brian and Debora Chiesi and (maybe) for Quicken Loans LLC and/or Inc.; and with David Ochoa of Lipson Neilson for Sun City Anthem and/or with Brody Wight and/or Steven Scow for Red Rock Financial Services, a partnership (EIN 88-058132) for, upon information and belief, the corrupt purpose of uniformly concealing and misrepresenting material facts to the court in the same manner.
  6. Their actions to gang up on me resulted in the obstruction of any possible fair adjudication of my claims and have prevented ANY judicial scrutiny of the evidence I possess that would be fatal to their clients’ cases. 
  7. See  “Nationstar evidence was not examined” 7-page exhibit that analyzes line by line Nationstar’s NRCP 16.1 4th supplemental disclosures, served on 3/12/19, two weeks after the end of discovery in A-15-720032-C.
  8. Akerman Attorneys know, or have access to information that they reasonably should know, that Nationstar’s false and conflicting filed and recorded claims judicially estopped Nationstar from claiming to own now, or to ever have owned, the disputed Hansen deed of trust. See 1/11/16 complaint, 6/2/16 AACC counter-claim vs. Jimijack, 12/1/14 recorded claim, 3/8/19 recission of the 12/1/14 claim, 3/8/19 assignment, 2/28/19 response to #7 interrogatory, 6/3/19 reconveyance.
  9. Upon information and belief, Steven Scow has conspired with attorneys from Akerman LLP, Wright, Finley, Zak LLP to conceal Nationstar’s criminal acts of recording false claims to title (NRS 205.377, NRS 207.360) while they conealed Red rock’s rejection of SCA 302, and support them in their fraudulent claims with the quid pro quo being that Koch & Scow gets to keep more of the undistributed proceeds for keeping the devil’s bargain with Nationstar and other lenders. “210116 We can learn a lot from this Spanish Trail HOA case” 
  10. Akerman attorneys know that the disclosures served into A-15-720032-C contain false evidence and that the responses to my interrogatories and requests for documents were duplicitous.
  11. Akerman attorneys know that Nationstar was not complaint with NRS 38.310 and therefore Judge Kishner did not have jurisdiction pursuant to NRS 38.310(2) to provide either Akerman’s or Hong’s clients their requested relief, but Melanie Morgan pursuaded Judge Kishner that she had to strike my 4/9/19 NTOC notice of completion of mediation from the record unheard since I was the only one, in both my capacities to complete mediation.
  12. Judge Kishner persisted in the delusion that I wasn’t a party and so she refused to hear my 7/26/19 NOTC.
  13. Brody Wight knowingly filed a motion to dismiss that was not supported by facts or law to cover up the crimes of his law firm and its clients.
  14. Akerman and Wright Finley Zak attorneys know that Red Rock Financial Services conducted an unfair, unnoticed and fraudulent sale and provided false evidence (RRFS 001-425) that was further falsified by Sun City Anthem attorneys David Ochoa and/or Adam Clarkson and/or John Aylor in SCA 176-643) to cover it up.
  15. All attorneys for Nationstar, for Sun City Anthem, Red Rock Financial Services, and their financially-conflicted errors & omissions insurance policy carrier, concealed or withheld documents , falsified evidence, filed court documents rife with deception,  for the corrupt purpose of evading detection of the true facts of how the disputed HOA sale was conducted, where the money came from and where the money went. See A-19-799890-C complaint that was dismissed unheard by Judge Susan Johnson of the grounds of res judicata by 12/3/20 order of dismissal with prejudice. See “TOC TOBIN 4 APPEALS 12-pages” to understand how successful their conspiracy has been in obstructing ALL judicial scrutiny of the evidence
  16. Akerman and Wright Finley Zak attorneys for Nationstar know that Nationstar negotiator Veronica Duran’s 5/28/14 Equator message to Craig Leidy saying she was authorized to offer $1100 to the HOA to close the 5/14/14 $367,500 sale to MZK Properties was disclosed as  (SCA 302) but did not acknowledge it. 
  17.  Melanie Morgan, and the other Akerman attorneys, knew that the Equator records that they refused to provide in discovery, and that Forrest Barbee, Berkshire Hathaway broker under contract with me from 2/20/14 to 10/31/14, helped them conceal, would have been additional proof that in 2014 servicing bank Nationstar refused to identify the beneficiary, refused to close escrow on the 5/8/14 sale to MZK properties.
  18. Melanie Morgan, and the other Akerman attorneys, knew that Nationstar didn’t begin lying about being owed the $389,000 balance on the Hansen deed of trust until 12/1/14, over three months after the sale, and that if the HOA sale was valid to extinguish the interest of the estate of the deceased borrower, that it also extinguished the deed of trust. Nevertheless, she persisted in fabricating standing for Nationstar that did not exist in fact or in law.
  19. Melanie Morgan tricked the court into letting her and Hong settle out of court without either Plaintiff Nationstar or Jimijack presenting a case or going to trial. See 3/14/19 Complaint to the Nevada Attorney General,  11/10/20 Complaint to the Nevada Attorney General, and the linked tables of contents of exhibits to both.
  20. Akerman and Wright Finley Zak attorneys concealed all of the Equator records and other mortgage-servicing and broker files to which I am entitled and which I requested in discovery that would have shown the exact nature of Nationstar’s agents, employees, and/or attorneys’ communications with Red Rock about the HOA sale, and how the $1100 Nationstar offer was rejected. (2/21/19 RESP to RFDs) See also NSM’s 2/21/19 RESP 2 ROGs.
  21. Akerman and Wright Finley Zak attorneys concealed the $1100 offer from Nationstar rejected by Red Rock and mysteriously never claimed it as a justification for voiding the sale.
  22. Akerman and Wright Finley Zak attorneys knowingly and repeatedly made the false claim that Red Rock’s 5/9/13 covert rejection of $825 tendered by Bank of America’s attorney, Rock K. Jung, then an attorney with Miles, Bauer, Bergstrom & Winters, LLP, but currently with Wright, Finley, Zak, LLP, was grounds for voiding the sale only insofar as protecting the security interest Nationstar was pretending to own, but was not grounds for protecting the ownership interest of the deceased borrower. See
  23. SCA attorney Ochoa claimed in his 8/9/19 AFFD for attorney fees (page 35 of 53) that he prepared RFDs, ROGs, and RFAs for NSM on 8/8/18, but no SCA to NSM RFDs, ROGs, or RFAs were served on the parties, and no NSM RESP to SCA ROGs, RFDs, or RFAs were ever served through the NVefile system.
  24. SCA/RRFS/NSM concealed in discovery the 3/28/14 RRFS pay off demand to Chicago Title which on page 6 includes a $400 fee waiver approved by the HOA Board at its 3/27/19 meeting that Leidy did request.
  25. SCA concealed in discovery the requested board minutes where the HOA sale was approved, because there are no minutes of any meeting at which the sale was approved. SCA lied about the minutes being contained in SCA 644-654 in its 2/26/19 RESP to RFDs (page 7, response 7), line 10). See also 2/28/19 RESP ROGs
  26. SCA 315 claims that the sale was approved as item R-05-120513 at the 12/5/13 HOA Board meeting is false and deliberately deceptive.

I declare under penalty of perjury under the laws of the State of Nevada that the foregoing is true and correct.

Dated this 21st day of March 2021.

2nd complaint to the Nevada Attorney General & exhibits

Links to exhibits to 2nd complaint to the Nevada Attorney General

  1. 12/1/14 Assignment    Nationstar – no power of attorney – executed B of A to Nationstar assignment of the 7/22/04 Hansen deed of trust
  2. NSM 258-260 Nationstar disclosed it did not have the original Hansen promissory note, and the copy of the note it had was not endorsed to Nationstar
  3. 2/20/19 SODWOP      Nationstar dropped all its quiet title claims against all parties except Jimijack (1/11/16 COMP in A-16-730078-C) without adjudication or any judicial scrutiny of evidence.
  4. 2/2819 RESP Pg 6      Nationstar admitted in response to interrogatories that it was not the beneficiary of the Hansen deed of trust; it was just the servicing bank for non-party Wells Fargo who has never claimed to be the beneficiary of the Hansen deed of trust. On page 7, the verification only included that Nationstar was the servicer and was signed by a previously unknown person of unknown authority.
  5. 3/8/19 Rescission        Nationstar – no power of attorney – rescinded 12/1/14 B of A to Nationstar assignment of the 7/22/04 Hansen deed of trust which means that Nationstar had no recorded claim to give it standing to be in either cases A-15-720032-C or A-16-730078-C and is judicially estopped from claiming that it was the owner of the Hansen deed of trust during all relevant times or ever.
  6. 3/8/19 Assignment      Nationstar – no power of attorney – executed Wells Fargo to Nationstar assignment of the 7/22/04 Hansen deed of trust
  7. 3/14/19 AG 2-2019     Complaint to the AG that was allegedly served on Melanie Morgan
  8. 3/18/19 NITD Nationstar three-day notice to take default against Jimijack since Jimijack did not answer the 6/2/16 AACC
  9. 3/21/19 MSJ   Nationstar filed an MSJ against Jimijack and not against Nona Tobin, the HOA or the Gordon B Hansen Trust
  10. 4/10/19 OPP/MSJ       Tobin opposition to Nationstar’s MSJ as Nationstar did not own the beneficial interest of the Hansen deed of trust; and the HOA sale was void in its entirety so foreclosure would have to have been against Tobin for any lender; plus Jimijack’s deed was void per NRS 111.345.
  11. 4/9/19 NRS 38.310(2) Notice of completion of mediation by Tobin/Hansen Trust when neither Jimijack nor Nationstar had complied with NRS 38.310 so the court lacked jurisdiction to grant them relief sought.
  12. 4/12/19 NS      Jimijack (who didn’t have a valid deed never filed any claims against Nationstar or against Tobin or the Hansen Trust) prevailed in the quiet title case by “settling” out of court with Nationstar in a fraudulent deal that excluded Tobin and the Hansen Trust. Judge Kishner never examined any evidence to support their claims (Judge Kishner held 42 hearings, but never examined any evidence.)
  13. 4/17/19 TOC exhibits 600 pages of evidence to support Tobin’s claims that were stricken from the record unheard by bench orders at the 4/23/19 ex-parte hearing.
  14. 4/19/19 RESP Nationstar convinced the court that it was ok for Nationstar and Jimijack to settle the quiet title dispute without the court examining any evidence because Nationstar and Tobin/ Hansen trust weren’t really opposing parties.
  15. 4/23/19 NWM Nationstar dropped its motion for summary judgment against Jimijack without Jimijack filing an opposition (that Judge Kishner required to be filed by 4/26/19 on her 4/12/19 order continuing the hearing to 5/7/19and convinced Judge Kishner that was the end of the case because she had granted the HOA’s motion for summary judgment (based on no evidence) and Nationstar’s limited joinder (based on no evidence and explicitly contrary to the Hansen deed of trust PUD rider Remedies (f) (NSM 160) that prohibits the use of tender of delinquent HOA assessments as a de facto foreclosure.
  16. 4/23/19 Transcript      Nationstar & Jimijack’s attorneys, Melanie Morgan & Joseph Hong met with Judge Kishner ex-parte after serving notice that the hearing was continued on 4/15/19 (SAO) and 4/22/19 (NTSO) in order to get Nona’s pro se motions and notices stricken unheard from the record to make a fraudulent “settlement”.
  17. 5/23/19 DOT annotated          Neither Nationstar nor Jimijack are parties to $355,000 deed of trust executed & recorded on 5/23/19 by nonparties Joel A Stokes & Civic Financial Services
  18. 4/23/19 video 
  19. 4/23/19 minutes         
  20. 5/1/19 DEED  Joel & Sandra Stokes as trustees of Jimijack dumped Jimijack’s deed by transferring the title into Joel’s name as an individual. Judge Kishner never ruled on Jimijack’s deed that Nona Tobin claimed was inadmissible per NRS 111.345 in her 2/1/17 AACC vs Jimijack and in two declarations under penalty of perjury.
  21. 5/21/19 Transcript      Nationstar attorneys characterize as a settlement agreement between parties Jimijack & Nationstar that excluded parties Nona Tobin & the Gordon B. Hansen Trust from the title fight without the court examining any evidence including not examining the alleged settlement documents.
  22. 5/31/19 NESO Nationstar stipulates that it drops its remaining quiet title claim against Jimijack with prejudice so they both win without the judge ever looking at the evidence or hearing Nona Tobin’s claims against Nationstar & Jimijack.
  23. 6/3/19 Reconvey         Nationstar dba Mr. Cooper falsely claimed to be both the beneficiary and the trustee of the Hansen deed of trust and reconveyed without legal authority the property to Joel A Stokes two days before the quiet title trial (A-15-720032-C) that allegedly was held to determine the title rights between the Gordon B. Hansen Trust and the Jimijack Irrevocable Trust.
  24. Supreme Court case 79295     Online case management system – see how opposing parties were successful in getting me removed as a party by saying I was not aggrieved. See orders SC 19-37846 and SC 20-016346.
  25. Judicial Jiu-jitsu          Youtube channel contains closed-caption videos of all the A-15-720032-C court hearings from 2016-2019 and all the A-19-798990-C court hearings held in 2020 as well as brief videos explaining the trickery employed by the opposing attorneys to suppress Nona Tobin’s evidence and obstruct her access to a fair adjudication of her claims on their merits by an impartial tribunal.

11/10/20  NV AG complaint

12/4/20 rejection of the complaint by the Nevada Attorney General

A Duel to the Death

A Simple Fable: Jimijack and Nationstar weaponize settlement

How a bank and a speculator think a quiet title dispute with me should be settled.

The Scheme

In April, 2019, conspirators Joseph Hong and Melanie Morgan covertly devised a scheme to “resolve all parties’ claims” for the title of 2763 White Sage!

Hong & Morgan didn’t warn Nona Tobin

Hong & Morgan’s Slick Scheme:

A duel between Jimijack and Nationstar


Pistols raised. 

Count 10 paces.

They turn.

Both shoot Nona Tobin.

Hong & Morgan declare the winner!

On 4/23/19, Joseph Hong & Melanie Morgan reported to Judge Kishner that the Jimijack & Nationstar had settled the dispute over who gets the $500,000 house Nona Tobin inherited.

Hint: It’s not Nona.

Judge Kishner blessed the deal!

“Your work is done, Your Honor.

Jimijack and Nationstar have agreed.

Joel Stokes gets the title.

By the way, Nona Tobin is dead.”

Joseph Hong & Melanie Morgan, ex parte on 4/23/19