Tag: motion to disqualify the judge

Court records and documentary evidence to support motion to disqualify Judge Peterson

On 4/26/23, I filed a motion to disqualify Judge Jessica K. Peterson from this case pursuant to NRS 1.230 and NCJC 2.11 on the grounds of actual and implied bias. Judge Peterson, without notice, good cause or an opportunity to oppose, entered a vexatious litigant restrictive order against me on March 28, 2023.

This order was originally issued, unbeknownst to me, at an ex parte hearing held on 2/2/23, at which time, two of my unopposed motions that were scheduled to be heard on 2/28/23, were denied in my absence, after Judge Peterson told the attorneys for Nationstar and Red Rock that they didn’t need to file the required written opposition (EDCR 2.20(e)) to my pending motions because she was going to deny them anyway.

Substantial evidence backing the order is thoroughly documented and hyperlinked in this blog. However, the utilization of a newly available artificial intelligence significantly streamlines and clarifies the data.

CaseText Transcript Analysis assesses the implied bias or a lack of judicial impartiality

Over the past four years, I’ve been a subscriber to a legal research service available on casetext.com. On March 15th, 2023, I upgraded to a tier called Co-counsel, which features an OpenAI-powered document analysis tool. I employed it to evaluate Judge Peterson’s perceived impartiality during court hearings by supplying a set of questions for each session. Find the links below for the responses pertaining to all A-21-828840-C hearings.

August 19, 2021 Casetext Transcript Analysis

November 16, 2021 Casetext Transcript Analysis

January 19, 2022 Casetext Transcript Analysis

July 7, 2022 Casetext Transcript Analysis

February 2, 2023 Casetext Transcript Analysis ex parte hearing

Hyperlinks to all filed A-21-828840-C case documents and 2023 communications with court regarding EDCR 2.20(e), EDCR 2.23(b), NCJC 2.9, and requests to add opposition

PDF LINKCOURT RECORD
2/3/2021Doc ID# 1 Initial Appearance Fee Disclosure
02/03/21Doc ID# 2 Complaint for interpleader
02/03/21Doc ID# 3 Electronic Summons for Nona Tobin, as an individual and as trustee for the Gordon B. Hansen Trust, dated 8/22/08
2/9/2021Doc ID# 7 Notice of Department Reassignment
2/17/2021Doc ID# 8 Affidavit of service-Republic Services
2/17/2021Doc ID# 9 Affidavit of service- Wells Fargo
2/17/2021Doc ID# 10 Affidavit of service Nona Tobin, as an individual via attorney John Thomson
2/17/2021Doc ID# 11 Affidavit of service-Nona Tobin as trustee of the Hansen Trust via attorney John Thomson
2/17/2021Doc ID# 12 Affidavit of service-Nationstar
2/17/2021Doc ID# 13 Disclaimer of interest – Republic Services
3/8/2021Doc ID# 14 Nona Tobin’s Answer, Affirmative Defenses, Answer And Counter-Claim vs. Red Rock Financial Services, Cross-Claims Vs. Nationstar Mortgage LLC And Wells Fargo, N.A., And Motion For Sanctions vs. Red Rock Financial Services And Nationstar Mortgage LLC, and/or Nationstar Mortgage dba Mr. Cooper Pursuant To NRCP 11(b)(1)(2)(3) and/or(4), NRS 18.010(2), NRS 207.407(1), NRS 42.005
3/15/2021Doc ID# 15 Request for Judicial Notice
Nona Tobin’s Request for Judicial Notice of the Complete Official Clark County 2003-2021 Property Records for APN 191-13-811-052
3/22/2021Doc ID# 16 Initial Appearance Fee Disclosure for Nona Tobin an Individual
3/22/2021Doc ID# 17 Nona Tobin’s Third-Party Complaint 1. Abuse Of Process; 2. Racketeering (NRS207.360(9)(18) (29)(30) (35); NRS 207.390, NRS 207.400(1)(2); 3. Fraud NRS 205.330, NRS 205.360, NRS 205.372, NRS 205.377, NRS 205.395, NRS 205.405, NRS 111.175; 4. Restitution And Relief Requested Exceeds $15,000 5. Exemplary And Punitive Damages Pursuant To NRS 42.005, NRS 207.470(1)&(4) 6. Sanctions Pursuant To NRCP 11(b)(1-4); NRPC 3.1, 3.3, 3.4,3.5(b), 4.1, 4.4, 5.1, 5.2, 8.3, 8.4 vs. Steven B. Scow; Brody R. Wight; Joseph Hong; Melanie Morgan; David Ochoa; Brittany Wood
4/4/2021Doc ID# 18 Nona Tobin’s Request for Judicial Notice of Relevant Unadjudicated Civil Claims and Administrative Complaints
4/7/2021Doc ID# 19 Nona Tobin’s Request for Judicial Notice of the Nevada Revised Statutes, Nevada Rules of Civil Procedure, Nevada Rules of Professional Conduct and Sun City Anthem Governing Documents Germane To the Instant Action
4/9/2021Doc ID# 20 Wells Fargo, N.A. and Nationstar Mortgage LLC’s Answer to Red Rock Financial Services’ Complaint for Interpleader (NRCP 22)
4/9/2021Doc ID# 21 Nona Tobin’s Request for Judicial Notice of NRCP 16.1 Disclosures /Subpoena Responses from Discovery in Case A-15-720032-C and Disputed Facts in the Court Record
4/12/2021Doc ID# 22 Nona Tobin’s Amended Motion for an Order to Distribute Interpleaded Proceeds with Interest to Sole Claimant Nona Tobin
4/14/2021Doc ID# 23 CNONCD A-21-828840-C.pdf
4/15/2021Doc ID# 24 Counter-Claimant & Cross-Claimant Nona Tobin’s Motion for Summary Judgment vs. Counter-Defendant Red Rock Financial Services and Cross- Defendants Nationstar Mortgage LLC & Wells Fargo, N.A. and Motion for Punitive Damages and Sanctions Pursuant to NRCP 11(b)(1)(2)(3) and/or(4), NRS 18.010(2), NRS 207.401(1) and/or NRS 42.005
4/16/2021Doc ID# 25 CLERK’s notice of hearing Tobin motion for an order to distribute on 5/18/21
4/16/2021Doc ID# 26 A-21-828840-C.pdf Clerk’s Notice of Nonconforming Document and Curative Action
4/16/2021Doc ID# 27 CLERK’s notice of hearing Tobin MSJ and petition for sanctions 7:39AM
4/16/2021Doc ID# 28 Non-party Red Rock Financial Services, LLC’s Motion to Dismiss Counterclaimant Nona Tobin’s Counterclaim and Petition for Sanctions
4/16/21Doc ID# 29 CLERK’s notice of hearing Non-party Red Rock LLC’s motion to dismiss
4/26/2021Doc ID# 30 Nona Tobin’s Opposition to Red Rock Motion to Dismiss Tobin’s Counter-Claims and Motion for Sanctions Pursuant to NRCP 11(b)(1)(2)(3) and/or (4), NRS 18.010(2), NRS 207.40(1), NRS 42.005
4/26/2021Doc ID# 31 Wells Fargo, N.A. and Nationstar Mortgage LLC’s Limited Opposition to Defendant Nona Tobin’s Motion for an Order to Distribute Interpleaded Proceeds
4/27/2021Doc ID# 32 Non-party Red Rock Financial Services, LLC’s rogue Joinder to Wells Fargo, N.A. and Nationstar Mortgage LLC’s Limited Opposition to Defendant Nona Tobin’s Motion for an Order to Distribute Interpleaded Proceeds
4/29/2021Doc ID# 33 Red Rock Financial Services’ Opposition to Nona Tobin’s Motion for Summary Judgment
5/3/2021Doc ID# 34 Wells Fargo, N.A. And Nationstar Mortgage LLC’s Joinder To Red Rock Financial Services, LLC’s Motion To Dismiss Counterclaimant Nona Tobin’s Counterclaim And Petition For Sanctions
5/4/2021Doc ID# 35 Nona Tobin’s Reply To Nationstar’s & Wells Fargo’s Opposition To Tobin’s Motion To Opposition To Tobin’s Motion To Distribute Proceeds And To Their Untimely Joinder To Red Rock’s Motion To Dismiss And Tobin’s Reply To Support Tobin’s Motion For Summary Judgment Vs. Nationstar & Wells Fargo
5/5/2021Doc ID# 36 Wells Fargo, N.A. And Nationstar Mortgage LLC’s Joinder To Red Rock Financial Services’ Opposition To Nona Tobin’s Motion For Summary Judgment
5/9/2021Doc ID# 37 Nona Tobin’s Reply To Red Rock’s Joinder To Nationstar’s & Wells Fargo’s Opposition To Tobin’s Motion To Distribute Proceeds
5/9/2021Doc ID# 38 Nona Tobin’s Reply To Red Rock’s Opposition To Motion For Summary Judgment And Motion To Amend Third Party Complaint
5/11/2021Doc ID# 39 Non-Party Red Rock LLC’s Rogue Reply In Support Of Its Motion To Dismiss Counterclaimant Nona Tobin’s Counterclaim And Petition For Sanctions
6/22/2021Doc ID# 40 NOTICE OF APPEARANCE – JOHN THOMSON FOR NONA TOBIN
6/26/2021Doc ID# 41 STIPULATION AND ORDER – MOVE EVIDENTIARY HEARING TO 8/18/21by stipulation, changed manually by the court to 8/19/21
7/27/2021Doc ID# 42 NOTICE OF ENTRY OF STIPULATION AND ORDER – MOVE EVIDENTIARY HEARING TO 8/19/21
8/19/2021Casetext.com Co-counsel OpenAI-enabled transcript analysis of the 8/19/21 hearing utilized to assess Judge Peterson’s appearance of bias against Tobin and to summarize the hearing
8/19/2021Transcript of Proceedings 8/19/21
9/10/2021Doc ID# 43 “ORDER & JUDGMENT ON PLAINIFF (SIC) RED ROCK FINANCIAL SERVICES, LLC’S MOTION TO DISMISS COUNTERCLAIMANT NONA TOBIN’s COUNTERCLAIM AND PETITION FOR SANCTIONS AND DEFENDANTS/ COUNTERCLAIMANT NONA TOBIN’s MOTION FOR SUMMARY JUDGEMENT AND MOTION FOR SANCTIONS”
9/10/2021Doc ID# 44 Notice of Entry of Order & Judgment granting non-party Red Rock LLC’S rogue Motion to Dismiss Tobin’s Counterclaim, Petition for Sanctions And Tobin’s Motion For Summary Judgement against counter-defendant Red Rock
9/15/2021Substitution of Attorneys for Tobin from John Thomson to Taylor Simpson, Suzanne Carver, P. Kerr Sterling
10/8/2021Motion for Reconsideration
10/11/2021Notice of Hearing Motion for Reconsideration
10/12/2021[49] Notice of Voluntary Dismissal of Third-Party Claims Without Prejudice
10/13/2021Doc ID# 50 Notice of Voluntary Dismissal Without Prejudice
10/13/2021Doc ID# 51 Notice of Entry of Order
10/21/2021Doc ID# 52 Wells Fargo, N.A. and Nationstar Mortgage LLC’s Opposition to Nona Tobin’s Motion for Reconsideration
10/22/2021Doc ID# 53 Non-party Red Rock Financial Services LLC’s rogue Opposition to Motion for Reconsideration of Order Dismissing Nona Tobin’s Counterclaim and Petition for Sanctions
10/29/2021Doc ID# 54 Tobin Reply in Support
11/9/2021Doc ID# 55 Notice of Change of 11/16/21 Hearing of all matters from 10 AM to 8 AM. Bluejeans link provided. Parties were asked to contact the court if unavailable.
11/9/2021Doc ID# 56 Susan Carver Motion for Withdrawal as Tobin’s attorney oral argument requested
11/9/2021Doc ID# 57 DECLARATION OF NONA TOBIN IN SUPPORT OF MOTION TO RECONSIDER ORDER ENTERED SEPTEMBER 10, 2021
11/10/2021Doc ID# 58 Ex Parte Application for an Order Shortening Time
11/10/2021Doc ID# 59 Clerk’s Notice of Hearing Tobin motion for reconsideration on 11/16/21 @ 10 AM
11/10/2021Doc ID# 60 Nona Tobin’s Three-Day Notice of Intent to Take Default vs. Wells Fargo, N.A. as to Tobin’s Cross-Claims Filed on March 8, 2021
11/10/2021Doc ID# 61 Tobin Notice of Intent to Take Nationstar’s Default
11/11/2021Doc ID# 62 Akerman Motion to Withdraw as Counsel for Nationstar and Wells Fargo
PNG #62 shows Akerman knew it had to get out because Nationstar and Wells Fargo were in default for never answering my 3/8/21 cross-claims. 362 also show that Nationstar claims here to be the servicer for Wells Fargo which contradicts its claims on different dates. The exit and the fact that there was no IAFD and no SUBT shows Wells Fargo did not hire them and maybe Nationstar didn’t either.
11/12/2021Doc ID# 63 Clerk’s Notice of 12/15/21 Hearing of Carver’s motion on Order Shortening Time
11/14/2021Doc ID# 64 Declaration of Nona Tobin In Support Of Motion For P. Sterling Kerr To Withdraw As Counsel To Allow Her Return To Pro Se With No Hearing – PNG #64 show
11/15/2021Doc ID# 65 Clerk’s Notice of Hearing the Akerman Motion to Withdraw on 12/22/21
11/15/2021Doc ID# 66 Nationstar and Wells Fargo’s Motion to Strike Tobin’s notice of intent to take their default for failure to file a timely (NRS 12(a)(1)(B)) responsive pleading to my 3/8/21cross-claim and petition for sanctions. Note that on 5/3/21 Akerman did file an untimely (EDCR 2.20(d)) joinder to non-party Red Rock LLC’s rogue and untimely ((NRS 12(a)(1)(B)) motion to dismiss and also note that since Akerman never filed a mandatory counterclaim for the interpleaded proceeds for either of the banks (NRCP 13(a)(1)) the banks should have filed a disclaimer of interest and withdrawn from the case in February 2021 and not obstructed my asserting my claim for funds in which they have no interest.
11/15/2021Doc ID# 67 Clerk’s Notice of Hearing
11/16/21Casetext.com Co-counsel OpenAI-enabled transcript analysis of the 11/16/21 hearing utilized to assess Judge Peterson’s appearance of bias against Tobin and to summarize the hearing
11/16/2021Doc ID# 74 Recorders Transcript of Hearing Re: Defendant/ Counterclaimant’s Motion for Reconsideration 11/16/21
11/17/2021Doc ID# 68 Order to Withdraw as Attorney of Record
11/19/2021Doc ID# 69 Notice of Entry of Order
11/30/2021Doc ID# 70 Order Clarifying Sept. 10th, 2021 Order and Mooting Notice of Default and Motion to Strike
11/30/2021Doc ID# 71 Order Denying Nona Tobin’s Motion to Reconsider of Order Dismissing Nona Tobin’s Counterclaim and Petition for Sanctions and Defendant/Counterclaimant Nona Tobin’s Motion for Summary Judgment and Motion for Sanctions
11/30/2021Doc ID# 72 Notice of Entry of Order Clarifying September 10, 2021 Order And Mooting Notice of Default and Motion to Strike
11/30/2021Doc ID# 73 Denial of Motion to Reconsider
12/14/2021Doc ID# 75 Nona Tobin’s Motion for an Evidentiary Hearing to Set Aside Orders and for Sanctions Pursuant to NRCP 60(B)(3) and (D)(3), NRS 18.010(2) and EDCR 7.60 (1) and (3)
12/14/2021Doc ID# 76 Notice of Hearing
12/28/21Doc ID# 77 Non-party Red Rock Financial Services LLC’s rogue Opposition to Nona Tobin’s Motion for an Evidentiary Hearing to Set Aside September 10, 2021 Order and November 30, 2021 Orders Pursuant to NRCP 60(b)(3) (Fraud) and NRCP 60 (d)(3) (Fraud on the Court) and Motion for Attorneys’ Fees and Costs Pursuant to EDCR 7.60(b)(1) and (3), NRS 18.010(2); and, Countermotion for Abuse of Process; For a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
12/29/2021Doc ID# 78 Insufficient Notice of Appearance “Aaron D. Lancaster, Esq., of Troutman Pepper LLP, will appear as Counsel for Defendant, Wells Fargo, N.A. and Nationstar Mortgage LLC.”
No IAFD. No SUBT. No Signature from Wells Fargo, Nationstar, or Akerman.
“Gary Schnitzer, of Kravitz Schnitzer Johnson Watson & Zeppenfeld, Chtd., the office of which is located within the State of Nevada at 8985 S. Eastern Avenue, Suite 200, Las Vegas, Nevada 89123, has agreed to serve as the Designated Attorney for service of papers, process, or pleadings required to be served on the attorney, Aaron D. Lancaster, Esq., including service by hand delivery or facsimile transmission, as Troutman Pepper LLP does not maintain an office in the State of Nevada.”
12/29/2021Doc ID# 79 Wells Fargo and Nationstar’s Joinder to Defendant Red Rock Financial Services LLC’s Opposition to Nona Tobin’s Motion for an Evidentiary Hearing to Set Aside September 10, 2021 Order and November 30, 2021 Orders Pursuant to NRCP 60 (b)(3) (Fraud) and NRCP 60 (b)(3) (Fraud on the Court) and Motion for Attorneys’ Fees and Costs Pursuant to EDCR 7.60 (1) and (3) NRS 18.010 (2); and Countermotion for Abuse of Process; for a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
1/10/2022Doc ID# 80 Nona Tobin’s Reply to Red Rock Financial Services LLC’s Opposition to Nona Tobin’s Motion for an Evidentiary Hearing to Set Aside September 10, 2021 Order and November 30, 2021 Orders Pursuant to NRCP 60(b)(3) (Fraud) and NRCP 60(b)(3) (Fraud on the Court) and Motion for Attorneys’ Fees and Cots Pursuant to EDCR 7.60(1) and (3), NRS 18.010(2); and, Countermotion for Abuse of Process for a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
1/10/2022Doc ID# 81 Nona Tobin’s Reply To Nationstar’s And Wells Fargo’s Joinder And Countermotions For Attorney Fees And A Vexatious Litigant Order
1/11/2022Doc ID# 82 Notice of Change of Hearing
1/14/2022Doc ID# 83 Order Granting Akerman s Motion to Withdraw as Counsel for Wells Fargo, N.A. and Nationstar Mortgage LLC
1/19/2022Doc ID# 84 Notice of Entry of Order Granting Akerman s Motion to Withdraw as Counsel for Wells Fargo, N.A. and Nationstar Mortgage LLC
1/19/22Casetext.com Co-counsel OpenAI-enabled transcript analysis of the 11/16/21 hearing utilized to assess Judge Peterson’s appearance of bias against Tobin and to summarize the hearing
1/24/2022Doc ID# 85 Recorders Transcript of Hearing Re: 01/19/22
4/26/2022Doc ID# 86 Notice of Appearance No IAFD. No SUBT. No authorization by Nationstar or Wells Fargo. Aaron Lancaster notices begin “VANESSA M. TURLEY, of Troutman Pepper LLP, is admitted and authorized to practice in this Court, and will appear as Counsel for Defendant, Wells
Fargo, N.A. and Nationstar Mortgage LLC.”
5/25/2022Doc ID# 88 Order Denying Nona Tobin’s Motion For An Evidentiary Hearing To Set Aside 9/10/21 Order And 11/30/21 Orders Pursuant To NRCP 60(b)(3)(Fraud) And NRCP 60(d)(3)(Fraud On The Court) And Motion For Attorneys’ Fees And Costs Pursuant To EDCR 7.60(1) And (3), NRS 18.010(2); And, Denying non-party Red Rock LLC’s 12/28/21 Countermotions For Abuse Of Process & Denying non-party Red Rock LLC’s motion For A Vexatious Litigant Restrictive Order Against Nona Tobin And denying For Attorney Fees Costs
5/25/2022[89] Notice of Entry of Order Denying Nona Tobin’s Motion For An Evidentiary Hearing To Set Aside 9/10/21 Order And 11/30/21 Orders Pursuant To NRCP 60(b)(3)(Fraud) And NRCP 60(d)(3)(Fraud On The Court) And Motion For Attorneys’ Fees And Costs Pursuant To EDCR 7.60(1) And (3), NRS 18.010(2); And, Denying non-party Red Rock LLC’s 12/28/21 Countermotions For Abuse Of Process and Denying non-party Red Rock LLC’s motion For A Vexatious Litigant Restrictive Order Against Nona Tobin And denying For Attorney Fees Costs
5/30/2022[90] Second Amended Motion for an Order to Distribute Interpleaded Funds with Interest to Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant to NRS 18.010(2) and EDCR 7.60(b)(1) and (3) and Motion to Correct Nunc Pro Tunc Notices of Entry of Orders Entered on November 30, 2021 and May 25, 2022
5/30/2022Doc ID# 91 Exhibits To Second Amended Motion For An Order To Distribute Interpleaded Funds With Interest To Sole Claimant Nona Tobin And Motion For Attorney Fees And Costs Pursuant To NRS18.010(2) And EDCR7.60(b)(1) And (3) And Motion To Correct Nunc Pro Tunc Notices Of Entry Of Orders Entered On 11/30/21 And 5/25/22
5/31/2022Doc ID# 92 Clerk’s Notice of Hearing
6/13/2022Doc ID# 93 Non-party Red Rock Financial Services LLC’s Opposition to Nona Tobin’s Second Amended Motion for An Order to Distribute Interpleaded Funds With Interest to Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant to NRS 18.010(2) and EDCR 7.60(b)(1) and (3) and Motion to Correct Nunc Pro Tunc Notices of Entry of Orders Entered on November 30, 2021 and May 25, 2022; and Renewed Countermotion for Abuse of Process; For a Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
6/21/2022Doc ID# 94 Reply to Non-Party Red Rock LLC’s Opposition to Tobin’s Second Amended Motion For An Order To Distribute Interpleaded Funds With Interest To Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant to NRS 18.010(2) and EDCR 7.60(B)(1) and (3)
6/22/2022Doc ID# 95 Nona Tobin’s Reply to Non-Party Opposition to Motion To Correct Notices Of Entry Of Three Orders
6/27/2022Doc ID# 96 Response to Non-Party Red Rock Financial Services, LLC’s Countermotion for a Restrictive Vexatious Litigant Order Against Nona Tobin and Motion for Attorney Fees and Costs and Nona Tobin’s Counter-Motion to Adopt Tobin’s Proposed Final Judgment Order
6/30/2022Doc ID# 97 Notice of Appellate Decision
7/7/2022Casetext.com Co-counsel OpenAI-enabled transcript analysis of the 11/16/21 hearing utilized to assess Judge Peterson’s appearance of bias against Tobin and to summarize the hearing
8/29/2022Doc ID# 98 Notice of Tobin Petition For Writ Of Prohibition And Or Mandamus
9/23/2022Doc ID# 99 Amended Notice of the Filing of a NRAP 40 Motion for Rehearing of Petition for a Writ of Prohibition and/or Mandamus
10/5/2022Doc ID# 100 Motion for Rehearing Petition for Writ of Prohibition and /or Mandamus
11/28/2022Doc ID# 101 Notice of NRAP 40a Petition For En Banc Reconsideration 85251
12/19/2022Doc ID# 102 Request for Judicial Notice Verified Complaints of Attorney Misconduct filed with the State Bar of Nevada vs. Brittany Wood
12/19/2022Doc ID# 103 Tobin Motion for An Order to Show Cause Why Written Findings of Attorney Misconduct Should Not Be Forwarded To The State Bar of Nevada
12/19/2022Doc ID# 104 Request for Judicial Notice Verified Complaint of Attorney Misconduct Filed with The State Bar of Nevada Vs. Steven Scow
12/19/2022Doc ID# 105 Request for Judicial Notice Verified Complaints of Attorney Misconduct Filed with the State Bar of Nevada vs. Melanie Morgan, Esq. (SBN 8215), Akerman, LLP; and Wright, Finlay, Zak, LLP, and Draft Alternative Civil Action
12/19/2022Doc ID# 106 Request for Judicial Notice Verified Complaint of Attorney Misconduct Filed With The State Bar of Nevada Vs. Joseph Y. Hong
12/19/2022Doc ID# 107 Request for Judicial Notice Verified Complaints of Attorney Misconduct Filed With The State Bar of Nevada Vs. David Ochoa, Esq. (SBN 10414) and Adam Clarkson, Esq.
12/20/2022Doc ID# 108 Corrected Motion for an Order to Show Cause Why Written Findings of Attorney Misconduct Should Not be Forwarded to the State Bar
12/20/2022Doc ID# 109 Clerk’s Notice of 2/2/23 Hearing of Doc #102, Tobin’s 12/19/22 RFJN vs Joseph Hong uninvestigated complaint vs. Brittany Wood and draft civil action that will be necessary if this court chooses not to act
12/20/2022Doc ID# 110 Clerk’s Notice of 2/2/23 Hearing of Doc103 Tobin’s 12/19/22 MOSC why written findings of attorney misconduct should not be forwarded to the State Bar
12/20/2022Doc ID# 111 Clerk’s Notice of 2/2/23 Hearing of Doc #106, Tobin’s 12/19/22 RFJN vs. uninvestigated complaint vs. Brittany Wood and draft civil action that will be necessary if this court chooses not to act
1/3/2023Doc ID# 112 1) Motion to Withdraw Tobin’s Motion for an Order to Show Cause Why Written Findings of Attorney Misconduct Should Not Be Forwarded to the State Bar And 2) Motion to Withdraw Tobin’s Counter-Claims / Cross-Claims vs. Red Rock, Nationstar and Wells Fargo
3) Motion to Modify Grounds for Tobin’s Petitions for Sanctions vs. Red Rock and Nationstar to Include NRS 357.040(1(a),(b),(i), and NRS 199.210, NRS 205.0824 and NRS 205.0833, and NRS 41.1395 And
4) Motion to Adopt Tobin’s Proposed Final Judgment Order (as amended on 1/3/23)
It allowed the attorneys to walk away and put the entire cost onto Red Rock and Nationstar. It also moved the punitive damages from being payable to me to being payable to the State of Nevada through the courts via the false claims act without me having to file a whistleblower action.
1/3/2023Doc ID# 113 Red Rock Response to Tobin Motion for an Order to Show Cause Why Written Findings of Attorney Misconduct Should Not Be Forwarded to the State Bar.
#
1/6/2023Doc ID# 114 Clerk’s Notice of 2/8/23 Hearing in Chambers of #113 Tobin’s 1/03/23 motions
1/9/202301/09/2023 Order Doc ID# 115 Order Granting in Part and Denying in Part Nona Tobin’s Second Amended Motion for an Order to Distribute Interpleaded Funds with Interest to Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant to NRS 18.010(2) and EDCR 7.60(b)(1) and (3) and Motion to Correct Nunc Pro Tunc Notices of Entry of Orders Entered on November 30 2021 and May 25 2022 and Granting in Part Red Rock Financial Services’ Countermotion for Abuse of Process; for a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
1/10/2023Notice of Entry of Order Doc ID# 116
1/16/2023Doc ID# 117 Order Granting in Part and Denying in Part Nona Tobin’s Second Amended Motion for an Order to Distribute Interpleaded Funds with Interest to Sole Claimant Nona Tobin and Motion for Attorney Fees and Costs Pursuant to NRS 18.010(2) and EDCR 7.60(b)(1) and (3) and Motion to Correct Nunc Pro Tunc Notices of Entry of Orders Entered on November 30 2021 and May 25 2022 and Granting in Part Red Rock Financial Services’ Countermotion for Abuse of Process; for a Vexatious Litigant Restrictive Order Against Nona Tobin and for Attorney Fees and Costs
1/17/2023Doc ID# 118 Notice of Entry of Corrected 1/9/23 Order amended solely to correct the 1/9/23 order to state that Tobin had responded, refused to sign for the reasons identified in the opposition attached to the corrected order. PNG # 118 shows neither 1/9/23 nor 1/16/23 were “restrictive orders” as misrepresented in the 3/28/23 order.
1/17/2023Doc ID# 119 Red Rock Financial Services’ Response/Opposition to (1) Motion to Withdraw Tobin’s Motion for an Order to Show Cause Why Written Findings of Attorney Misconduct Should Not be Forwarded to the State Bar; (2) Motion to Withdraw Tobins Counter-Claims and Cross-Claims vs. Red Rock, Nationstar and Wells Fargo; (3) Motion to Modify Grounds for Tobin’s Petitions for Sanctions vs. Red Rock and Nationstar to include NRS 357.0401(a), (b), (i) and NRS 199.210, NRS 205.0824 and NRS 205.0833, and NRS 41.1395; and (4) Motion to Adopt Tobin’s Proposed Final Judgment Order
1/23/2023Doc ID# 120 Tobin 1/23/23 Motion to Reconsider 1/16/23 Order and Renewed Motion to Strike Non-Party Red Rock Financial Services LLC’s Rogue Filings PNG # 120 shows my good faith intent to resolve the matter without appeal and without the court acting outside its jurisdiction and without forcing a multitude of additional cases to address the number of attorneys who had lied to the court to cover up the criminal activities of their clients.
1/24/2023Doc ID# 121 Clerks’ Notice of 2/28/23 Hearing Tobin Motion to Reconsider 1/16/23
Order and Renewed Motion to Strike Non-Party Red Rock Financial Services LLC’s Rogue
Filings. Note this would result in adopting Tobin’s unopposed 6/27/22 judgment order.
1/24/2023Doc ID# 122 Wells Fargo and Nationstar’s Joinder to Red Rock Financial Services’ Response//Opposition to (1) Motion to Withdraw Tobin’s Motion for an Order to Show Cause Why Written Findings of Attorney Misconduct Should Not Be Forwarded to The State Bar; (2) Motion to Withdraw Tobin’s Petitions For Sanctions VS. Red Rock, Nationstar to Include NRS 357.0401(A), (B), (I) and NRS 199.210, NRS 205.0824 and NRS 205.0833, and NRS 41.1395; and (4) Motion to Adopt Tobin’s Proposed Final Judgment Order
1/31/2023Doc ID# 123 Tobin’s Reply to Red Rock’s Opposition to Tobin’s Four 1/03/23 Motions to Amend Final Order
2/2/2023Casetext.com Co-counsel OpenAI-enabled transcript analysis of the 11/16/21 hearing utilized to assess Judge Peterson’s appearance of bias against Tobin and to summarize the hearing
2/2/2023Minutes published on the court website that were NEVER SERVED on the parties inaccurately describe that Judge Peterson was alone in Chambers at 11:15 AM when she denied the Tobin’s 1/23/23 motion to reconsider “- The Court having advanced this hearing to 2.-02-23 and following review of the papers and pleadings on file herein, COURT ORDERED, Defendant Nona Tobin’s Motion to Reconsider 1/16/23 Order and Renewed Motion to Strike Non-Party Red Rock Financial Services LLC’s Rogue Filings, DENIED.” Note that these motions were on the docket for 2/28/23 by CNOH Doc No. 114 and Judge Peterson actually denied these motions at a hearing that was held ex parte after Tobin requested on 1/23/23 that it be vacated as moot. See PNG 230123 request to vacate.
Note that there are no minutes regarding the vexatious litigant restrictive order. There are no minutes that of the ex parte hearing at all. There are no minutes that show the three items that were on the docket were acted on, i.e. Docs. 102, 103, and 106,12/19/22 MOSC and the RFJNs for Wood and Hong.
2/2//2023I did not anticipate that the court would so aggressively deprive me of the most minimum due process that could be reasonably expected, especially when so unreasonably restricting my fundamental rights to access to any impartial tribunal, and yet it got progressively worse until by April the court was neither accepting nor rejecting just ignoring and letting time pass.
AS to the 2//2/23 ex parte hearing, it was completely improper and unnoticed.
1. I did not receive a phone call that the court claims was made to me from the ex parte hearing. I do not have any record that I missed such a call. I received no voice mail from the court. Like everything I say, I can say it under oath. I don’t know who at the court can.
2. I requested on 1/23/23 that the 2/2/23 hearing be vacated as moot.
3. The court did not address the three unopposed items actually docketed for 2/2/23. Neither Joseph Hong nor Brittany Wood were present for the hearing that was supposed to be about the motion for an order to show cause why written findings of attorney misconduct should not be forwarded to the State Bar and the RFJN of my uninvestigated complaints vs. them. There are no minutes that the court denied this, but when (2/21/23) I turned in a proposed order granting my 12/19/22 MOSC as unopposed, I was ordered to stop and threatened with an order to show cause why I shouldn’t be held in contempt.
2/2/2023Minutes published on the court website that were served See PNG 230202 4:44PM minutes notice served on the parties inaccurately describe Judge Peterson denied Tobin’s 1/03/23 four motions in chambers alone (scheduled to be decided on 2/8/23 by CNOH #114) when actually these motions were denied at a hearing that was held ex parte after Tobin requested on 1/23/23 that it be vacated as moot. See PNG 230123 request to vacate. Why were Steven Scow or Vanessa Turley to be present when the RFJN about them were not on the docket, and Turley’s motion for Nationstar for a vexatious litigant restrictive order against me, filed on 1/24/23, shouldn’t have been considered without considering my opposition, that I timely filed, four hours after the ex parte hearing I didn’t know about. See Doc No. 125 filed a 3:46 PM
2/2/2023Doc ID# 124 Declaration of Steven B. Scow in Support of Attorneys’ Fees Awarded to Red Rock Financial Services
2/2/2023Doc ID# 125 Tobin’s Reply to Nationstar’s Opposition and Vexatious Litigant Motion
2/10/2023Gmail Tobin to DC8inbox and opposing counsels entitled “Order filed pursuant to EDCR 2.23(b)” as time to file written opposition had passed so pursuant to ECCR 2.23(b) I filed an order granting unopposed 6/27/22 and 1/23/22 motions (EDCR 2.20(e))
2/10/2023Proposed order filed granting unopposed 6/27/22 and 1/23/22 motions (EDCR 2.20(e))
2/12/2023Doc ID# 126 Tobin Opposition To Scow Declaration ISO Attorney Fees
2/15/2023Gmail from court returned Tobin’s proposed order as it had been denied ex parte
2/16/23Gmail Scow to Tobin to say that court asked him to prepare the order from the 2/2/23 ex parte hearing
2/16/23Proposed order denying all Tobin’s motions even if unopposed
2/16/23Court returned Order without a reason specified
2/16/23Gmail Tobin to court resubmitting proposed order showing why not denying her motions was an abusive means to prevent appeal.
2/16/23Gmail court to Tobin resubmission returned within 20 minutes
2/16/2023Doc ID# 127 Memorandum of Costs and Disbursements
Red Rock Financial Services’ Memorandum of Costs and Disbursements as Supplement to Declaration of Steven B. Scow
2/20/2023Doc ID# 128 Reply to Opposition
Tobin Reply in Opposition to Red Rock 2/16/23 Memo of Fees and Costs
2/21/23Gmail Tobin to court submitting Tobin’s 12/19/22 MOSC pursuant to EDCR 2.20(e)
2/21/23Proposed order granting 12/19/22 MOSC pursuant to EDCR 2.20(e)
2/21/23Gmail Court to Tobin threatening an order to show cause why not to be held in contempt for submitting draft order per EDCR 2.23(b) granting 12/19/22 MOSC pursuant to EDCR 2.20(e)
2/21/23Gmail Tobin to court submitting Tobin’s 12/19/22 MOSC pursuant to EDCR 2.20(e)
2/21/23Proposed order granting 12/19/22 MOSC pursuant to EDCR 2.20(e)
2/21/23Gmail Tobin to Assistant Bar Counsel Pattee begging him to voluntarily lift the onerous requirement to get a court order with written findings before the State Bar Ethics & Disciplinary panels will investigate to enforce the rules of professional conduct. I tried to impress upon him that without the support of the State Bar and the other administrative enforcement agencies the citizens of Nevada do not have a chance in the courts against the big monied interests who pay attorneys who are willing to lie and cheat to win. I got no response. Not even an acknowledgement of receipt.
2/21/202310:41 AM Court to Tobin “The next submission into OIC will result in the court
issuing an order to show cause as to why you should not be held in contempt.”
2/21/23Gmail Court to Tobin threatening an order to show cause why not to be held in contempt for submitting draft order per EDCR 2.23(b) granting 12/19/22 MOSC pursuant to EDCR 2.20(e)
2/21/23Gmail 9:59 AM Tobin to court entitled “Order granting Tobin’s 1/19/22 MOSC pursuant to EDCR 2.20(e)” explaining that the court minutes say that the court denied my motion to withdraw the unopposed 12/19/22 MOSC
2/21/23Proposed order submitted pursuant to EDCR 2.23(b) to adopt as unopposed per EDCR 2.20(e) . there were no minutes that my 12/19/22 MOSC why written findings of attorney misconduct should not be forwarded to the State Bar was denied on 2/2/23
3/3/2023Doc ID# 129 Court Recorders Invoice for Transcript Ex parte 2/2/23 hearing
2/2/2023 recording fee and transcript
3/3/2023Doc ID# 130 Recorders Transcript of 2/2/23 ex parte unnoticed Hearing was added to court record on 3/3/23
3/3/2023Doc ID# 129 Court Recorders Invoice for Transcript Ex parte 2/2/23 hearing
2/2/2023 recording fee and transcript
3/3/2023Doc ID# 130 Recorders Transcript of 2/2/23 ex parte unnoticed Hearing was added to court record on 3/3/23
3/24/202311:53AM Gmail from Steven Scow’s legal assistant giving me the proposed order out of the ex parte hearing that was delivered to the court at the same time. I didn’t open this Friday afternoon email until Monday since I expected I would have the normal ten days to review or oppose or sign off as to form and content as is standard practice under EDCR.
3/27/23I only had an opportunity to read through the proposed order on Monday and I used the MS word editor to track my comments, but I had guests visiting from out of the country.
3/28/2023Order Declaring Nona Tobin a Vexatious Litigant, Order Denying Defendant Nona Tobin’s: (1) Motion to Withdraw Tobin’s Motion for Order to Show Cause why Written Findings of Attorney Misconduct Should no be Forwarded to the State Bar; (2) Moton to Withdraw Tobin’s Counter- Claims and Cross-Claims vs Red Rock, Nationstar and Wells Fargo/ (3) Motion to Modify Grounds for Tobin’s Petitions for Sanctions vs Red Rock and Nationstar to Include NRS 357.404(1)(A), and NRS 199.210, NRS 205.0824 and NRS 205.0833, and NRS 41.1395 and (4) Motion to Adopt Tobin’s Proposed Final Judgment Order and Order Denying Defendant Nona Tobin’s: Motion to Reconsider 1/16/23 Order and Renewed Motion to Strike Non-Party Red Rock Financial Services LLC’s Rogue Filings
3/28/2023Doc ID# 132
Notice of Entry of Order
3/28/2023Order Declaring Nona Tobin a Vexatious Litigant, Order Denying Defendant Nona Tobin’s: (1) Motion to Withdraw Tobin’s Motion for Order to Show Cause why Written Findings of Attorney Misconduct Should no be Forwarded to the State Bar; (2) Moton to Withdraw Tobin’s Counter- Claims and Cross-Claims vs Red Rock, Nationstar and Wells Fargo/ (3) Motion to Modify Grounds for Tobin’s Petitions for Sanctions vs Red Rock and Nationstar to Include NRS 357.404(1)(A), and NRS 199.210, NRS 205.0824 and NRS 205.0833, and NRS 41.1395 and (4) Motion to Adopt Tobin’s Proposed Final Judgment Order and Order Denying Defendant Nona Tobin’s: Motion to Reconsider 1/16/23 Order and Renewed Motion to Strike Non-Party Red Rock Financial Services LLC’s Rogue Filings
3/28/2023Doc ID# 132
Notice of Entry of Order
3/28/23230328 gmail I sent an email to the court requesting 30 days to write an opposition considering that Scow got 50 days to draft an rder that was imposed unfairly ex parte for no just cause. but I got no answer.
3/28/23230328 gmail 11.02 The court acknowledged receipt that it was submitted to the dept. 8.
3/31/233/31/23 11:59 I submitte the first wo page I noticed were missing from the edited version of the order zi had submitted on 3/28/23 w my request for 30 days with the expectation that it would have been attached to the order as my opposition to the 1/9/23 order was attached to thit and became the 1/1623 order.. That didn’t happen in either case. The 3/28/23 order continuted uncorrected .proposed order
4/5/23230405 3.52 PM gmail to ccourt entitled corrections to 3/28/23 order to attach opposition erroneously or intentionally omitted. The court ignoed it . Did not respond.corrected 230328 I re submitted a
4/5/23230405 original plus corrected order to attach my ipposition is 52-pages. see the PNG.Sig pg. It shows the extreme difference in perspective between how I see this dispute and how Judge zzpeterson sees it. I see that my claims have never been heard on their merits and I am fighting constantly to get my evidence before a judge. Judge Peterson thinks I am judge beating a dead horse religating the same old thing that I derserve to keep losing.
4/13/23on 4/13/ I resubmitted the 4/5/23 corrections230405 corrected 23032 I didn’t hear anything from the court fofrom 4/523 to 4/13/23 so I re-submitted it and said i can;t appeal this order without my oppposition noted in the record more clearly,
4/13/234/13/23 6:06 PM Gmail Court to Tobin Proposed Order has been submitted. my resubmission was immediately acknoeldged by the court’s chatbot rsponder, but nothing ever came from Dept. 8 after 3/28/23.
4/19/234:00 PM Tobin to Clerk for Chief Judge ‘Could you please tell me if Judge Weise has seen this?
4/19/23230419 4.00 pm six days lay I contacted the clerk of the Chief Judge and ssked if my proposed corrections to the order had been seen by the Chief Judge.
4/20/23Apr 20, 2023 at 3:14 PM Gmail Tobin to Court The response came back the next day saying that the Chief judge was only responsible for reviewing a filing if Iinitiated a complaint , but any filing into the case was Dept. 8’s responsibility.
4/20/23230420 3.20 pm court ack so I resubmitted it to Dept 8 and predictabily it has been ignored ever since.