Steven Scow – SCA Strong

Plaintiff Nona Tobin repeats, re-alleges, and incorporates herein by this reference the allegations hereinabove inclusively as though set forth at length and in full herein.

Defendants, and each of them, misappropriated or otherwise improperly took possession of monies which belonged to or should have gone to Plaintiff.

As a direct, proximate, and foreseeable result of Defendants’ acts, 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 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 Plaintiff to secure the services of an attorney, and Plaintiff is entitled to recover fees and costs incurred herein as damages.

2/3/21 Red Rock Financial Services Interpleader Complaint electronically issued without notice to defendants

Case was assigned to Judge Kishner Dept 31

Judge Kishner immediately recused herself “in order to avoid the appearance of impartiality“

link to 2/9/21 minutes

There was no electronic service of the recusal as Steven Scow did not put any defendants’ service contacts into Odessey

2/9/21 Department reassignment from Judge Kishner (Dept. 31) to Judge Jessica K. Peterson (Dept. 8) occurred without notice

There was no electronic service of the notice of departmental reassignment as Steven Scow did not put any defendants’ service contacts into Odessey.

Link to 2/9/21 NODR notice of department reassignment

Service on Nona Tobin, as an individual

link to affidavit of service on Nona Tobin, an individual

Serving Nona Tobin as an individual was necessary because Nona Tobin, as an individual, has THE ONLY recorded claim for the proceeds.

Link to Nona Tobin’s 3/28/17 deed, as an individual,

Service on Nona Tobin, as a trustee

Unnecessary because Steven scow knows the Hansen Trust was closed in 2017.

link to affidavit of service on Nona Tobin, as trustee

Nona Tobin, as the trustee of the Gordon B. Hansen Trust, dated 8/22/08, does not have a competing claim with herself as an individual. The Hansen Trust was closed in 2017 when the title was transferred to Nona Tobin, an individual, as the sole beneficiary.

Page 2 of Nona Tobin’s 3/28/17 deed shows that the Hansen Trust has been closed

Service on Wells Fargo

Service was unnecessary as Wells Fargo released its 5/10/07 lien on 3/12/15

Link to Wells Fargo’s 3/12/15 Substitution and Reconveyance

Wells Fargo’s Registered agent Corporation Service Company, was served in Carson City, 112 North Curry Strret, 89703

link to affidavit of service on Wells Fargo

Obviously, Wells Fargo will not file a claim for the excess proceeds.

Service on Nationstar

Unnecessary because Nationstar (albeit for a corrupt intent and with no legal authority) released the lien of the disputed Hansen deed of trust on 6/3/19

Link to the 6/3/19 release of the lien of the Hansen deed of trust

Obviously, Nationstar will not file a claim for the excess proceeds.

Nationstar’s Registered agent Corporation Service Company, was served in Carson City, 112 North Curry Strret, 89703

Link to affidavit of service on Nationstar

Service on Republic Services

Service on Republic Services was unnecessary because its liens were released in 2017.

Republic Services was served on 2/16/21 at 12:23 PM via the Danielle Nakicommercial agent CT Corporation System, 701 S. Carson St., Ste. 200, Carson City 89701