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.
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