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 www.auction.com $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 auction.com 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.

Nona Tobin Declaration Under Penalty of Perjury

I, Nona Tobin, under penalty of perjury, state as follows:

I have personal knowledge of the facts stated herein, except for those facts stated to be based upon information and belief. If called to do so, I would truthfully and competently testify to the facts stated herein.

I am submitting the documentary evidence based on my personal knowledge, research, analysis, and/or experience.

I was forced into this litigation because Sun City Anthem attorney David Ochoa unilaterally obstructed my access to SCA CC&Rs XVI: Limits on Litigation alternative dispute resolution

See my 3/22/17 offer to settle at no cost to me or to the HOA that David Ochoa rejected, upon information and belief, based on his own imaginary authority or through consultation with HOA community managers, Sandy Seddon and/or Lori Martin.

My involvement with the courts in Nevada has 100% been a thus-far futile attempt to regain title to a house that was wrongly foreclosed and secretly sold by Red Rock Financial Services on 8/15/14, three months after I had approved a sale to the high bidder on auction.com.

Upon information and belief, the extreme abuse to which I have been subjected is only understandable if the opposing counsels are aiding and abetting their clients’ criminal actions, covering up their clients’ misdeed, and/or for their own unjust enrichment.

I have made the following videos and posted them on You-tube in an effort to simplify and publish the massive amount of evidence I have to support my claims that heretofore these attorneys have successfully suppressed and blocked from judicial scrutiny.

VIDEO 1:20-minute VIDEOHow did Nona Tobin lose the $500,000 house she inherited from Bruce Hansen?

4:52-minute VIDEO “How lenders cheat owners out of their houses

Over the last five years, no judge has looked at any evidence in district court cases A-15-720032-C, A-16-730078-C, or A-19-798990-C

7:39-minute VIDEO  “Complaint to the Nevada Commission on Judicial Discipline vs. Judge Kishner

2:08-minute VIDEO Is justice blind or is it just blinded by power or pals?

1:44-minute VIDEO “Please Judge Johnson

3:50-minute VIDEO “What evidence supports Nona Tobin’s claims?” – Craig Leidy declaration

1:56-minute VIDEO “All declarations under penalty of perjury support Nona Tobin

When all statements under oath support Nona Tobin, why does she keep losing?” 3-page blogpost with links to all declarations made under penalty of perjury.

Over the last five years, every opposing counsel lied to the court.

presented false evidence, concealed and misrepresented material facts, and obstructed a fair adjudication of my claims on their merits. 

2:48-minute VIDEO “Who started it?

5:53-minute VIDEO “Joseph Hong’s big ex parte lies

1:41-minute VIDEO “Plaintiffs did not meet their burden of proof

6:33-minute VIDEO “Nationstar lied about being owed $389,000

1:22-minute VIDEO “Joseph Hong dupes Judge Johnson

1:33-minute VIDEO “Judicial Jiu-Jitsu is fraud on the court

3:09-minute VIDEO “Nationstar kept changing its story to cover up the lie

2:05-minute VIDEO “Failure of Nevada civil courts to address white collar crime

17:53-minute VIDEO “Specific evidence of fraud against Nationstar

2:46-minute VIDEO “How Nationstar & Jimijack tricked the court into excluding all evidence

1:37-minute VIDEO “Nevada state courts are rigged

3:58-minute VIDEO “Remember Joseph Hong?”

3:36-minute VIDEO Why did Quicken secure a house that was already mortgaged?

2:24-minute VIDEO What does it take to get disbarred in Nevada?

2:59-minute VIDEO “Nationstar plays the IOU trick to steal from Nona Tobin

1:52-minute VIDEO “What kind of legal entity is Jimijack Irrevocable Trust?”

1:01-minute VIDEO “What is Jimijack Irrevocable Trust?”

4:52-minute VIDEO “How lenders cheat owners out of their houses

6:18-minute VIDEO “Nationstar and Joel Stokes stole my $500,000 house

0:50-minute VIDEO “10 reasons why to sanction Joseph Hong

7:39-minute VIDEO  “Complaint to the Nevada Commission on Judicial Discipline vs. Judge Kishner

1:01-minute VIDEO “A Simple Fable: Nationstar’s & Jimijack’s duel to the death

Actual damages to me personally

The consequences of this successful fraud perpetrated primarily by attorneys:

  1. The title to a $500,000 house was taken from me by a fraudulently conducted-unnoticed foreclosure sale,
  2. Nationstar stole from me the $389,000 outstanding Western Thrift & Loan debt of deceased borrower Gordon Hansen that I did not owe to anyone and was not owed to Nationstar by anyone,
  3. Joel and Sandra Stokes kept $100,000+ in over five years of rental profits that belong to me,
  4. Red Rock attorneys Koch & Scow retained $60,000 that they refused to distribute to me in 2014 and has now accrued plus six years of interest and costs to pursue my claim against massive obstruction
  5. I have been forced to expend tens of thousands of dollars on litigation costs and thousands of hours of personal time to attempt to recover what was stolen from me.

2:38-minute VIDEO “What happened after Sun City Anthem refused Nona Tobin’s 2017 offer to settle?

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,

All declarations under penalty of perjury support Nona Tobin’s claims

Because she is not a party to the case, all documents filed with this Court by Nona Tobin as an individual, are rogue documents and are stricken from the record. This includes both the Motion to Dismiss and Motion for New Trial (and all oppositions or replies) and the Notice of Lis Pendens.

11/22/19 Judge Kishner order, Page 4, paragraph 3

If all statements under oath support Nona Tobin’s claims, why does she keep losing?

  1. 4/15/19 Teralyn Lewis AFFD Teralyn Lewis, custodian of records authenticated the Ombudsman’s HOA foreclosure notice of sale compliance records for 2763 White Sage and 16 other HOA foreclosures related to Sun City Anthem and/or Joel Stokes/Joseph Hong.
    1. At the 3/26/19 hearing 3/26/19 hearing (3/26/19 annotated transcript3/26/19 minutes, 3/26/19, RTRAN, Judge Kishner accepted the HOA attorney David Ochoa’s misrepresentation of the Red Rock foreclosure file as verified evidence after he concealed in discovery the HOA’s actual official records (HOA Board minutes, 2/26/19 HOA RESP 2 ROGs, 2/26/19 HOA RESP 2 RFDs, Resident Transactions Report) that contradicted the Red rock foreclosure file.
    1. Judge Kishner rejected sua sponte the State of Nevada Ombudsman for the Owners in Common Interest Communities’ HOA foreclosure notice of sale compliance records on the grounds that the compliance screen (that I filed into the court record multiple times unchallenged (Tobin 080 (Exhibit 14, p. 112)) was not verified and, even if verified, it was not evidence of a disputed material fact.
    1. The same record verified by the Nevada Real Estate Division Custodian of Records Teralyn Lewis was resubmitted to support the motion for reconsideration as exhibit 7 to the 509-page 5/23/19 reply (See linked 5/23/19 TOC).
    1. Judge Kishner also declared stricken from the record my 4/17/19 621-page Reply to support my pro se 4/10/19 JMOT/MSJ joinder to Nationstar’s motion for summary judgment against Jimijack (also stricken) that included the authenticated Ombudsman’s HOA foreclosure notice of sale compliance records as an exhibit. See 12-page table of contents of the 4/17/19 filed, but stricken unheard, documentary evidence.
    1. In her 5/31/19 denial of the motion to reconsider her 4/18/19 motion, Judge Kishner concluded

The substantial exhibits that have been submitted in the case demonstrate that Nona Tobin as Trustee of the Trust was aware of the foreclosure and did not seek to stop the foreclosure.”

5/31/19 Judge Kishner order to deny reconsideration of the 4/18/19 order that granted the HOA’s highly disputed motion for summary judgment and Nationstar’s fraudulent joinder

Nothing could be farther from the truth. Red Rock’s only notice, recorded on 2/12/14, announcing a 3/7/14, 10 A.M foreclosure sale, was cancelled. No notice whatsoever was given for an 8/15/14 sale, and Red Rock never even gave any notice afterward that it had been sold.

The idea that I was aware a sale was going to happen and didn’t try to stop it is preposterous.
  • 1/17/17  Nona Tobin declaration regarding failed attempts to get a notary record for the defective Jimijack deed
  • 6/14/2016 Linda Proudfit, co-owner Proudfit Realty, sworn declaration that the 311 broker files and 9 folders she delivered to Tobin on 6/14/16 “are a true, correct and complete copy of any and all documents for (Client Name) The Gordon B. Hansen Trust, dated 8/22/08, Nona Tobin, Successor Trustee”. This declaration is significant for two reasons:
    • None of Red Rock’s or the HOA’s or the Berkshire Hathaway broker’s subpoena response have  “verifications” that say these words “are a true, correct and complete copy of any and all documents”
    • My statements under oath, e.g., that I did not receive notices that Red Rock claims to have sent or that Bank of America never recorded a notice of default on the Hansen deed of trust but refused to allow escrow to close on two fair market value sales  are corroborated by the presence or absence of those records in Doug and Linda Proudfit Realty’s official broker records.
  • 3/5/2019 DECL: Nona Tobin 3/5/19 opposing Sun City Anthem motion for Summary Judgment as the HOA was relying on the fraudulent records of the debt collector rather than requiring that its agents obey the law. Judge Kishner ignored this opposition that was filed an hour before (3/5/19 3:31 PM OPPM) sua sponte filed a 3/5/19 (4:45 PM) minute order to grant the HOA’s MSJ and Nationstar’s unsupported joinder as unopposed. Judge Kishner also ignored this declaration under penalty of perjury in both her 3/5/19 minute order and 4/18/19 order.
  • 3/14/19 Tobin DECL  DECL: Nona Tobin 3/14/19 AG Complaint 2-2019 opposing Nationstar lying about being owed $389,000 from the Hansen promissory note was rejected on 12/4/20 for lack of jurisdiction
    • 3/26/19 AG email response was that the complaint had been referred to “the appropriate investigative unit within the Office of the Attorney general for review” and that I would be contacted if they had any questions.
    • 12/4/20 AG email response rejected the complaint as outside of the AG’s jurisdiction “After careful review, it had been determined your complaint references allegations beyond the jurisdiction of this office.”
  1. 4/20/19 DECL Nona Tobin declaration under penalty of perjury, included with 5/23/19 Tobin Reply to opponents’ opposition to motion for reconsideration of 4/18/19 Kishner order This was included as exhibit 1 to the 509-page 5/23/19 reply (See linked 5/23/19 TOC).
  1. 4/29/19  Nona Tobin declaration under penalty of perjury, included with 4/29/19 motion to reconsider was not considered by judge Kishner when she denied the motion for reconsideration at the 5/29/19 hearing (5/29/19 RTRAN, 5/29/19 minutes, 5/29/19 VIDEO
  1. 12/16/20 DECL (20 pages) Nona Tobin complaint to the Mortgage servicing division vs. Nationstar and its attorneys has
  1.  692 pages in its full form
    1. on 1/28/21 I received an email, dated 1/27/21, from the Mortgage Lending Division forwarding a rejection letter, dated 1/6/21, I have yet to receive in the mail as of 1/28/21.
  1. Nona Tobin’s analysis of the evidence supporting voiding the 8/15/14 HOA sale was published in “The HOA sale was fatally flawed

By Judge Kishner’s refusal to look at the evidence and her unfounded insistence that there were no disputed of material facts surrounding the conduct of the HOA sale based on her ex parte 4/23/19 meeting with opposing counsels, Judge Kishner

  1. declared stricken from the record my seven pro se filings – oppositions, joinders, motions for summary judgment and notices- filed between 4/9/19-4/17/19 because my attorney had not filed a motion to withdraw,[1] 
  2. ignored my 4/24/19 MVAC/MSJ motion to vacate her 4/18/19 order and motion for summary judgment against all parties, 
  3. denied my motion for reconsideration based on 509 pages of filed evidence in her 5/31/19 order,
  4. accepted without review of the settlement documents Jimijack-Nationstar’s fraudulent side deal recorded on 5/23/19 See 5/21/19 hearing 5/21/19 minutes,  5/21/19 RTRAN, 5/21/19 24:43-minute VIDEO
  5. ordered on 6/3/19 that all documentary evidence must be excluded from the trial,
  6. ignored my attorney’s timely 6/3/19 Tobin/Trust FFCL proposed findings of fact and conclusions of law and accepted Joseph Hong’s untimely and unsupported 6/5/19 Jimijack FFCL
  7. 6/5/trial 6/5/19 trial day 1 minutes, 6/5/19 trial day 1 RTRAN 6/6/19 trial day 2 50:42-minute VIDEO

Judge Kishner also declared stricken and unheard the Pro Se filings below by granting improper motions by Joseph Hong (8/7/19 RESP/MSTR/MAFC) for counter- defendants and David Ochoa for cross- defendant HOA (8/8/19 RESP/JMOT) at the 9/3/19 hearing

Judge Kishner refused to hear my 6/17/19 motion to intervene or consider my 6/21/19 DECL supporting declaration under penalty of perjury.

OPPONENTS’ CASES WERE NOT SUPPORTED BY VERIFIED, CORROBORATED EVIDENCE.

No documents filed by parties opposing Nona Tobin in cases A-15-7220032-C, A-16-730078-C, Nevada Supreme Court appeal 79295 or A-19-798990-C were verified, corroborated, or supported by affidavits under oath.

Listed here are examples of what my opponents presented as verified evidence

Presented as evidence but lacking any sworn affidavit authenticating the records or stating that they are accurate, authorized, true or complete

  1. 2/11/19 Julia Thompson Affidavit Red Rock’s clerical supervisor , Julia Thompson, signed a modified certification, stopping way short of saying the Red Rock foreclosure file was a true, accurate, contemporaneous and complete response to 2/4/19 subpoena. (RRFS 001-0425 served on 2/27/19)
  • Sun City Anthem disclosed the Red Rock foreclosure file (RRFS 001-425) as unverified SCA 176 – SCA 643 by serving a picture of a DVD Pg 8 right after their ridiculous Privileges Log) on 5/31/18 (so I had no access to them until 12/24/18 a month after SCA mediated in bad faith). The Red Rock Foreclosure File (redacted), was disclosed per NRCP 16.1 as if it were the HOA’s true, complete, and accurate compliance, enforcement and foreclosure records without any certification of accuracy and completeness. Red Rock’s records are directly contradicted by SCA Board minutes and compliance records that were withheld in discovery. The 7-page blogpost linked here, aptly entitled, “Disputed Facts in Red Rock Foreclosure File Disclosed as SCA 176-643”, lists facts alleged by attorneys Steven Scow and David Ochoa that I dispute with verified documentary evidence that Judge Kishner ignored or excluded in toto without reasonable cause, notice or an opportunity to be heard.
  • Red Rock and SCA disclosed between them 110 pages of proofs of service, return to sender, etc. to create the deception that notices were sent that were not. There are no proofs of service or returns to sender for any of the disputed notices, e.g., SCA 278, SCA 286, SCA 642-643 SCA 635, SCA 628
  • Judge Kishner also declared stricken from the record my 4/17/19 621-page Reply to support my pro se 4/10/19 joinder to Nationstar’s motion for summary judgment against Jimijack (also stricken) that included the authenticated Ombudsman’s HOA foreclosure notice of sale compliance records as an exhibit. See 12-page table of contents of the 4/17/19 filed, but stricken unheard, documentary evidence.
  • In her 5/31/19 denial of the motion to reconsider her 4/18/19 motion, Judge Kishner concluded “The substantial exhibits that have been submitted in the case demonstrate that Nona Tobin as Trustee of the Trust was aware of the foreclosure and did not seek to stop the foreclosure.”

Nothing could be farther from the truth.

Conclusion

The evidence supporting my claims is overwhelming, and there is virtually nothing supporting the claims of my opponents.

I am exhausted by my attempts to articulate what I consider to be a massive failure of the judicial system to ensure a fair adjudication of a quiet title dispute.

I feel the discouragement and frustration of being a Cassandra.

I feel the sense of futility the New York Times cataloguers of The Complete List of Trump’s 2015-1/8/21 Twitter insults (134 pages) must have felt. 

No matter how overwhelmingly one-sided the evidence is to support my claims, it is still probable – not just possible, but overwhelmingly probable – that many, many people – including those with the sworn duty to enforce the law and protect the Constitution by weighing, and acting on, the verified evidence – will still ignore ALL the evidence and keep believing in a reality based on “alternative facts”.

I am begging you, Nevada Commissioners for Judicial Discipline, to look at the evidence and act according to your oath of office. Do not sweep this under the rug.

Here is a link to my 333-page rough draft of my complaint which has a linked table of contents. I can’t do any more.

Thank you for your prompt consideration.

Prepared on January 28, 2021

I declare under penalty of perjury under the laws of the State of Nevada that the foregoing, and everything I say in all of these documents is true, correct, accurate as complete as I can make it.

Dated this 28th day of January, 2021.

Nona Tobin, President

Fight Foreclosure Fraud, Inc.


  1. [1] 4/9/19 Tobin/Hansen Trust Notice of completion of mediation
  2. 4/9/19Tobin Notice of appearance to return to Pro Se status
  3. 4/10/19 Tobin Opposition to Nationstar’s motion for summary judgment against Jimijack and countermotion for summary judgment
  4. 4/12/19 19 Tobin notice of appearance to return to Pro Se status as an individual (duplicate filed in error)
  5. 4/12/19 Tobin/Hansen Trust Notice of completion of mediation (duplicate filed in error)
  6. 4/12/19 Tobin OPPC vs Nationstar and Jimijack (duplicate filed in error)
  7. 4/17/19 Tobin reply to support joinder to Nationstar motion for summary judgment

4/23/19 orders from the ex parte 4/23/19 hearing and the orders from the 9/3/19 hearing (#21-25 were not formalized until 11/22/19 order was entered five months after the trial and nearly three months after the Supreme Court dismissed my claims (See 9/10/19 NV Supreme Court’s return of my docketing statement (27 pages) unfiled because I was not aggrieved by the loss of a $500,000 house, $100,000 in rents, $60,000 in Red Rock unlawfully retained proceeds.