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Case 17-05016-btb Doc 16 Entered 08/18/17 14:12:53 Page 1 of 21
Adam McMillen
amcmillen@bhfs.com
BROWNSTEIN HYATT FARBER SCHRECK, LLP
Telephone: 775.324.4100
Facsimile: 775.333.8171
Attorneys for JED MARGOLIN
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF NEVADA
Case No. BK-N-16-50644-BTB
Adversary No. 17-05016-BTB
ANSWER AND AFFIRMATIVE DEFENSES OF JED MARGOLIN TO THE CROSS CLAIMS OF PATRICK CANET
In Re JAZI GHOLAMREZA ZANDIAN,
Debtor.
__________________________________/
FRED SADRI, AS TRUSTEE FOR THE STAR LIVING TRUST, DATED APRIL 14, 1997; RAY KOROGHLI AND SATHSOWI T. KOROGHLI, AS MANAGING TRUSTEES FOR KOROGHLI MANAGEMENT TRUST,
Plaintiffs,
v.
JED MARGOLIN; JAZI GHOLAMREZA ZANDIAN; and all other parties claiming an interest in real properties described in this action,
Defendants.
__________________________________/
PATRICK CANET,
v.
FRED SADRI, INDIVIDUALLY AND AS TRUSTEE FOR THE STAR LIVING TRUST; RAY KOROGHLI, INDIVIDUALLY; RAY KOROGHLI AND SATHSOWI T. KOROGHLI, AS MANAGING TRUSTEES FOR KOROGHLI MANAGEMENT TRUST.
__________________________________/
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PATRICK CANET,
v.
JED MARGOLIN.
______________________
Defendant Jed Margolin, by and through his counsel of record, Adam McMillen, hereby responds to the specific numbered paragraphs of Patrick Canet’s Cross Claims against Margolin, as follows:[1]
ANSWER
Answering the numbered paragraphs of the Cross Claims, Jed Margolin states as follows:
PARTIES, JURISDICTION AND VENUE
40.
Margolin admits that he is a resident of
41. Margolin admits that jurisdiction is proper and consents to entry of a final order or judgment by the Bankruptcy Court.
GENERAL ALLEGATIONS
42. Margolin denies that he filed a civil action against Zandian and Optima in the Ninth Judicial District in December 2009. Margolin filed his civil action against Zandian and Optima in the First Judicial District Court of Nevada in December 2009.
43. Margolin admits that in March 2011 a default judgment was entered against Zandian and Optima in the First Judicial District Court of Nevada, that the default judgment was set aside, that Margolin filed an amended complaint, and that the District Court allowed service of the summons by publication.
44. Margolin admits the allegations in ¶ 44.
__________________________
[1]
The other portions of Patrick Canet’s Answer,
Counterclaims and Cross Claims are specifically denied as they do not pertain
to Margolin or Margolin
does not have sufficient information or knowledge in order to admit or deny
those portions, unless otherwise noted herein.
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45. Margolin admits the allegations in ¶ 45.
46. Margolin admits the allegations in ¶ 46.
47. Margolin admits the allegations in ¶ 47.
48. Margolin admits the allegations in ¶ 48.
49. Margolin admits the allegations in ¶ 49.
50. Margolin admits the allegations in ¶ 50.
51. Margolin admits the allegations in ¶ 51.
52. Margolin admits the allegations in ¶ 52.
53. Margolin admits the allegations in ¶ 53.
54. Margolin admits the allegations in ¶ 54.
55. Margolin admits that on May 19, 2016, Canet filed his Chapter 15 Petition For Recognition of Foreign Proceeding. Canet’s Petition was filed 16 days after Margolin filed his Motion to Void Deeds, Assign Property, For Writ of Execution and to Convey in the First Judicial District Court of Nevada on May 3, 2016. See Exhibit 1, Motion to Void Deeds, Assign Property, for Writ of Execution and to Convey, filed 5/3/16 with the First Judicial District Court in Case No. 09OC00579 1B. Margolin also notes that on June 3, 2016, Margolin’s motion was subjected to an automatic stay due to Canet’s Chapter 15 Petition. See Exhibit 2, Notice of Bankruptcy Filing and Automatic Stay, filed 6/3/16 with the First Judicial District Court, in Case No. 09OC00579 1B.
56. Margolin
admits that this Court granted Canet’s request for
recognition of the foreign proceeding in September 2016, but the hearing where Canet’s Chapter 15 Petition was granted was held on
September 6, 2016. Margolin notes that it was at the
same hearing where Canet promised the Court that if Canet’s Chapter 15 Petition were granted, he would file a
Chapter 7 bankruptcy for Zandian. This has not been
done.
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57. Margolin admits the allegations contained in paragraph 57 of the complaint. A true and correct copy of the Sheriff’s Certificate of Sale of Property for APN 084-130-07 recorded in the Washoe County Recorder’s Office as Book and Instrument Number 4456021 is reproduced in the Sadri/Koroghli Complaint as Exhibit 9 thereto.
58. Margolin admits the allegations contained in paragraph 58 of the complaint. A true and correct copy of the Sheriff’s Deed Upon Execution of Real Property for APN 084-130-07 recorded in the Washoe County Recorder’s Office as Book and Instrument Number 4630134 is attached to Sadri/Koroghli Complaint as Exhibit 10 thereto.
59. Margolin admits the allegations contained in paragraph 59 of the complaint. A true and correct copy of the Sheriff’s Certificate of Sale of Property for APN 084-130-10 recorded in the Washoe County Recorder’s Office as Book and Instrument Number 4456020 is reproduced in Sadri/Koroghli Complaint as Exhibit 13 thereto.
60. Margolin admits the allegations contained in paragraph 60 of the complaint. A true and correct copy of the Sheriff’s Deed Upon Execution of Real Property for APN 084-130-10 recorded in the Washoe County Recorder’s Office as Book and Instrument Number 4630135 is attached to Sadri/Koroghli Complaint as Exhibit 14 thereto.
61. Margolin admits the allegations contained in paragraph 61 of the complaint. A true and correct copy of the Sheriff’s Certificate of Sale of Property for APN 084-040-02 recorded in the Washoe County Recorder’s Office as Book and Instrument Number 4456032 is reproduced in Sadri/Koroghli Complaint as Exhibit 11 thereto.
62. Margolin
admits the allegations contained in paragraph 62 of the complaint. A true and
correct copy of the Sheriff’s Deed Upon Execution of
Real Property for APN 084-040-02 recorded in the Washoe County Recorder’s
Office as Book and Instrument Number 4630133 is attached to Sadri/Koroghli Complaint as Exhibit 12 thereto.
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63. Margolin admits the allegations contained in paragraph 63 of the complaint. A true and correct copy of the Sheriff’s Certificate of Sale of Property for APN 079-150-12 recorded in the Washoe County Recorder’s Office as Book and Instrument Number 4456017 is reproduced in Margolin’s Exhibits as Exhibit 3. Margolin notes that this property was not part of the Sadri/Koroghli Complaint.
64. Margolin admits the allegations contained in paragraph 64 of the complaint. A true and correct copy of the Sheriff’s Deed Upon Execution of Real Property for APN 079-150-12 recorded in the Washoe County Recorder’s Office as Book and Instrument Number 4630125 is reproduced in Margolin’s Exhibits as Exhibit 4. Margolin notes that this property was not part of the Sadri/Koroghli Complaint.
65. Margolin admits the allegations contained in paragraph 65 of the complaint. A true and correct copy of the Sheriff’s Deed Upon Execution of Real Property for Clark County APN 071-02000-005 recorded in the Clark County Recorder’s Office as Book and Instrument Number 2016-1019-0000379 is reproduced in Margolin’s Exhibits as Exhibit 5. A true and correct copy of the Sheriff’s Deed Upon Execution of Real Property for Clark County APN 071-02000-013 recorded in the Clark County Recorder’s Office as Book and Instrument Number 2016-10190000378 is reproduced in Margolin’s Exhibits as Exhibit 6. Margolin notes that these properties were not part of the Sadri/Koroghli Complaint.
FIRST CROSS CLAIM
United Nations Commission on International Trade (UNCITRAL), Articles 21, 22 and 23, 11 U.S.C. §§ 1520, 1507 and 1521(a), Article L.632-1, French Commercial Code[2]
66. Paragraph 66 is an incorporation paragraph that is neither admitted nor denied.
67. Margolin denies the allegations of paragraph 67 of the Crossclaim.
________________________
[2]
Margolin denies the applicability of UNCITRAL and the
French Commercial Code. Margolin also denies 11
U.S.C. §§ 1520, 1507 and 1521(a) provide the relief Canet
is demanding.
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68. Margolin denies the allegations of paragraph 68 of the Crossclaim.
69. Margolin denies the allegations of paragraph 69 of the Crossclaim.
SECOND CROSS CLAIM
United Nations Commission on International Trade (UNCITRAL), Articles 21, 22 and 23, 11 U.S.C. §§ 362(a), 1520(a), 1507 and 1521(a), Article L.632-1, French Commercial Code[3]
70. Paragraph 70 is an incorporation paragraph that is neither admitted nor denied.
71. Margolin denies the allegations of paragraph 71 of the Crossclaim.
AFFIRMATIVE DEFENSES
Margolin asserts the following affirmative defenses, reserving the right to assert additional defenses when and if they become appropriate.
I. Introduction
A.
Margolin promptly recorded his June 24, 2013
Judgment against Zandian in the various
________________________
[3] Margolin denies the
applicability of UNCITRAL and the French Commercial Code. Margolin
also denies 11 U.S.C. §§ 362(a), 1520, 1507 and 1521(a) provide the relief Canet is demanding.
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B. Canet does not have standing to answer the Sadri/Koroghli Adversary Complaint because he is not named in the Adversary Complaint. Even if Canet did have standing, his Answer is untimely.
C. The property.
1.
Margolin obtained his Default Judgment
against Zandian on June 24, 2013 in the First
Judicial District Court of Nevada after Zandian’s
first attorney (Mr. John Peter Lee) withdrew from the case. Zandian’s
second attorney (Mr. Johnathon Fayeghi), moved to have the Judgment set aside. His motion was denied
and he withdrew from the case. Zandian’s third
attorney (Mr. Jason Woodbury of Kaempfer Crowell)
filed several appeals with the Nevada Supreme Court, which affirmed the Default
Judgment. See Exhibit 18,
2. During his appeals
related to the Default Judgment, Zandian recorded
fraudulent conveyances of his property in the various
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3.
Because Zandian had refused to post a supersedeas bond for his appeals, Margolin
obtained a Writ of Execution. See Exhibit 19,
Order Re: Writ of Execution issued by the First Judicial District Court of
Nevada, filed 8/18/2014. In December 2014, Margolin
obtained Writs of Execution against some of Zandian’s
properties. See Exhibit 20, Writ of Execution to
the Clark County Sheriff, issued by the First Judicial District Court of
Nevada, dated 9/5/2014 and Exhibit 21, Writ of
Execution to the Washoe County Sheriff, issued by the First Judicial District
Court of Nevada, dated 9/10/2014. The Clark County Sheriff auctioned Zandian’s property in
The Washoe County Sheriff auctioned the following Zandian properties on April 3, 2015:
•
Washoe County APN 079-150-12 - See Exhibit 24,
Washoe County Sheriff Certificate of
•
Washoe County APN 079-150-10 - See Exhibit 25,
Washoe County Sheriff Certificate of
•
Washoe County APN 084-040-02 - See Exhibit 26,
Washoe County Sheriff Certificate of
•
Washoe County APN 084-130-07 - See Exhibit 27,
Washoe County Sheriff Certificate of
Margolin was
the only bidder and he purchased the properties. Other bidders could have been
scared away by Zandian’s fraudulent conveyances. The
auctions were held more than a year before Canet
filed his Chapter 15 Petition. The
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no longer owned the properties. They were subject to Zandian having the right of redemption for one year.
4.
Three of the properties in
5.
All of the Sheriff sales took place more than a year before Canet’s Chapter 15 Petition was filed. Zandian’s
right of redemption expired before Canet’s Chapter 15
Petition was filed. The Sheriffs’ Deeds were mere formalities and were proper
under
6. To rescind these lawful sales now would be contrary to law and highly prejudicial to Margolin and would go against public policy regarding the recording of the ownership of (and liens on) property. No one would know if the property they had lawfully purchased would be taken away from them years later by a surprise claim such as Canet’s.
D. Canet’s Chapter 15 Petition could be contrary to 31 CFR
§560 and Executive Order 13599 and possibly a fraud upon the Court.
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1. Although
most of the sanctions against
a. It is still illegal to send money to the Government of Iran. See Exhibit 13 (Paragraph A.3), Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA) on Implementation Day, downloaded on or after October 7, 2017 [typo, should be 2017] from
https://www.treasury.gov/resource-center/sanctions/Programs/Documents/jcpoa_faqs.pdf .
b. Bank Melli of Iran is considered the same as the Government of Iran. See 31 CFR §560.304; Executive Order 13599 List (lists Bank Melli as an entity to be considered the same as the Government of Iran); Exhibit 14 (Excerpt from the list referred to in Executive Order 13599 List, which lists Bank Melli as an entity to be considered the same as the Government of Iran); the full list is at www.treasury.gov/resource-center/sanctions/Programs/Pages/13599_list.aspx .
c.
The 1998 French Judgment against Zandian was for up to 20M francs. Most of it (19M francs,
about 95%) was for the benefit of Bank Melli. See Exhibit 16, Document 2002L00750 from the
2.
At some point the
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has already collected at least 450,000 euros from Zandian.
a. Canet sold a property
belonging to Zandian at
b. Zandian also paid Canet 150,000 euros; and
c.
The debt to Bank Melli
had not been definitely approved as of 2011. See Exhibit
17, Document 2011L00791 from the
Canet has
not produced any evidence that Bank Melli’s claim was
ever approved by the
E. At the September 6, 2016 hearing, Canet promised that if his Chapter 15 Petition was granted, he would file a Chapter 7 bankruptcy for Zandian, either a voluntary Chapter 7 or an involuntary Chapter 7. At that hearing the Court granted Hartman’s Chapter 15 Petition. Canet has not filed Chapter 7 for Zandian.
F. Canet left out a few important events in the case.
1. Margolin filed his Motion to Void Deeds in the First Judicial District Court of Nevada on May 3, 2016. See Exhibit 1. The purpose of the Motion to Void Deeds was, in part, to void the fraudulent deeds that Zandian had recorded. Zandian did not oppose the motion.
2. Instead, Canet filed his Chapter 15 Petition For
Recognition of Foreign Proceeding on May 19, 2016, only 16 days later.
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3. On June 3, 2016, Margolin’s Motion to Void Deeds was subjected to an automatic stay due to Canet’s Chapter 15 Petition. See Exhibit 2, Notice of Bankruptcy Filing and Automatic Stay, filed 6/3/16 with the First Judicial District Court, in Case No. 09OC00579 1B.
G.
Canet has not provided any evidence that Zandian is or was insolvent. However, there is evidence
that Zandian might not be insolvent. While the
Settlement Agreement does not apply to the Pahrah
properties (because it was not recorded in
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LLC. In
Margolin’s case against Zandian
in the First Judicial District Court of Nevada, Zandian
refused to provide his financial records even though it resulted in a warrant
being issued for Zandian’s arrest. Canet had the opportunity of going after Zandian’s
H. In Canet’s FIRST CROSS CLAIM he cites as authorities: United Nations Commission on International Trade (UNCITRAL), Articles 21, 22 and 23, 11 U.S.C. §§ 1520, 1507 and 1521(a), Article L.632-1, French Commercial Code.
1. The United Nations Commission on International Trade (UNCITRAL), Articles 21, 22 and 23 are about arbitration. See Exhibit 9, United Nations Commission on International Trade (UNCITRAL), Articles 21, 22 and 23 Downloaded 8/11/2017 from:
https://www.uncitral.org/pdf/english/texts/arbitration/arb-rules/arb-rules.pdf . There is nothing in this case that mandates arbitration. Canet has not asked for arbitration.
2. Article
L.632-1, French Commercial Code appears to apply to debtor companies. See Exhibit 10 (English translation), the translation
of Article L.632-1 of the French Commercial Code; Exhibit
11 (French), the original French for L632-1. This does not apply to Margolin or Sadri/Koroghli. Indeed,
it seems to nullify some of the actions that Zandian
has engaged in, including recording fraudulent conveyances in several
3.
11 U.S.C. §§ 1520, 1507 and 1521(a): The relief that Canet
is requesting is at the discretion of the Court and must also protect the
interests of the creditors. Margolin is a major
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Zandian
creditor. The evidence shows Margolin’s
interests in Zandian’s assets take priority over Canet’s interest and Canet does
not have any legal rights to Zandian’s
First Affirmative Defense
To the extent applicable, Margolin hereby incorporates by reference all affirmative defenses set forth in Rule 8(c) of the Federal Rules of Civil Procedure, made applicable to this Adversary Proceeding pursuant to Rule 7008 of the Federal Rules of Bankruptcy Procedure.
Second Affirmative Defense
The Cross Claims fail to state a claim upon which relief can be granted.
Third Affirmative Defense
The Cross Claims and their claims for relief therein, are barred by the doctrine of estoppel.
Fourth Affirmative Defense
Canet, by their own conduct or the conduct of their predecessors in interest, have waived their claims asserted in the Cross Claims.
Fifth Affirmative Defense
The causes of action in the Cross Claims are barred, in whole or in part, because they are not supported by the material facts necessary to establish the claims.
Sixth Affirmative Defense
The causes of action in the Cross Claims are barred, in whole or in part, by the statute of limitations.
Seventh Affirmative Defense
Margolin
reserves the right to amend its answer to correct and add defenses as further
information regarding the Plaintiffs’ claims becomes available to it through
the course of discovery or otherwise.
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REQUEST
Wherefore, Defendant Margolin requests for judgment as follows:
1. That the FIRST CROSS CLAIM against Margolin be denied entirely;
2. That the SECOND CROSS CLAIM against Margolin be denied entirely;
3. That Canet’s Chapter 15 Petition be dismissed with prejudice;
4. That Canet’s Answer, Counterclaims and Cross Claims be stricken in their entirety;
5.
That the
Washoe County Document 4335754 recorded 03/18/2014 APN 079-150-12
Washoe County Document 4335755 recorded 03/18/2014 APNs 079-150-09, 079-150-10, 079-150-13, 084-040-02, 084-040-04, 084-040-06, 084-040-10, 084-130-07, and 084-140-17
Clark County Document 20140530-0001037 recorded 05/30/2014 APN 071-02000-005
Clark County Document 20140530-0001038 recorded 05/30/2014 APN 071-02000-013
Churchill County Document 439670 recorded 03/18/2014 APN 007-151-12
Churchill County Document 439671 recorded 03/18/2014 APN 007-151-77
Churchill County Document 439672 recorded 03/18/2014 APN 009-33-104
Elko County Document 684351 recorded 03/17/2014 APN 001-660-034
Lyon County Document 521531 recorded 05/21/2014 APNs 015-311-18/015-311-19
Lyon County Document 521532 recorded 05/21/2014 APNs 006-052-04, 006-05205, and 006-052-06
Lyon County Document 521533 recorded 05/21/2014 APN 015-311-02
6.
Declare that the unrecorded Sadri/Koroghli/Zandian
Stipulated Settlement shall have no effect on the
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purchasers for value.
7.
Declare that as the result of auctions lawfully held in
a.
b. Washoe County APN 079-150-12, APN 079-150-10, APN 084-130-07, and APN 084-040-02.
8. For attorney’s fees;
9. For costs incurred herein; and
10. For any and all further relief deemed appropriate by this Court.
DATED: August 18, 2017.
BROWNSTEIN HYATT FARBER SCHRECK, LLP
/s/ Adam P. McMillen
Adam P. McMillen, Esq.
Attorneys
for Defendant Jed Margolin
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CERTIFICATE OF SERVICE
Pursuant to Fed. R. Civ. P. 5(b), I certify that I am an employee of BROWNSTEIN HYATT FARBER SCHRECK, LLP, and on this 18th day of August, 2017, I served the document entitled ANSWER AND AFFIRMATIVE DEFENSES OF JED MARGOLIN TO THE CROSS CLAIMS OF PATRICK CANET on the parties listed below via the following:
Dana Jonathon Nitz, Esq.
Yanxiong Li, Esq.
Attorneys for Plaintiffs
Fred Sadri, as Trustee for The Star Living Trust, dated April 14, 1997; Ray Koroghli and Sathsowi T. Koroghli, as Managing Trustees for Koroghli Management Trust
Jeffrey L. Hartman, Esq.
Hartman & Hartman
Attorney for Patrick Canet
[X]
VIA FIRST CLASS U.S. MAIL: by placing a true copy thereof enclosed in a sealed
envelope with postage thereon fully prepaid, in the
/s/ Nancy R. Lindsley
Employee of Brownstein Hyatt
Farber
Schreck, LLP
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EXHIBIT LIST
|
EXHIBIT NO. |
DESCRIPTION |
PAGE(S) |
|
Motion to Void Deeds, Assign Property, for Writ of Execution and to Convey, filed 5/3/16 with the First Judicial District Court in Case No. 09OC00579 1B |
303 |
|
|
|
|
|
|
Notice of Bankruptcy Filing and Automatic Stay, filed 6/3/16 with the First Judicial District Court, in Case No. 09OC00579 1B |
3 |
|
|
|
|
|
|
|
|
|
|
Sheriff’s Certificate of Sale, Washoe County APN 079-150-12, as recorded with the Washoe County Recorder’s Office on 4/9/2015 as Document No. 4456017 |
3 |
|
|
|
|
|
|
Sheriff’s Deed Upon Execution of Real Property for APN 079-150-12 recorded in the Washoe County Recorder’s Office as Book and Instrument Number 4630125, recorded 9/8/2016 |
4 |
|
|
|
|
|
|
Sheriff’s Deed Upon Execution of Real Property for Clark County APN 071-02000-005 recorded in the Clark County Recorder’s Office as Book and Instrument Number 2016-1019-0000379, recorded 10/19/2016 |
6 |
|
|
|
|
|
|
Sheriff’s Deed Upon Execution of Real Property for Clark CountyAPN 071-02000-013 recorded in the Clark County Recorder’s Office as Book and Instrument Number 2016-1019-0000378, recorded 10/19/2016 |
6 |
|
|
|
|
|
|
Zandian’s recorded fraudulent conveyances in
several |
53 |
|
|
|
|
|
|
Default Judgment - Margolin’s Judgment against Zandian as recorded in the following Nevada Counties:
|
26 |
|
|
|
|
|
|
United Nations Commission on International Trade (UNCITRAL), Articles 21, 22 and 23 Downloaded 8/11/2017 from: https://www.unitral.org/pdf/english/texts/arbitration/art-rules/arbrules.pdf |
27 |
|
|
|
|
|
|
The translation of Article L.632-1 of the French Commercial Code. |
6 |
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|
10 (con’t) |
Downloaded 8/11/2017 as part of a much larger document (772 pages) containing all of the French Commercial Codes from: https://www.legifrance.gouv.fr/Media/Traductions/English-en/code_commerce_part_L_EN_20130701
Legifrance is the French government entity responsible for publishing legal texts online. |
|
|
|
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|
|
The original French for L632-1 Downloaded 8/11/2017 from:
https://www.legifrance.gouv.fr/affichCode.do;jsessionid= CC4339D25DFA59D54DB206BE5A5EAA7C.tpdila18v_3?idSectionTA= LEGISCTA000006146112&cidTexte= LEGITEXT000005634379&dateTexte=20130701
Legifrance is the French government entity responsible for publishing legal texts online. https://www.legifrance.gouv.fr/Traductions/en-English |
3 |
|
|
|
|
|
|
A
search of the databases of the relevant |
8 |
|
|
|
|
|
|
Frequently Asked Questions Relating to the Lifting of Certain U.S. Sanctions Under the Joint Comprehensive Plan of Action (JCPOA) on Implementation Day downloaded on or after October 7, 2017 from https://www.treasury.gov/resource-center/sanctions/Programs/Documents/jcpoa_faqs.pdf |
46 |
|
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|
|
|
|
Excerpt from the list referred to in Executive Order 13599 List which lists Bank Melli as an entity to be considered the same as the Government
of www.treasury.gov/resource-center/sanctions/Programs/Pages/13599_list.aspx |
3 |
|
|
|
|
|
|
Document
from the Date: Purchased and downloaded 8/7/2016 |
2 |
|
|
|
|
|
|
Document
2002L00750 from the (Infogreffe.fr is “les greffes des tribunaux de commerce” which is “The Registrars of Commercial Courts.”)
Date: Purchased and downloaded 8/7/2016
Followed by English translation purchased from Vanan Online Services (www.vananservices.com) Translation performed 8/30/2016 |
8 |
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|
Document
2002L00791 from the Followed by English translation purchased from Vanan Online Services (www.vananservices.com) Translation performed 9/19/2016 |
13 |
|
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Order of Affirmance, Nevada Supreme Court Document 15-31719 affirms First Judicial District Court of Nevada in Case Nos. 65205 and 65960, filed 10/19/2015 |
4 |
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Order Re: Writ of Execution issued by the First Judicial District Court of Nevada, filed 08/18/2014 |
4 |
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Writ of Execution to the Clark County Sheriff, issued by the First Judicial District Court of Nevada dated 09/5/2014 |
6 |
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Writ of Execution to the Washoe County Sheriff, issued by the First Judicial District Court of Nevada dated 09/10/2014 |
7 |
|
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Clark County Sheriff’s Certificate of Sale of Real Property for APN 071-02000-005 filed 01/8/2015 |
3 |
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Clark County Sheriff’s Certificate of Sale of Real Property for APN 071-02000-013 filed 01/8/2015 |
3 |
|
|
|
|
|
|
Washoe
County Sheriff Certificate of |
3 |
|
|
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|
Washoe
County Sheriff Certificate of |
3 |
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|
Washoe
County Sheriff Certificate of |
3 |
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Washoe
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Motion to Withdraw as Counsel filed by Kaempfer Crowell with the First Judicial District Court of Nevada, Case No.090C099679 1B |
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Warrant of Arrest issued for Zandian by First Judicial District Court of Nevada of Court, filed 2/3/2016 |
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Grant, Bargain and Sale Deed, recorded on 8/19/2010 with the Elko County Recorder, as Document No. 629773 (The settlement of the |
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Case 17-05016-btb Doc 16 Entered 08/18/17 14:12:53 Page 21 of 21
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Fronteer Development lawsuit was recorded in |
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Real Property Assessment Data for Sparks Village LLC - owns Washoe County APN 084-140-11 (219.712 Acres). Was bought in 2005 for $750,000. From Washoe County Assessor Web site. |
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Zandian Certificate of Resignation as Manager
of |
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NV SOS Entity Details re Sparks Village, LLC (The remaining member and registered agent of Sparks Village LLC is Sean S. Fayeghi - Downloaded from Nevada Secretary of State’s database 10/07/2016) |
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